Planning Performance Framework Annual Reports

Introduction

This is a report to the Scottish Government on our performance within the Planning System during the period 1 April 2020 to 31 March 2021. It reports against a series of performance markers covering different elements of our engagement in the Planning System, and identifies priorities for improvement during the next reporting period from1 April 2021 to 31 March 2022. It follows a template agreed with the other Key Agencies and the Scottish Government.

Description of our service

Our planning service includes advice and associated guidance and capacity-building. It supports implementation of the Third National Planning Framework, and accords with Scottish Planning Policy and the Scottish Regulators’ Strategic Code of Practice. It helps deliver the Scottish Government’s commitment to tackling the twin challenges of climate change and biodiversity loss, and the transition to a net zero carbon economy that is fair for all. The service has a vital part to play in Scotland’s ’green recovery’ from the Covid-19 pandemic and ensuring a resilient nature-rich future.

Our Planning for Development service statement Planning for Great Places outlines our approach and the support that stakeholders can expect from us. It emphasises the connection between people, development and nature, and the importance of achieving the right development in the right place to make Scotland the best place to live, work, visit and do business. It focuses our efforts on upstream engagement in the Planning System; working together with business interests; and providing clear, early advice that is alert to other interests and provides certainty for investment. In summary, we:

• influence national strategic development policies and plans and associated Strategic Environmental Assessment (SEA);
• input to regional and local spatial plans as an active partner in Development and Marine Planning, master plans and action programmes;
• publish guidance and standing advice to help developers assess and minimise impacts on nature;
• provide pre-application advice to developers, and advice to decision-makers focused on matters of potential national interest;
• inform post consent monitoring at a strategic and project level to advance understanding of the impact of development on nature;
• build greater capacity amongst developers and planning authorities to identify nature-based solutions and make sustainable use of our natural assets.

Together with other public bodies and agencies we have embedded the Place Principle in the way we work, to help overcome organisational and sectoral boundaries, and encourage better collaboration and community involvement. The application of our balancing duties helps to make sure we are alert to wider social and economic interests when discharging our responsibilities for nature, and that we are helping to shape Scotland as an inclusive, fair, prosperous and innovative country.

The service delivers benefits that contributed to all four of the outcomes in our corporate plan Connecting People and Nature, around which our work is based:

1. More people across Scotland are enjoying and benefiting from nature.
2. The health and resilience of Scotland’s nature is improved.
3. There is more investment in Scotland’s natural capital and its management to improve prosperity and wellbeing.
4. We have transformed how we work.

2020/21 was a particularly challenging year with the impact of the Covid pandemic on staff wellbeing and availability, and on our ways of working. Despite the difficult circumstances we continued to provide a comprehensive service that has helped to progress key deliverables set out in our business plan for the 2020/21, including:

• Putting nature at the heart of the Planning System by influencing the new National Planning Framework and being an active, valued and influential partner in development planning and regional/city/island growth deals;
• Providing effective input to strategic sectoral and marine spatial planning, to guide sustainable use of our coasts and seas;
• Providing targeted and influential advice on proposals to enable good quality development that secures positive benefits for nature;
• Providing support to Local Authorities and others on how they can embed nature-based solutions to address Government climate change commitments;
• Engaging with key business interests and industry sectors to help them maximise the competitive advantage of nature and invest in the nature-based solutions required in response to the climate emergency and biodiversity crisis.

Organisational structure

The strategic direction of our engagement in the Planning System is provided by our Board and Senior Leadership Team. The service is delivered by Activity and Area teams. Our Supporting Good Development Activity coordinates our work within the Planning System. It leads onshore development advice, our input to development planning, working with Industry and strategic planning. To support this, our People & Places Activity provides advice on placemaking, green infrastructure and engagement with community planning; and our Sustainable Coasts and Seas Activity leads marine planning and development advice. Local delivery of the service across the country is through seven Area Teams (Northern Isles & North Highland, South Highland, Argyll & Outer Hebrides, Strathclyde & Ayrshire, Tayside & Grampian, Forth and Southern Scotland).

Resources

The service is funded through our Scottish Government grant-in-aid. Given the multiple benefits it achieves, we continued to invest a significant proportion of the grant-in-aid in planning and placemaking work. In 2020/21 this was approximately £4 million (8.6% of our £46.6 million grant-in-aid) and was made up of staff costs of about £3.5 million (76 full-time equivalents) and project costs of about £0.5 million.

Performance markers

Placemaking

Strategic planning

We contributed to strategic planning through our advice on a range of policies and plans, associated SEA and the development of plans for projects that are part of the Third National Planning Framework. Our contribution in 2020/21 included:

• supporting the implementation of the new Planning Act by inputting to the work programme for Transforming Planning in Practice as a member of Development Management Working Group and contributing to Key Agency input to other working groups;
• responding to Scottish Government’s position statement for the fourth National Planning Framework (NPF4) and follow up discussion with the NPF4 team;
• supporting the development of Regulations regarding the preparation of Open Space Strategies and Play Sufficiency Assessments as part of the OSSPSA Core Group;
• preparing a commissioned report for Scottish Government on options to deliver Scotland’s ambition for the planning system to secure Positive Effects for Biodiversity and sitting on the Working Group to consider how to take this issue forward in NPF4;
• issuing the ‘Green Recovery Offer’ to all local authorities in partnership with other members of the Key Agency Group Placemaking Sub-group, in order to encourage local authorities to work with the group in a more coordinated way to develop and inform evidence approaches for regional spatial strategies, local development plan preparation or for sites identified as a priority to support a Green Recovery;
• inputting to Scottish Government work to develop the Infrastructure Investment Plan;
• responding to Scottish Government consultations on Permitted Development Rights and regional economic zones;
• advising on 138 SEA consultations, from pre-screening to Environmental Reports (See Appendix, Table 1 for details), covering a wide range of policies and plans eg. Scottish Government’s Climate Change Plan, Infrastructure Investment Plan and Cleaner Air for Scotland strategy, Local Development Plans, Regional Transport Strategies, SG Hydrogen Action Plan and Basin Management Plans;
• responding to consultations on the National Transport Strategy and the second Strategic Transport Projects review, including Case for Change documents and advising Transport Scotland and its consultants on the Habitats Regulations Appraisal (HRA) process;
• inputting to the sustainability plans of energy transmission and distribution companies Scottish Power Energy Networks and Scottish & Southern Electricity Networks;
• continuing input to the work of the SCDI Clean Growth Leadership Group, including comments on the drafts of the Manifesto for Clean Growth which SCDI launched in December 2020;
• supporting Marine Scotland in their road map to deliver evidence needs identified in the Sectoral Marine Plan for Offshore Wind.

Development Plan engagement

We continued to be an active partner in Development Planning in 2020/21, supporting our commitment to a plan-led approach to development. Through engagement in the plan-making process, we planned for further investment in natural capital, helped to balance competing interests and guide development to the right places. Our contribution included advising on development frameworks, briefs and master plans, supplementary guidance, action programmes, SEA and HRA.

Appendix Table 1 shows the number of development planning consultations we received in 2020/21. We received a total of 64 statutory and non-statutory plan consultations. This was a significant reduction compared to previous years as consultations were delayed as a result of the Covid pandemic.

We responded positively to opportunities to engage early in the pre-Main Issues Report plan preparation process, for example:

• virtual charrettes held to inform the indicative Regional Spatial Strategy for Forth Valley;
• Edinburgh Council’s HRA of their emerging Proposed Plan;
• Highland Council’s trialling of a new approach to on-line engagement with their MIR for the Inner Moray Firth LDP;
• collaborative plan and policy making processes related to the Glasgow District Regeneration Frameworks, and contributing to the City’s policy response to the declaration of an Ecological Emergency;
• Phase 2 consultation for the West Edinburgh Spatial Strategy for Inclusive Growth (WE-SSIG) including advice on opportunities for nature networks, green active travel and nature-based solutions.

Development Management

We provided advice on 491 planning application consultations (excluding ‘no comment’ responses). We advised developers, local authorities and agencies on the impact of development proposals on nature, including advice on mitigation. This has enabled the delivery of development priorities across a range of industrial sectors including housing, renewable energy, manufacturing, transport, marine development, fish farming and telecommunications. We also provided advice and support to the Planning and Environmental Appeals Division (DPEA) as a member of the DPEA Stakeholders Group.

Pre-application engagement

Our early pre-application engagement aimed to support a more efficient Planning System. It allowed issues to be identified early in the development and planning process, and afforded time to try and resolve issues ahead of applications being submitted. We responded to 196 pre-application consultations, often in collaboration with other key agencies. This is a similar number to that in the previous couple of years. Examples of pre-application engagement in 2020/21 include:

• continued support for the Scottish and UK Government expansion of digital infrastructure, including the roll out of the Emergency Services Network, Shared Rural Network and Scottish 4G Infill Programme;
• advice on a mixed-use solar, battery and hydrogen proposal at Whitelee wind farm;
• liaison with landscape consultants to agree the National Scenic Area and wild land assessments (Chleansaid wind farm, Corriegarth 2 wind farm and Loch Liath wind farm, Corrievarchie pump hydro scheme);
• meeting with Simply Blue Aquaculture to discuss the site selection and constraints for semi-closed fish farms within the Highlands;
• advising consultants on gaps in ecological and landscape surveys for development proposals resulting from Covid travel restrictions;
• providing advice and support for Transport Scotland’s A83 Access project;
• improving plans for the development of the former Chapelcross nuclear power site as part of the Borderlands Growth Deal project, to make best use of the natural assets of the site and linking these with nature in the wider countryside.
• providing advice to Marine Scotland and SSE on scoping and pre application engagement for Berwick Bank offshore wind development proposal (Scotland’s largest offshore wind scheme to date).

We have continued to focus on Development Management advice cases with potentially the most significant impacts on nature; those that give rise to issues of national interest. Following the establishment of our service statement thresholds for consultations in 2015/16, there has been a significant reduction in the number of planning applications we are consulted on, though the numbers appear to be levelling off (Appendix Table 2.). The 534 planning application consultations received in 2020/21 is similar to the number received in 2019/20 (516).

The success of our pre-application engagement and advice to improve development outcomes is again reflected in the continued low number of application consultations resulting in an outright objection (Appendix Table 2). We objected to 8 planning applications in 2020/21 (1.5 % of consultations received). These were four wind farms (three in relation to impacts on Wild Land Areas and one regarding impacts on an NSA) and four other types of development; housing (NSA impacts), fish farm (NSA impacts), watchtower (SAC impacts) and clay pigeon shooting (SPA impacts). In addition, we objected to three Section 36 wind farm applications (in relation to impacts on an SPA, Wild Land Areas and peatland).

Consenting

Examples of where we have worked closely with developers in 2020/21 to successfully deliver improved development outcomes include:

• discussion with the developers of Strathrory wind farm that led to the removal of our objection on landscape grounds;
• providing advice on Pundeavon hydro track development to minimise sensitive landscape impacts;
• working with the salmon farming company Loch Duart on the production of an Environmental Management Plan to prevent impacts to freshwater pearl mussels within the Abhainn Clais and Alt Mhuilinn SAC;
• advising Scottish & Southern Electricity Networks during the construction of the Lairg to Loch Buidhe overhead powerline to ensure no disturbance to SPA breeding bird interest;
• providing advice and support for Knoydart community in relation to a replacement pipeline and new access track for the community hydro scheme to avoid impacts on sensitive species and landscape.

Delivery of development

We continued to lead the delivery of the following national infrastructure projects that provided further opportunities for active travel, improving health and helping communities to grow economic activity and employment:

• Green Infrastructure Strategic Intervention: The delivery of the GISI projects was significantly delayed during 2020/21 due to Covid-19. All active Phase 1 projects were paused, and Phase 2 projects delayed in starting. All remaining Phase 1 projects are now back up and running and Phase 2 projects will be starting delivery in 2021/22. We still expect to be able to deliver the GISI programme fully by the end of 2023. Fernbrae Meadows was one of the first Phase 1 projects to finish, and has already become a valued resource for the local community, particularly during lockdown when levels of use increased dramatically, underlining the importance of accessible, high quality greenspace.
• National Walking and Cycling Network: We spent £171K on NWCN related projects in 2021, with capital improvements again focussed on Scotland’s Great Trails; and a total joint investment in strategic route development over the lifetime of the project of over £30 million. As well as delivering projects, we have continued to input to policy development, leading several NWCN Steering Group discussions on how a strategic routes project can be taken further as part of NPF4.

Capacity-building

Our programme of capacity-building is integral to our commitment to upstream engagement in the Planning System. It includes training and guidance to support planners and developers, helping them to understand and take account of nature in designing proposals and decision-making.

Sharing good practice, skills and knowledge

We developed and shared good practice with a wide range of different stakeholders to help generate good development proposals. This included:

• continuing our series of ‘Planning for Great Places’ webinars to assist practitioners with development and planning issues, including spatial planning for green networks and delivering green infrastructure;
• improving the reading accessibility of guidance documents on our website in line with The Public Bodies Accessibility Regulations;
• a feasibility study to explore the potential to retrofit blue-green infrastructure around NatureScot/Key Agency shared office spaces;
• delivering a presentation at the Scottish EIA Conference on the role of EIA in enabling Nature-based Solutions;
• a joint Scottish Water/Dundee City Council/NatureScot landscape design commission to support the delivery of blue-green infrastructure in St Mary’s Park Dundee;
• delivering a seminar for DPEA and planning inspectors on our input to the planning system, including issues of natural interest and our balancing duties;
• advice to the UK Space Agency on environmental objectives under the Space Industry Act to inform the work of the regulator;
• developing guidance  to be delivered prior to ScotWind leases being announced;
• delivering a joint presentation with Marine Scotland at a ScotMer symposium  (MS-led Scottish marine energy research programme) on lessons learned from offshore wind development particularly post consent monitoring;
• developing guidance to assist regulators and developers in addressing risks of diving bird entrapment in top nets on fishfarms, and liaising with stakeholders to refine and monitor the results.

We continued to update and expand our range of standing advice and guidance to support high-quality development, including:

• standing advice for any developments potentially affecting beavers, including planning requirements, survey methods, mitigation and licensing;
• staff guidance on dealing with applications to vary section 36 wind farm proposals;
• Piloting landscape sensitivity studies in Moray and Highland Council areas to inform new guidance;
• developing guidance to help design forest buffers to protect rivers and wetlands and maximise their ecological value.

Evidence and data-sharing

Our programme of research and evidence gathering increased knowledge and understanding of development issues, helped to solve problems and improved the quality of development proposals; along with the sharing of our data and making information more accessible to stakeholders. Examples in 2020/21 include:

• a successful bid to CREW to fund research on sediment dynamics on run-of-river hydro schemes;
• creating a GIS layer of notable species for the River Tweed SAC in partnership with the Wildlife Information Centre to help with proposals affecting the River Tweed;
• ongoing engagement and sharing of our protected areas datasets with Network Rail to aid their electrification programme;
• continuing to help maintain the online Air Pollution Information System (APIS), an essential tool for developers and planners in assessing air pollution impacts on protected areas, including the development of a mapping interface for users;
• progressing our GovTech Challenge project to develop an automated online platform for developers and land managers to gain easy access to information and advice regarding protected areas; successful consultants have progressed to Phase Phase 2 and prototype development;
• working with other SNCBs to help develop the Offshore Wind Environmental Evidence Register (OWEER) - a UK initiative building on ScotMer;
• input to Project Steering Groups for marine energy research and evidence projects including ScotMer, ORJIP (Offshore Renewables Joint Industry Programme) and OWSMRF (Offshore Wind Strategic Monitoring and Research Forum);
• Supporting SEPA and Marine Scotland in work to assist the aquaculture sector during Covid to streamline the consenting process and improve accessibility of online map layers for sensitive seabed features.

Service

We aimed to provide an efficient service that kept our advice on plans and applications on track to meet timescales and key deadlines.

Decision-making timescales

We continued to perform well in 2020/21 in terms of response times, with 91% of responses to SEA provided by the required date, and 94% of responses to planning consultations within agreed service timescales (Appendix Table 3).

Joint-working arrangements

We have collaborated with the Key Agencies Group (KAG) and others on initiatives to support the ongoing reforms to the Scottish Planning System, and continue to work jointly with the other key agencies to provide integrated services wherever possible. For example:

• collaborating with Heads of Planning Services to help ensure effective engagement and function of Environmental Clerks of Works in the planning system;
• our ongoing membership of the Scottish Government/Local Energy Scotland CARES panel providing early planning advice on funding applications;
• working with the JNCC, the other country agencies, SEPA and Environment Agency on the UK AERIUS project to develop an integrated air pollution modelling tool to support the risk assessment of air pollution effects on ecosystems, statutory reporting requirements and decision making on individual plans and projects;
• input to the Salmon Interactions Working Group to produce recommendations to guide improved regulation of aquaculture and wild salmonid interactions;
• working with Marine Scotland to develop improved regulation for the use of Acoustic Deterrent Devices in aquaculture.

Engagement with service users

Our independent customer satisfaction surveys gather evidence to support our commitment to continuous improvement. The 2020 Customer Survey provided positive feedback on our performance. The researchers’ key conclusions were:

• Overall satisfaction with the service we provide is high.
• We are seen to make a positive contribution to the planning process.
• Most respondents found it easy to contact staff.
• Views about our guidance and advice were positive.

The main areas where respondents would like to see improvements are in consistency of advice within NatureScot and across other agencies, clarity and conciseness of guidance and higher levels of collaboration with other agencies.

Our complaints procedure provides a further opportunity for customers to contact us over any issues. We received three planning-related complaints in 20201/21. Two from members of the public questioning our advice on a development proposal, and one from a member of Community Council regarding the withdrawal of GISI funding from a project. All three cases were resolved satisfactorily without the need for any escalation.

We circulated our twice-yearly e-newsletter to developers, planners and other stakeholders, keeping them informed of the work we are doing to address development issues and the publication of any new or updated guidance, as well as inviting feedback.

Other examples of engagement with service users included the capacity-building outlined above, as well as working closely with the renewables sector through our engagement with Scottish Renewables and through liaison meetings with individual developers, as well as attendance at key renewables sector events.

Changes to meet this year's improvement priorities

To meet the improvement priorities we had set for 2020/21, we:

• rebranded the organisation as NatureScot, to help raise our profile and demonstrate impact and value as leaders in biodiversity. As NatureScot we will be more recognisable to the general public as the organisation at the heart of how we deliver the transformational change needed to ensure a nature rich future for Scotland;
• responded to the Covid restrictions by transitioning quickly to home working, virtual meetings and online support; and adopting a 90 day planning horizon for prioritisation of tasks, which allowed us to adapt to changing circumstances and the variation in staff time available due to Covid;
• continued to seek to position nature at the heart of the planning system through further input to the development of NPF4, promotion of nature-based solutions, progressing Positive Effects for Biodiversity, and in supporting Scottish Government’s response to the climate change and biodiversity emergencies;
• further embedded the commitments and approach outlined in our service statement Planning for Great Places; taking a place-based approach and keeping the focus of our planning advice on issues of national interest, while maintaining support on issues of lower risk through new standing advice and capacity building with key stakeholders;
• continued to explore the use of digital technology to improve the way we work and to better share information with others;
• engaged further with key industries and business groups to help them deliver maximum benefits for nature and develop the skills required to help secure Scotland’s green recovery from Covid.

Service improvements for 2021/22

Our Business Plan 2021/22 is the fourth and final annual business plan in support of our Corporate Plan for 2018-2022 Connecting People and Nature. It sets out ten priorities for our work across the organisation in 2021/22:

• investing in action to reverse biodiversity loss and jointly lead the Scottish Biodiversity Programme;
• helping to transform use of land and sea so that it contributes even more to the future wellbeing economy;
• supporting a step-change in use of Nature-based Solutions to climate change and other problems;
• focusing effort on mainstreaming natural capital approaches/accounting in decision-making;
• helping to grow and diversify environmental green finance;
• investing in skills for a nature-rich future, especially in youth employment;
• facilitating the role of nature in transforming places where people live;
• supporting and encouraging access to and enjoyment of nature;
• accelerating peatland restoration through our Peatland Action Programme and collaboration with others;
• transforming as an organisation to meet the demands of the future, including accelerating its transition to a net zero emissions organisation.

All these priorities will shape our planning work to some extent, but of particular note we will:

• help to secure strengthened policy and spatial direction in NPF4 that puts nature at the heart of a planning system that embraces nature-based solutions, makes Scotland more resilient to climate change and accelerates the transition to net zero;
• invest in nature-based skills through a training and employment programme, and continue to work with businesses to develop the skills they need to help deliver a planning system that maximises the benefits for nature;
• support Scottish Government in mainstreaming natural capital accounting in decision making, developing new approaches to grow private investment in natural capital and connecting green finance with the emerging approach of Positive Effects for Biodiversity;
• continue to deliver Green Infrastructure investment, advice and good practice to improve urban environments, including spatial and locational planning, and building community skills and capacities to help to transform the places where people live;
• look to further streamline our involvement in development management casework, and free up more time for upstream engagement in the planning system and a greater influence on strategic and development planning stages.

During the course of 2021/22 we will be preparing a new Corporate Plan for 2022-2026. This will further establish the direction and challenge we are setting ourselves in helping to address the climate change and biodiversity emergencies, and the changes we need to make to the way we work in order to meet that challenge.

Appendix: Consulting Statistics

Table 1

Table 2

Table 3 

1 Includes consultations on topics such as calls for sites, topic papers, research, HRA, SEA and draft supplementary guidance.

2 Includes consultations on documents such as draft Proposed Plans, HRA and SEA draft supplementary guidance.

3 Median used to calculate the average.

4 Required dates include those where a new extended deadline has been agreed with the planning authority and where they have given us an initial deadline which is greater than the minimum 14 days.

Introduction

This is a report to the Scottish Government on our performance within the Planning System during the period 1 April 2019 to 31 March 2020. It reports against a series of performance markers covering different elements of our engagement in the Planning System, and identifies priorities for improvement during the next reporting period from1 April 2020 to 31 March 2021. It follows a template agreed with the other Key Agencies and the Scottish Government.

Description of our service

Our planning service includes advice and associated capacity-building and guidance. It supports implementation of the Third National Planning Framework, and accords with Scottish Planning Policy and the Scottish Regulators’ Strategic Code of Practice. It helps deliver the Scottish Government’s commitment to tackling the twin challenges of climate change and biodiversity loss, and the transition to a net zero carbon economy that is fair for all. It now has a key part to play in helping Scotland’s economic recovery from the Covid pandemic.

Our services aim to help make Scotland the best place to live, work, visit and do business. To support this aim, and achieve the right development in the right place, we have promoted plan-led approaches and engaged early with development interests to provide certainty for investment as soon as possible. In summary, we:

• build greater capacity amongst planning authorities and developers to achieve sustainable use of our natural assets - our guidance and training helps maximise the opportunities and competitive advantage from our natural resources;
• influence national strategic development policies and plans and associated Strategic Environmental Assessment (SEA);
• input to regional and local spatial plans - we are an active partner in Development and Marine Planning, master plans and action programmes;
• provide early, pre-application advice on development proposals, including mitigation measures;
• advise decision-makers on potential impacts of proposals on the natural heritage, targeting matters of potential national interest; and
• inform post consent monitoring at a strategic and project level to advance understanding of the impact of development on the natural heritage.

Our planning service has delivered multiple benefits that contributed to all four of the outcomes in our corporate plan Connecting People and Nature, around which our work is based:

1. More people across Scotland are enjoying and benefiting from nature.
2. The health and resilience of Scotland’s nature is improved.
3. There is more investment in Scotland’s natural capital and its management to improve prosperity and wellbeing.
4. We have transformed how we work.

The service helped to deliver the priorities for 2019/20 set out in our business plan for the period It’s in our Nature: Year Two; including:

• place making, targeted investment in green infrastructure and strategic path networks, and helping more people to connect with and benefit from nature;
• preparing for the challenges arising from new international targets for biodiversity in 2020 and ensure that we are maintaining, protecting and enhancing Scotland’s nature;
• demonstrating how people, the climate and the economy can benefit from investments in nature, to pursue opportunities for investment and to maximise the benefits and impacts that this brings;
• continuing to support Scottish Government’s commitment to plan-led development and the transition to a low-carbon economy through the development of renewable energy resources on land and at sea; and
• ensuring that our workforce is fit for the future, through a new Organisational Development Framework; focussing on workforce wellbeing and skills development, organisation design, innovation through technology and working in partnership.

More specific key deliverables identified for our planning service where:

• Influence city & regional growth strategies/deals to better reflect the role of nature and prepare the foundations for an enhanced commitment to nature.in the new National Planning Framework as part of the transition to a low-carbon economy.
• Help key industry interests - particularly housing, energy and transport – and enterprise bodies to use proportionate environmental assessment.
• Be an active, valued and inclusive partner in development planning.
• Provide targeted and streamlined advice on proposals to enable good development.
• Progress investment on green infrastructure improvements through our leadership and support of national projects, such as the Green Infrastructure Strategic Intervention (GISI).
• Fund the National Walking and Cycle Network (NWCN) and the Central Scotland Green Network (CSGN).

Our service has sought to enhance the quality of people’s lives by tackling disadvantage and promoting equality and fairness; provide social and economic competitive advantage through a Scottish brand framed by natural capital; and minimise adverse impacts on nature. We have adopted the Place Principle to help overcome organisational and sectoral boundaries, and encourage better collaboration and community involvement.

Organisational structure

The strategic direction of our engagement in the Planning System is provided by our Board and Senior Leadership Team. Our Planning for Development service statement Planning for Great Places outlines our approach. It strengthens the connection between people, development and nature, and focuses our efforts on: earlier and more upstream engagement in the Planning System; stronger working with business interests; and providing clearer advice that is alert to other interests.

The service was delivered by Activity and Area teams. Our Supporting Good Development Activity coordinates our work within the Planning System.  It leads onshore development advice, our input to development planning, working with Industry and strategic planning. To support this, our People & Places Activity provides advice on placemaking and green infrastructure and engagement with community planning; and our Sustainable Coasts and Seas Activity leads marine planning and development advice. Local delivery of the service across the country is through seven Area Teams (Northern Isles & North Highland, South Highland, Argyll & Outer Hebrides, Strathclyde & Ayrshire, Tayside & Grampian, Forth and Southern Scotland).

Resources

The service is funded through our Scottish Government grant-in-aid. Given the multiple benefits it achieves, we continued to invest a significant proportion of the funding in planning and placemaking work. In 2019/20 this approximated to £4 million (7% of our £56.2 million grant-in-aid) and was made up of staff costs of £3.5 million (70 full-time equivalents) and project costs of £0.5 million.

Performance markers

Placemaking

Strategic planning

We contributed to strategic planning through our advice on a range of strategic policies and plans, associated SEA and the development of plans for projects that are part of the Third National Planning Framework. Our contribution in 2019/20 included:

• supporting the implementation of the new Planning Act by inputting to the work programme for Transforming Planning in Practice as a member of Development Management Working Group and contributing to Key Agency input to other working groups;
• preparing our response to the Scottish Government’s call for ideas for the fourth National Planning Framework (NPF4) - Our Board considered two papers to frame our response;
• responding to Scottish Government consultations on Planning Fees and Performance, the District Heating Regulation - Heat Networks Bill, the National Transport Strategy and Housing to 2040;
• advising on 252 SEA consultations, from pre-screening to Environmental Reports (See Appendix, Table 1 for details), covering a wide range of policies and plans - eg. Sustainability Appraisal of Permitted Development Rights, National Transport Strategy, Scottish Transport Projects Review (STPR), Road Safety Framework, National Tourism Strategy and Export Plan;
• a workshop with Transport Scotland on the draft National Transport Strategy consultation document, advice to Transport Scotland and its consultations on the development of STPR, as well as participation in a series of STPR2 workshops, identifying interventions from a national to a local scale to support Regional Transport Strategy updates, and input to the review of the Scottish Transport Appraisal Guidance (STAG);
• inputting to SPEN’s Sustainability Working Group, and responding to SSEN’s Draft Business Plan;
• supporting the SCDI Clean Growth Leadership Group, including providing a speaker at the high-profile launch event; partnering in the SCDI Forum in 2019, with a workshop presentation on the economic benefits from nature.

Case Study: Strategic planning for wind farm repowering in South Lanarkshire

We are working with the South Lanarkshire Council, Scottish Government Energy Consents Unit and a group of seven developers to test a new approach that will facilitate the repowering of wind farms; with the aim of speeding up the planning process, reducing costs and delivering greater benefits for nature. The project began in September 2019 and is starting to deliver results. Work has been completed on bird monitoring and landscape and visual impacts, and a development framework for the cluster of wind farms is in preparation. By the end of 2020 we aim to have a model developed that can be adapted and applied to clusters of wind farms elsewhere in Scotland.

Development Plan engagement

We continued to be an active partner in Development Planning in 2019/20, supporting our commitment to a plan-led approach to development. Through engagement in the plan-making process, we planned for further investment in natural capital, helped to balance competing interests and guide development to the right places. Our contribution included advising on development frameworks, briefs and master plans, supplementary guidance, action programmes, SEA and Habitats Regulations Appraisal (HRA).

We responded positively to opportunities to engage early in the pre-MIR plan preparation process, for example:

• multi-partner discussions for the Inner Moray Firth LDP pre-call for sites stage;
• working with The Highland Council to explore a more effective way to link the very early stages of Local Development Plan (LDP) preparation and its environmental assessment, developing an approach that uses SEA site assessment questions at the Call for Sites stage.

Appendix, Table 1 shows the number of development planning consultations received in 2019/20. We received a total of 96 statutory and non-statutory plan consultations. This was an expected small increase on the previous couple of years, as we moved further into plan cycles.

Examples that demonstrate the added value we have brought to Development Planning in 2019/20 include:

• working with planning authorities, Sustrans and other key stakeholders to develop the Dundee to St Andrews strategic access link;
• maintaining a national overview and work to influence key stakeholders in planning for City Deals (Glasgow, Edinburgh, Inverness, Stirling, Dundee/Perth and Aberdeen) and the Borderlands regional growth deal;
• advising on the West Edinburgh MIR and City Mobility Plan to help ensure that transport and spatial planning benefit from nature-based solutions that are responsive to place;
• publishing guidance on spatial planning for coastal change;
• working with public and private sector stakeholders on the Fort William 2040 Vision and Masterplan, and the progression of associated key investment opportunities.

Case Study: East Lothian ClimatEvolution Project 

We have been working together with East Lothian Council, SEPA, Scottish Water, Scottish Government and developers on the ClimatEvolution Project; a visionary approach to the delivery of blue and green infrastructure for an area of East Lothian, including the new Blindwells development, the former Cockenzie Power Station site and existing settlements. The integrated approach to planning and design, and use of nature-based solutions, is a blueprint for the positive part development can play in adapting to and mitigating the impacts of climate change, and providing community benefits through, for example, addressing strategic drainage challenges, connecting people through active travel, delivering innovative geo-thermal energy generation, and the provision of new sport and leisure opportunities.

Development Management

We provided advice on 473 planning application consultations (excluding ‘no comment’ responses). We advised developers, local authorities and agencies on the impact of development proposals on natural heritage interests, including advice on mitigation. This has enabled the delivery of development priorities across a range of industrial sectors including housing, renewable energy, manufacturing, transport, marine development, fish farming and telecommunications.

We provided advice and support to the Planning and Environmental Appeals Division (DPEA) through attendance at the public local inquiry for North Lowther Energy Initiative (providing evidence on landscape and visual impacts and our process of considering national interest), and more generally as a member of the DPEA Stakeholders Group.

Pre-application engagement

Our early pre-application engagement aimed to support a more efficient Planning System. It allowed issues to be identified early in the development and planning process. It afforded time to try and resolve issues ahead of applications being submitted. We responded to 186 pre-application consultations, often in collaboration with other key agencies. Examples of pre-application engagement in 2019/20 include:

• input to masterplanning for the redevelopment of Longannet embedding nature based solutions into the design and layout of the new use of an industrial site;
• resolving an SPA issue with the Lairg to Loch Buidhe Overhead Line through analysis of existing data and expert peer review, avoiding need for additional survey work and further delay to the project;
• advice and support for Orkney Islands Council’s impact assessment of its own suite of wind farm proposals;
• working with Energie-Kontor to improve the design of their Lairg II wind farm to avoid impacts on peatland habitat and develop a Habitat Management Plan to benefit upland birds;
• engagement with SSEN over Western Isles transmission and avoidance of impacts on Marine Protected Areas;
• providing advice on the HRA for the £250 million Grangemouth Flood Protection Scheme, including proposals for the development of potential compensation areas, and ground investigation works to be carried out in 2020;
• developing spatial guidance and policy to help identify and avoid sensitive seabed habitats in selecting suitable locations for development;
• Inputting to the development of new regulatory approach for wild fish interactions to reduce delays in the planning process.

We have continued to focus on Development Management advice cases with potentially the most significant impacts on the natural heritage; those that give rise to issues of national interest. Following the establishment of our service statement thresholds for consultations in 2015/16, there was been a significant reduction in the number of planning applications we are consulted on (Appendix, Table 2). This decrease continued in 2019/20 with 516 planning application consultations, less than half the number of consultations we received in 2015/16.

The success of our pre-application engagement and advice to improve development outcomes is again reflected in the continued low number of application consultations resulting in an outright objection (Appendix, Table 2). We have objected outright to less than 1% of the planning applications we have been consulted on in each of the last six years, with only three outright objections to planning applications in 2019/20; a wind turbine (impacts on a Wild Land Area) and two forestry buildings (impacts on a Special Protection Area). In addition, we objected to three Section 36 wind farm applications (in relation to landscape and visual impacts on a National Scenic Area and Wild Land Areas).

Case Study: Sectoral Plan for Offshore Wind

Throughout 2019/20 we have worked with Marine Scotland in the preparation of a Sectoral Plan for offshore wind energy in Scotland, which has a key role to play in Scotland’s transition to a net zero carbon economy. This plan-led approach directs offshore wind development to those areas of our seas best able to accommodate large scale turbine arrays with least impact upon nature and other interests and uses. We have helped to identify areas offering opportunities for development, alongside those where constraints may exist. A focus of this has been bespoke guidance for each draft plan option area illustrating where and how best to minimise visual impacts from the coast, to inform lease applications at an early stage.

Consenting

Examples of where we have worked closely with developers in 2019/20 to successfully deliver improved development outcomes include:

• collaborating with Mowi to develop and agree an adaptive management framework to manage the risks of sea lice on FWPM, allowing the proposed expansion of Macleans Nose fish farm;
• landscape advice on major wind farm cases including Glenshero, Kirkan, Rothes III, Clash Gour and Sanquar II;
• providing peat management advice (jointly with SEPA) to Liberty Group for the proposed aluminium factory site at the Lochaber Smelter, identifying least environmentally damaging solutions;
• responding to the planning application for a major substation for Orkney connection project;
• assisting Scottish Power over plans for the restoration of the Valleyfield ash lagoons at Longannet adjacent to the Firth of forth SPA;
• placemaking and green infrastructure advice for the major Durieshills Hill housing proposal in Stirling;
• advising Argyll and Bute Council on the restoration requirements at Merk Hydroelectric Scheme.

Case Study: Meadowbank Development Green Roof Options Appraisal

We have been working with City of Edinburgh Council and others to explore the viability of integrating green roofs into an existing development proposal. The Meadowbank Development Green Roof Options appraisal was the result of a partnership between the Scottish Government, Architecture and Design Scotland, the Scottish Federation of Housing Associations and City of Edinburgh Council. The partners commissioned a multi-disciplinary design team (comprising Architects, Landscape Architects, Structural Engineers, Quantity Surveyors and a leading UK Green Roof expert) to carry out a viability study based on an existing housing and mixed-use development proposal at Meadowbank, close to the centre of Edinburgh. The team took a collaborative place-based approach to identifying solutions appropriate to the specific challenges and opportunities at the site.

Delivery of development

We continued to lead the delivery of the following national infrastructure projects that provided further opportunities for active travel, improving health and helping communities to grow economic activity and employment:

• Green Infrastructure Strategic Intervention: We allocated a further £7.5m of the European Regional Development Fund to 8 capital green infrastructure projects in deprived areas of urban Scotland. Alongside of our existing 7 capital and 11 community engagement projects, this brings the total investment, with match funding, through the fund to almost £40m. The first of our Phase 1 projects are set to complete during 2020. Their impact will be demonstrated through case studies showing the multiple benefits they bring to local communities.
• National Walking and Cycling Network: We continued to lead on the National Walking and Cycling Network with main partners Sustrans and Scottish Canals, spending a further £270K on improvements to 7 of Scotland’s Great Trails. This brings the total joint investment in strategic route development over the first five years of the project to £30 million.

Capacity-building  

Our programme of capacity-building is integral to our commitment to upstream engagement in the Planning System. It includes training and guidance to support planners and developers, helping them to understand and take account of the natural heritage in designing proposals and decision-making.

Sharing good practice, skills and knowledge

We developed and shared good practice with a wide range of different stakeholders to help generate good development proposals. This included:

• continuing our series of ‘Planning for Great Places’ webinars to assist practitioners with development and planning issues (wind turbine aviation lighting, planning for coastal change, solar energy development, Habitats Regulations Appraisal, and development on peatland);
• preparing new content on our website, including pages on good practice construction and placemaking and green infrastructure, and improving access to all of our planning-related standing advice and guidance documents;
• providing SEA training for Crown Estate Scotland and for Key Agency Group partners, jointly with HES and SEPA;
• delivering a workshop with HES and SEPA for Scottish Government Environmental Assessments team;
• running an EIA training course for key agencies, including SEPA, HES, Scottish Forestry, Marine Scotland and SG Energy Consents Unit;
• providing lectures, dissertation research topics and workshops to planning and engineering students at Aberdeen, Dundee, Heriot Watt and Strathclyde Universities, including the trialling of on-line scenario-based learning;
• an ongoing programme of capacity-building within local authorities, helping planning officers to consider natural heritage issues early on in their planning and decision-making, including a joint workshop with Edinburgh, Lothians and Borders local authorities;
• delivering a joint presentation with SEPA to Senior Managers and staff at Robertson Construction and Balfour Beatty;
• giving a presentation to the Solar Trade Association on benefitting nature;
• presenting and exhibiting at conferences and events eg. All Energy, Scottish Renewables hydro conference, Scottish Renewables Onshore Wind Conference, Wildlife and Renewable Energy Network, Scotland’s Towns Partnership, Association of Environmental and Ecological Clerks of Works (AEECoW) annual conference, Scottish Power’s World Environment Day event and Global Goals event;
• helping to organise the Fifth Conference on Wind Energy and Wildlife Impacts in collaboration with wind energy companies, environmental consultancies, scientific institutions, RSPB and JNCC;
• advising CARES panel on natural heritage impacts from community energy developments;
• sponsoring a conference on Future Planning – Designing Places in a Climate Emergency, organised by the Ecosystems Knowledge Network;
• organising a multi-agency lessons learned site visit to the Aberdeen Western Peripheral Route, jointly with Transport Scotland;
• hosting a two day workshop with consultancy CBEC on river processes and sustainable approaches to river restoration;
• establishing strategic engagement group with Network Rail to deliver biodiversity benefits within their estate;
• running a workshop on assessment of offshore wind bird impacts to engage stakeholders in the development of guidance for new applications.

Case Study: Sharing Good Practice: Helping Scotland’s Pollinators

We hosted a Sharing Good Practice event Creating a buzz in development – how can developers help Scotland’s pollinators? It was attended by a wide range of stakeholders, including Planning Authorities, Public Bodies, Biodiversity and Community Partnerships, Academic Institutions, NGOs, architects and consultants, and power and construction companies. Delegates were informed of current infrastructure projects benefitting pollinators, with some of the cost saving examples that minimise maintenance regimes and examples of good soil management. Interactive workshops considered master-planning for pollinators and learning on the ground, and exhibition stands by guest organisations promoted pollinator work. The varied audience made for good networking and the sharing of ideas.

We have continued to update and expand our range of standing advice and guidance to support high-quality development, including:

• publication of  standing advice notes for protected species to guide developers and planners through planning requirements, survey methods, mitigation and licensing;
• a revised version of the Good Practice Guide to Hydropower Construction, a joint publication with SEPA and Scottish Renewables;
• a review of Developments on Peatland guidance jointly with SEPA
• input to the development of guidance by the UK Space Agency on the assessment of environmental effects of spaceport activities;
• a revised version of our General scoping and pre-application advice for onshore wind farms, including new advice on assessing the impacts of turbine lighting;
• developing further standing advice for Marine Scotland in relation to aquaculture marine licensing, and initiation of standing advice for Local Authorities.

Evidence and data-sharing  

Our programme of research and evidence gathering increased knowledge and understanding of development issues, helped to solve problems and improved the quality of development proposals. Examples in 2019/20 include:

• commissioning work to develop a decision support framework for the bird impacts of offshore windfarms, to help make our future advice more efficient and transparent;
• engaging in discussions with the Offshore Wind Industry Council and a range of partners on Barriers to Growth as part of the Offshore Wind Sector Deal, to identify shared priorities to overcome current consenting challenges;
• discussing innovation projects with the aquaculture industry to support the sector in finding new approaches to overcome environmental constraints;
• supporting SEPA’s implementation of new modelling and monitoring techniques for aquaculture developments, improving accuracy and speed of decision making;
• working with Scottish Enterprise and the Infrastructure Commission for Scotland to deliver a Scottish Futures Group workshop which was one of the key evidence-gathering sessions for the Commission’s initial report.

Case Study:  A green heart to future infrastructure investment plans 

We provided advice to the Infrastructure Commission in response to their Call for Evidence. This included case studies that illustrate the contribution of natural capital to Scotland’s infrastructure. Our advice aimed to encourage more investment in natural capital; put investment in natural capital on a level footing with other infrastructure types; and develop an approach to infrastructure planning that delivers benefits for nature and reduces conflict between development and protecting natural capital. We want investment in natural capital infrastructure (whether green or blue) to become routine in the planning, management and maintenance of our built environment.

We also made additional efforts to share our data and make information more accessible to stakeholders by:

• continuing to help maintain the online Air Pollution Information System (APIS), an essential tool for developers and planners in assessing air emission impacts on protected areas from development proposals such as combustion plants and intensive livestock units;
• progressing our GovTech Challenge project to develop an automated online platform for developers and land managers to gain easy access to information and advice regarding protected areas; through to the start of Phase 2 and prototype development;
• ongoing membership of the Scottish Government/Local Energy Scotland CARES panel providing early planning advice on funding applications.

Service 

We aimed to provide an efficient service that kept our advice on plans and applications on track to meet timescales and key deadlines.

Decision-making timescales

We continued to perform well in 2019/20 in terms of response times, with 98% of responses to SEA provided by the required date, and 95% of responses to planning consultations within agreed service timescales (Appendix, Table 3).

Joint-working arrangements

We have collaborated with the Key Agencies Group (KAG) and others on initiatives to support the ongoing reforms to the Scottish Planning System, and continue to work jointly with the other key agencies to provide integrated services wherever possible. This has included:

• publishing People, Place and Landscape setting out a joint vision and approach with HES for managing change in Scotland’s landscapes, together with an action plan for its implementation;
• considering revisions to working arrangements with CNPA and LLTNPA in relation to landscape advice and casework affecting European Sites;
• supporting Cromarty Port Authority in their review of activities and compliance with Natura requirements;
• as part of the Social Housing and GI Steering Group, meeting with three groups of potential partners to discuss opportunities for joint working and to add value to housing developments;
• establishing a common KAG position on Masterplan Consent Area provisions in Planning Bill, balancing safeguards with enabling;
• working with Cairngorm Mountain and Nevis Range on monitoring and future plans;
• establishing a new working group with Civil Engineering Contractors Association (CECA), AEECoW and SEPA;
• as part of KAG, bringing partners together to develop a shared vision for Forthside;
• working with the SCDI Initiative on Clean Growth;
• running a joint workshop with Scottish Enterprise on how our two organisations can best work together.

Engagement with service users  

We commissioned Why Research to undertake our annual customer satisfaction survey for 2019/20, to gather evidence to support our commitment to continuous improvement. For the first time, the survey was run jointly with another key agency (HES), to develop a consistent key agency approach and avoid customers receiving separate surveys. The survey provided positive feedback on the performance of both agencies:

• Overall satisfaction with the service we provide is high.
• We are seen to make a positive contribution to the planning process.
• Most respondents found it easy to contact staff.
• Views about our guidance and advice were positive.

The main areas where respondents would like to see improvements are in consistency of advice within SNH and across other agencies, clarity and conciseness of guidance and higher levels of collaboration with other agencies.

Our complaints procedure provides a further opportunity for customers to contact us over any issues. We received two planning-related complaints in 2019/20. Both were in relation to dissatisfaction with our advice on development proposals; on the part of the developer in one case and an individual objector in the other. The two cases were resolved.

Other examples of engagement with service users (in addition to the capacity-building outlined in section 3.2 above) included:

• working closely with the renewables sector through our engagement with Scottish Renewables and through liaison meetings with individual developers, as well as attendance at key sector events;
• issuing our Planning for Development e-newsletter, keeping developers, planners and other stakeholders informed of the work we are doing to address development issues and the publication of any new or updated guidance, as well as inviting feedback.

Changes to meet this year’s improvement priorities

To meet the improvement priorities we had set for 2019/20, we have:

• Continued to support the Scottish Government’s improvements to the Planning System by helping further with the implementation of the new Planning Act and preparing a response to the government’s initial call for ideas on NPF4.
• Further embedded the Place Principle and place-based approaches in the way we work, to help ensure the provision of services and caring for assets in a place are planned in collaboration with local communities to improve lives and support inclusive and sustainable economic growth; including our ongoing leadership of the ERDF Green Infrastructure Strategic Intervention, and developing a framework of spatial priorities and projects to deliver more focused action across Scotland.
• Focused our planning advice on issues of national interest, with support on issues of lower risk provided through standing advice/guidance and capacity building with key stakeholders; leading to a further reduction in the number of development management consultations we received and freeing up more staff time for upstream engagement in the Planning System.
• Made greater use of digital communication media and explored new technology for sharing knowledge and building capacity in local authorities, industry sectors and other key agencies; including improved access to standing advice and guidance on our website, establishing a programme of webinars, and further development of an automated on-line advice service as part of the GovTech Catalyst programme that pays suppliers to solve public sector problems using innovative digital technology.
• Targeted our engagement with business interests to those best placed to shape future investment in nature. For example. Inputting to Scottish Power Energy Network’s Sustainability Stakeholder Working Group, Scottish & SSEN’s Draft Business Plan, the review of STAG, and working with Network Rail on maximising the benefits to nature on their landholding.
• Created efficiencies in our work with Marine Scotland by clarifying roles and responsibilities, and secured improved outcomes in marine aquaculture casework by helping to implement a new approach to marine aquaculture, including strengthened regulation to protect wild salmonids and for managing the use of Acoustic Deterrent Devices.

Service improvements for 2020/21

We will continue to embed the Planning for Great Places 

commitments and approach in our service. This is reflected in our Business Plan for 2020/21 Putting Nature First: Year Three, which sets out the ambitious steps we will take to tackle the climate change and biodiversity emergencies, and move Scotland to a nature-rich future. Our services will aim to:

• Put nature at the heart of the Planning System by influencing the new National Planning Framework and be an active, valued and influential partner in development planning and regional/city/island growth deals.
• Provide targeted and influential advice on proposals to enable good quality development that secures positive benefits for nature.
• Engage with key business interests and industry sectors to help them maximise the competitive advantage of nature and invest in the nature-based solutions required in response to the climate emergency and biodiversity crisis.
• Make the case through evidence and best practice for nature-based solutions in our towns and cities.
• Provide effective input to strategic sectoral and marine spatial planning, and advice on major developments, to guide sustainable use of our coasts and seas.

Through our advice, we will help shift the focus of the Planning System from avoiding the worst negative impacts to delivering positive benefits for nature, thereby halting and reversing biodiversity loss. We will share our expertise of green and blue infrastructure to 

promote nature-based solutions and encourage greater natural capital investment through development strategies and plans.

We are also committed to exploring new ways of working that facilitate good regulation and earlier certainty for investment. We want to: support greater integration of various place-based land use planning initiatives to achieve Sustainable Land Use; champion Place-based approaches through national, regional and local spatial planning; and encourage more inclusive engagement in the Planning System.

We will continue to support the Planning System as best we can during the Covid restrictions, responding to consultations on development policies, plans and proposals, and supporting these through targeted advice, guidance and capacity building. We will be as proportionate, pragmatic and prompt as possible in the way we work.

We will be working with development and planning stakeholders to ensure that nature supports Scotland’s green recovery from the Covid pandemic, and make us more resilient socially, economically and environmentally.

Appendix:  Consultation Statistics

1 Includes consultations on topics such as calls for sites, topic papers, research, HRA, SEA and draft supplementary guidance.

2 Includes consultations on documents such as draft Proposed Plans, HRA and SEA draft supplementary guidance.

3 Median used to calculate the average.

4 Required dates include those where a new extended deadline has been agreed with the planning authority and where they have given us an initial deadline which is greater than the minimum 14 days.

3.2 Capacity-building

Our programme of capacity-building is integral to our commitment to upstream engagement in the Planning System. It includes training and guidance to support planners and developers, helping them to understand and take account of the natural heritage in designing proposals and decision-making.

d. Sharing good practice, skills and knowledge

We developed and shared good practice to help generate good development proposals. This included:

• an ongoing programme of capacity-building within local authorities. This has helped planning officers to consider natural heritage issues early on in their planning and decision-making;
• a programme of lectures and workshops in college and university planning and engineering courses, with the aim to influence future developers and planners. This work included supplying research topics to Strathclyde University’s ‘Engage’ programme for research in collaboration with industry. Examples of topics were landscape impacts from upland tracks, and green-infrastructure-related research;
• a Sharing Good Practice event covering Successful Environmental Management and Good Construction, in collaboration with the construction industry;
• introduction of a new series of ‘Planning for Great Places’ webinars to assist practitioners with development and planning issues. Topics delivered covered upland track construction and visualisation for wind energy projects;
• industry capacity-building training sessions, in collaboration with SEPA, for Robertson Construction, AMEY Highways, Scottish Power and Network Rail;
• presentations at industry conferences, including promoting biodiversity on solar farms at the All Energy event, and promoting good practice on hydro scheme development at the Scottish Renewables hydro conference;
• contributing to the drafting of the ICE report State of the Nation: Infrastructure and Investment 2018;
• sponsoring the annual Association of Environmental and Ecological Clerks of Works conference;
• running learning visits to wind farm sites for planning authority and Energy Consents Unit staff;
• providing SEA/EIA training for Scottish Government and Key Agencies, including a two-day EIA training Course for participants from Scottish Government, SEPA, Forestry Commission Scotland, and HES;
• delivering a joint workshop with HES at the EIA Scottish Practitioners Conference, as part of the launch of Version 5 of our Environmental Impact Assessment Handbook. The new version incorporates changes to EIA regulations and includes a new chapter on cultural heritage impact assessment;
• holding a joint workshop with Scottish Power Energy Networks to share experiences and plan how best to work together to help deliver on the UN sustainable development goals;
• launch of our Planning for Great Places service statement at an SCDI event to highlight to its members the importance of nature to Scotland’s economy and the benefits from investing in natural capital.
• presenting our aspirations for connecting people and nature, and our planning services to support this, to the Heads of Planning Conference in Shetland;
• a staff secondment to Scottish Government Energy Consents Unit to help build broader understanding of nature interests and develop closer working relationships;
• engagement of staff in a programme of aquaculture site visits and industry interchange to build mutual understanding.

We have continued to update and expand our range of guidance to support high-quality development, including:

• developing new guidance on planning for coastal change to help Planning Authorities take account of coastal change, consider the risks to infrastructure and identify nature-based solutions to reduce risks (see case study below);
• refreshing our guidance on Good Practice During wind Farm Construction, in collaboration with industry and public agency stakeholders;
• consulting on good practice guidance for hydro developments;
• producing a ‘dangle’ book visual guide for hydro construction site staff dealing with invasive non-native species;
• publication of Maximising the benefits of green infrastructure in social housing – the result of collaborative research with social housing providers. With a view to implementing the report’s recommendations, a joint steering group comprising the Scottish Federation of Housing Associations, Architecture & Design Scotland and Scottish Government Planning & Architecture Division has launched a call for expressions of interest in exploring opportunities to demonstrate how input from design professionals at an early stage of procurement can help support better outcomes for place;
• preparing guidance on the provision of advice to Planning Authorities on the use of Acoustic Deterrent Devices (ADDs) in and around the Inner Hebrides and the Minches SAC.

e. Evidence and data-sharing

Our programme of research and evidence gathering increased knowledge and understanding of development issues, helped to solve problems and improved the quality of development proposals. Examples in 2018/19 include:

• continuing our support of Marine Scotland’s Scottish Marine Energy Research (ScotMER) research programme to produce prioritised lists of research requirements and the successful delivery of agreed priority projects, reducing consenting risk across all EIA topic areas. This is re-enforced by our membership of the research panel for the European Offshore Wind Deployment Centre, which has also commissioned research of benefit to future offshore wind projects, and through our input to other national research initiatives focusing on offshore renewables such as the Offshore Renewables Joint Industry Programme, Offshore Wind Strategic Monitoring & Research Forum and BEIS Offshore Energy SEA programme;
• producing the revised national Landscape Character Assessment for Scotland - now available via the SNH website on an interactive map (see case study below);
• commissioning research to inform guidance development for the offshore renewables sector, including on the Selection of Buffer Zones for Impact Assessment to Inform Offshore Renewables Consenting, and the Application of

Noise Abatement Systems for Mitigating Piling Noise in Scottish Seas;

• hosting two study tours for Japanese colleagues to share our experience in offshore wind development;
• providing oral and written evidence to both the ECCLR and REC Committee inquiries on fish-farming, highlighting the challenges and potential solutions to environmental issues faced by the sector;
• updating Landscape Capacity Studies for wind energy development in East and South Ayrshire;
• establishing a National Technical Group to provide informed advice to Planning Authorities on potential interactions between fish-farms and the interests of Special Areas of Conservation, such as wild salmon and freshwater pearl mussel.

Case Study: Landscape Character Assessment for Scotland

Landscape Character Assessment (LCA) identifies and describes the diversity of landscape. It is the commonly accepted way of understanding landscapes, and underpins modern landscape planning. In 1999, Scotland was the first country to achieve nationwide coverage of LCA through an SNH-led programme of individual assessments. Following a comprehensive review, we have produced an updated, digital version which is available on our website. The review involved partnership working with FCS and HES, analysis by consultants, a users’ questionnaire, and consultation rounds with all local authorities and our own landscape advisers. The result is a much-improved source of the key landscape information for Scotland. We will also be providing links to related information and revised background chapters, which will be added to the web page in the future.

We also made additional efforts to share our data and make information more accessible to stakeholders by:

• continuing to maintain the online Air Pollution Information System (APIS), an essential tool for developers and planners in assessing air emission impacts on protected areas from development proposals such as combustion plants and intensive livestock units;
• making a successful application to the GovTech Challenge to develop an automated online platform for developers and land managers to gain easy access to information and advice regarding protected areas (see case study below).
• ongoing membership of the Scottish Government/Local Energy Scotland CARES panel providing early planning advice on funding applications;
• contributing to the Regional Advisory Groups set up to approve conditions and discuss post-consent monitoring requirements for offshore renewables, including for Meygen tidal array, Moray Firth and Forth and Tay wind farm clusters;
• working as part of the organising committee for the international Conference on Wildlife and Wind (to be held in Stirling in August 2019).

3.3 Service

We aimed to provide an efficient service that kept our advice on plans and applications on track to meet timescales and key deadlines.

f. Decision-making timescales

We continued to perform well in 2018/19 in terms of response times, with 96% of responses to SEA provided by the required date, and 94% of responses to planning consultations within agreed service timescales (Appendix, Table 3).

g. Joint-working arrangements

As a member of the Key Agencies Group we have collaborated on initiatives to support the ongoing reforms to the Scottish Planning System, and continue to work jointly with the other Key Agencies to provide integrated services wherever possible. This has included:

• a review of the Stage 1 Report on the Planning (Scotland) Bill, and consideration of Stage 2 amendments including a Joint Statement from the Key Agencies Group relating to amended provisions for Masterplan Consent Areas in Stage 2 of the Planning (Scotland) Bill;
• start of discussions on input to the preparation of National Planning Framework 4;
• updating the Key Agency Joint Statement on pre-application, which sets out the principles governing our commitment to effective and timely pre-application engagement with Planning Authorities and developers in relation to development of national and major significance;
• working with Local Development Plan teams through user research to identify a wider suite of relevant environmental information, improve the cascade of information from LDPs into other planning and environmental assessment processes, and developing and improving user guidance;
• collaborating with Scottish Government’s Digital task Force to develop digital platforms for LDP and other information;
• setting up a subgroup to consider how greater collaboration at an earlier stage of master planning can help deliver shared objectives and positive outcomes for placemaking;
• input to the Information Service’s Partners in Planning (PiP) initiative to develop skills and build capacity across the Planning System; and the launch of the PiP web portal for sharing information and best practice, including preparation of a short film on the role of Key Agencies in the Planning System and an active learning workshop;
• hosting a conference ‘Planning for Positive Outcomes – Working with the Key Agencies’ promoting collaboration and constructive dialogue between planners and Key Agencies;
• taking a collective approach to reporting on planning performance, including a peer review exercise and preparation of a Joint Statement on Key Agency performance in 2017/18.

h. Engagement with service users

We commissioned Why Research to undertake our fifth annual customer satisfaction survey to gather evidence to support our commitment to continuous improvement. The main findings from the 2019 Customer Survey (of our 2018 service) provided positive feedback on our performance:

• SNH is perceived to make a positive contribution to the planning process. - Overall satisfaction with the service received from SNH remains high.
• Most customers agree that SNH’s approach to advice is enabling and influential.
• Views are positive in relation to contacting SNH.
• Awareness of SNH guidance documents remains high and views on the guidance are positive.
• There has been an increase in the level of awareness of the SNH Service Statement.

The main areas where respondents would like to see improvements are in consistency of advice within SNH and across other agencies, as well as guidance which is clearer and more concise, and easier to find on the website. There were also requests for SNH to have a more robust involvement in local issues and in objecting to planning applications.

Our complaints procedure provides a further opportunity for customers to contact us over any issues. We received three planning-related complaints in 2018/19, all from individual objectors to planning applications regarding the absence of an SNH objection. One of the complaints was upheld and led to us altering our position to a holding objection in relation a Natura issue.

Other examples of engagement with service users (in addition to the capacity-building outlined in section 3.2 above) included:

• working closely with the renewables sector through our engagement with Scottish Renewables and through liaison meetings with individual developers as well as attendance at key sector events;
• liaising with the aquaculture sector, including regular meetings with the Scottish

Salmon Producers Organisation (SSPO), and our input to the Industry Leadership Group, Farmed Fish Health Framework groups, Interactions and Technical Working Groups;

• meeting regularly with a range of non-governmental organisations to discuss planning issues, both individually (e.g. RSPB), and collectively through Scottish Environment LINK;
• issuing our Planning for Development e-newsletter, keeping developers, planners and other stakeholders informed of the work we are doing to address development issues and the publication of any new or updated guidance, as well as inviting feedback;
• upgrading our Casework Management System to ensure that it is GDPR-compliant.

4. Changes to meet this year’s improvement priorities

As introduced in Section 2, we repositioned our planning and development services in 2018/19. This reflected the changing external operating environment and our resourcing challenges. It strengthened alignment of our efforts to the whole of the government’s work in order to maximise our support for inclusive and sustainable growth.

This repositioning led to the launch of our new Planning for Development Service Statement Planning for Great Places. The new statement highlights our focus on: sharing knowledge about Scotland’s nature; helping developers invest in nature; supporting plan and placemaking; and providing advice to enable good development. Delivery of our new Service Statement has required leadership and commitment for early and upstream engagement in the Planning System, strong working with business interests and clear advice that demonstrates that we are alert to other interests.

We continued to raise awareness of the Scottish Regulators’ Strategic Code of Practice and embed its implementation into all aspects of our regulatory role through the delivery of our Action Plan. To aid this, we have adopted a new approach to the application of our Balancing Duties. This is focused on use of enabling behaviours as well as discharging due processes, to take account of wider socio-economic interests at all stages of our engagement in the Planning System. We have engaged with partner agencies to further join-up our regulatory roles. For example, we worked with Marine Scotland regarding our advice on aquaculture, well boat licences, and European Protected Species; and with local authorities to identify priorities for our support of placemaking.

Our Workforce Planning has provided greater capacity in our staff to lead, engage and inspire, so that we can more effectively connect people and nature through the Planning System. In particular, we have widened our skills base in facilitation and placemaking.

5. Service improvements for 2019/20

We will continue to embed the Planning for Great Places commitments and approach in our services in 2019/20. This is reflected in our Business Plan 2019/20 It’s in our Nature: Year Two.

We aim to provide earlier, stronger and more positive interaction with stakeholders that is good for business, climate and nature and helps decision-makers balance competing demands to deliver sustainable, inclusive growth. We will strengthen our support for place-based approaches and continue to make the case for preventative spend on greenspace.

We will also ensure that our Planning Service supports the government response to the climate emergency and help to tackle the drivers of biodiversity loss. This will include input to the next National Planning Framework and the review of Scottish Planning Policy.

Given the changing demands and our reducing resources, we will improve our services in 2019/20 to:

• provide advice that enables good development in new, more efficient and targeted ways. For example, we will place greater store on standing advice in support of development that has low risk to natural heritage interests of national importance;
• use new technology and communication media to share knowledge and build capacity amongst local authorities and industry sectors. For example, we have developed a new series of webinars to share our knowledge in a dynamic and efficient way;
• target engagement with business interests, to work with those best placed to shape future investments in natural capital through their strategic plans and funding streams. For example, we will increase our work with Scottish Enterprise and the Scottish Land Commission on the derelict and Vacant Land Commission, and support SCDI on their climate change business leadership plan;
• prepare recommendations for post-EU support mechanisms to deliver green infrastructure, paths and landscape partnerships;
• develop a framework of spatial priorities and projects to deliver more focused action to support placemaking activity action across Scotland;
• seek efficiencies through further work on roles, responsibilities and interactions with Marine Scotland;
• help implement a new approach to aquaculture regulation, including strengthened regulation for wild salmonids and Acoustic Deterrent Device use that secures improved outcomes;
• Increase engagement with key partners (marine industries, enterprise bodies, regulators) to better understand their aspirations and improve understanding of marine natural heritage issues;
• change the way we deliver our onshore development management advice service by:
  • reducing demand for our advice and making its delivery more efficient;
  • using more targeted responses to consultations;
  • adopting new approaches such as greater reliance on standing advice and less detailed input;
  • ending input to casework where outcomes are less significant.
• reduce the need for our bespoke advice on some types of marine development through capacity-building, guidance production and the use of standing advice and model wording in collaboration with Marine Scotland;
• begin work on redeveloping our Casework Management System to provide us with more effective reports on our input to the Planning System and improve our service to customers.

We will also continue our journey of digital transformation improving engagement with the people of Scotland; and investing in technologies including Earth Observation and Remote Sensing.

We will increase the sharing of our knowledge, information and data, making sure we provide information at the right time to inform decisions about nature, and work to further enhance our evidence base.

We will identify alternative funding streams to achieve greater investment in nature and support delivery of Connecting People and Nature.

Collectively, we hope that these changes will transform the way engage in the Planning System: supporting an increasingly enabling and targeted approach; and by encouraging smarter, more flexible, dynamic and collaborative working, to help developers identify opportunities for investment that will sustain future prosperity.

Appendix:  Consultation Statistics