Scottish National Planning Framework 4 – Consultation Response
The Institute of Acoustics Scottish branch has responded to the Scottish Government’s draft National Planning Framework 4 (NPF4). When adopted, the framework will set out the Scottish Government’s planning system policies and priorities to 2045 and how their approach will help to achieve a net zero, sustainable Scotland. IOA took the opportunity to highlight areas where noise and acoustics should be considered. Comments on the extensive document included:
- Noting that the policies on design, quality and place mention noise throughout the draft, with "vibration" only referenced in relation to minerals, and recommending vibration is considered along with noise for all relevant development.
- On infrastructure policy and development for business and employment, the branch recommended noise is included for consistency with other policies,
- To achieve delivery of high quality sustainable homes, it is advised that potential noise impacts should be considered in local development plans, and the Agent of Change principle acknowledged.
- In considering heating and cooling policy to support the achievement of net zero and adaption to changing temperatures, IOA advise that both active and passive systems have potential noise impacts, and this should be accounted for in policy.
- On health and well-being, IOA would like to see emphasis on promotion of sound and soundscapes as a positive resource, including in blue green infrastructure policy, rather than just a problem to address.
- For culture and creativity, the branch recommends the Agent of Change principle is taken into account at strategic development plan stage, with zoning taking consideration of existing businesses.
- Given some low carbon energy technologies are permitted development, there must be acknowledgement that noise should be considered in their deployment, as adherence to planning does not confer immunity to noise nuisance.
- Looking at low carbon living, urban edges and green belt it is noted that there is no acknowledgement of the Quiet Areas adopted under the Environmental Noise (Scotland) Regulations 2006 or of strategic noise mapping outcomes.
In examining the accompanying Environmental Report:
- numerous references to ‘nuisance’ are noted. Given nuisance is a legal term not part of NPF4, it is recommended that this is replaced with ‘adverse impact’.
- On electric vehicles, IOA recommend it should state “electric vehicles are quieter when travelling at low speeds” given moving to electric vehicles will not solve noise problems adjacent to higher speed roads where tyre noise dominates.
NPF4 differs from previous NPFs it that it incorporates Scottish Planning Policy and the NPF into a single document and will form a part of the statutory development plan.
Full response attached.