Formal Board Paper 1 Annex 1.3 - Site assessment methodology
Cairngorms National Park Authority Ùghdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
Formal Board Paper 1 Annex 1.3 13 March 2026
Paper 1
Annex 1.3
Cairngorms National Park Authority Ùghdarras Pàirc Nàiseanta a’ Mhonaidh Ruaidh
Overarching topics
Schedule 3: Site assessment methodology
Cairngorms National Park Local Development Plan: Evidence Report March 2026
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Schedule 3: Site assessment methodology
March 2026
Schedule contents
Requirements addressed in this schedule 2 Links to evidence 2 Summary of evidence 4 Policy context 4 National Planning Framework 4 4 Legislation and national documents 9 Key agency documents 16 National Park Authority documents 23 Baseline 23 This section provides baseline information on the following matters:
- Site assessment methodology 23
- Site assessment template 26 Evidence gaps 26 Summary of stakeholder engagement 26 Summary of implications for Proposed Plan 27 Statements of agreement 28 Statements of dispute 31
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Requirements addressed in this schedule
Table 1 Information required by the Town and Country Planning (Scotland) Act 1997 (CNPA003), as amended, regarding the issue addressed in this schedule.
| Section | Requirement |
|---|---|
| Section 16B(4)© | The evidence report is also to include a statement on the extent to which the views expressed under paragraphs (a) and (b) have been taken into account in the report. |
| Section 264A | In the exercise, with respect to any land in a National Park, of any power under the planning Acts, special attention shall be paid to the desirability of exercising the power consistently with the National Park Plan as adopted under section 12(7)(a) of the National Parks (Scotland) Act 2000 (asp 10). |
Links to evidence
Legislation
- CNPA003 — Town and Country Planning (Scotland) Act 1997
- CNPA004 — National Park (Scotland) Act 2000
- CNPA946 — Environmental Assessment (Scotland) Act 2005
- CNPA226 — The Conservation (Natural Habitats, &c.) Regulations 1994
- CNPA684 — The Town and Country Planning (Development Planning) (Scotland) Regulations 2023
National documents
- CNPA004 — National Park (Scotland) Act 2000
- CNPA008 — National Planning Framework 4
- CNPA009 — Local Development Planning Guidance 2023
- CNPA234 — Updated Scottish Government policy on protecting Ramsar sites
- CNPA947 — The Deliverability of Site Allocations in Local Development Plans (February 2020)
Key agency documents
- CNPA206 — Joint Local Development Plan Site Assessment and Strategic Environmental Assessment Checklist (February 2024)
- CNPA207 — Guidance on Key Agency engagement with local development plan site appraisals (March 2025)
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- CNPA948 — Historic Environment Scotland engagement in LDP site appraisal and assessment
- CNPA208 — Scottish Environment Protection Agency Planning Advice Note for Planning Authorities: Scottish Environment Protection Agency engagement in local development plan site appraisal and assessment (May 2025)
- CNPA949 — NatureScot Planning and Development: standing advice and guidance documents — Development Planning (website)
- CNPA1391 – NatureScot guidance note – the handling of mitigation in Habitats Regulations appraisal – the People Over Wind CJEU judgement
National Park Authority documents
- CNPA010 — Cairngorms National Park Partnership Plan 2022 – 2027
- CNPA097 — Cairngorms National Park Local Development Plan 3: Strategic Flood Risk Assessment 2024
- CNPA1261 – Cairngorms National Park Local Development Plan 3: Site assessment template
- CNPA210 — Draft site assessment template (engagement version) — August 2025
- CNPA211 – Cairngorms National Park Local Development Plan 3 Strategic Environmental Assessment Scoping Report
- CNPA1343 — Topic: Site assessment methodology — engagement version
Consultation material
- CNPA338 — 01954 — Scoping — Cairngorms National Park Authority — Cairngorms National Park Local Development Plan 3 — HES response — 15 September 2025
- CNPA339 — 01954 — Scoping — Cairngorms National Park Authority — Cairngorms National Park Local Development Plan 3 — NatureScot Response — 18 September 2025
- CNPA340 — 01954 — Scoping — Cairngorms National Park Authority — Cairngorms National Park Local Development Plan 3 — SEPA response — 22 September 2025
- CNPA1340 — Evidence report engagement responses
- CNPA1034 — SEPA Response to Site assessment methodology
- CNPA1421 — Scottish Forestry response to consultation 24 Sept 2025
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Summary of evidence
Policy context
National Planning Framework 4
National Planning Framework 4 (CNPA008) came into force in February 2023 and is the long term National Spatial Strategy for Scotland. For the first time it contains a set of planning policies that form part of the statutory development plan.
Scotland’s national spatial strategy is divided into three parts which are sustainable places, liveable places and productive places, each with two spatial principles, national developments and policies. This overarching, integrated strategy should form the basis of the local development plan’s site selection and assessment methodology and is therefore set in Error! Reference source not found..
Table 2 National Planning Framework 4 – National spatial strategy, spatial principles and what it means for sustainable, liveable and productive places
| Sustainable places |
|---|
| National spatial strategy ‘Scotland’s future places will be net zero, nature-positive places that are designed to reduce emissions and adapt to the impacts of climate change, whilst protecting, recovering and restoring our environment.’ |
| Spatial principles Just transition – empowering people to shape their places and ensure the transition to net zero is fair and inclusive. Conserving and recycling assets – making productive use of existing buildings, places, infrastructure and services, locking in carbon, minimising waste, and building a circular economy. |
| What it means for site selection and assessment Ensuring the right development happens in the right place. Development that is accessible by sustainable travel. Using land wisely including through a renewed focus on reusing vacant and derelict land to help limit the new land that we build on. Protecting and enhancing our historic environment. |
| Liveable places National spatial strategy ‘Scotland’s future places will have homes and neighbourhoods that are healthier, affordable and vibrant places to live.’ |
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| Spatial principles |
|---|
| Local living — supporting local liveability and improve community health and wellbeing by ensuring people can easily access services, greenspace, learning, work and leisure locally. Compact urban growth – limiting urban expansion so we can optimise the use of land to provide services and resources, including carbon storage, flood risk management, blue and green infrastructure and biodiversity. |
| What it means for site selection and assessment Creating communities that are inclusive, empowered, resilient, safe and provide opportunities for learning – local living shaped by local context. Homes served by local facilities and services – enough land in the right locations to meet future needs and aspirations. Higher density development to sustain public transport and support local living. Virtual connectivity and investment in active travel links. * Green infrastructure to connect people with nature. |
| Productive places National spatial strategy ‘Our future places will attract new investment, build business confidence, stimulate GDP (Gross Domestic Product), export growth and entrepreneurship, and facilitate future ways of working.’ |
| Spatial principles Rebalanced development – targeting development to create opportunities for communities and investment in areas of past decline and managing development sustainably in areas of high demand. Rural revitalisation. Encouraging sustainable development in rural areas, recognising the need to grow and support urban and rural communities together. |
| What it means for site selection and assessment Diversification of town and commercial centres. Distributing development, investment and infrastructure strategically by enabling rural development. |
Relevant National Planning Framework 4 policies Policy 1 Tackling the climate and nature crisis requires significant weight to be given to the global climate and nature crises in the consideration of all development proposals. This includes by ensuring that the local development plan’s spatial strategy will reduce emissions and adapt to current and future risks of climate change by promoting nature
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recovery and restoration in the area. Site allocations will be a key part of the spatial strategy¹.
This is reinforced by Policy 2 Climate mitigation and adaptation which requires local development plans to guide development to, and create, sustainable locations based on the six spatial principles, informed by an understanding of the proposals on greenhouse gas emissions².
Within the context of Policies 1 and 2, the key policies relating to site selection and assessment are Policy 16 Quality Homes and Policy 26 Business and industry.
Policy 16 advises that deliverable land should be allocated to meet the ten year Local Housing Land Requirement in locations that create quality places for people to live. The location of new home allocations should be consistent with local living including, where relevant, 20 minute neighbourhoods and an infrastructure first approach³.
Policy 26 requires local development plans to allocate sufficient land for business and industry, in particular ensuring that there is a suitable range of sites that meet current market demand, location, size and quality in terms of accessibility and services. The allocations should take account of local economic strategies and support objectives of delivering a low carbon and net zero economic recovery, and a fairer and more inclusive wellbeing economy⁴.
The following policies place requirements on the local development plan, which will be important considerations for site selection and assessment.
Policy 4 Natural Places requires local development plans to protect locally, regionally, nationally and internationally important natural assets. When allocating land, the spatial strategy should safeguard them and consider the objectives and level of their protected status⁵.
¹ Matters relating to Policy 1 are covered in a range of schedules including Schedule 4: Climate change, Schedule 5: Natural heritage: Schedule 8: Land use, soil and resources and Schedule 19: Flood risk and water management. ² Matters relating to climate change are covered in a range of schedules. An overview is in Schedule 4: Climate change. ³ Matters relating to housing are covered in Schedule 13: Housing. ⁴ Matters relating to business and industry are covered in Schedule 21: Economic development. ⁵ Matters relating to natural places are covered in Schedule 5: Natural heritage, Schedule 6: Landscape, Schedule 7: Historic and cultural heritage and Schedule 8: Land use, soil and resources.
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Policy 5 Soils requires local development plans to protect locally, regionally, nationally and internationally valued soils. This means limiting development on prime agricultural land (or land of lesser quality that is culturally or locally important for primary use), peatland, carbon rich soils and priority peatland habitat to a series of exceptions (and subject to the more detailed policy wording) relating to essential infrastructure only where there is a specific locational need; small scale development directly linked to a rural business, farm or croft; production and processing facilities associated with the land; the generation of energy from renewable sources or the extraction of minerals. Note that there is no prime agricultural land in the National Park.
Policy 9 Brownfield, vacant and derelict land and empty buildings aims to maximise the use of existing land and buildings and minimise additional land take. Policy 9(b) states that proposals on greenfield sites will not be supported unless the site has been allocated for development or the proposal is explicitly supported by policies in the local development plan. The site selection and assessment methodology therefore need to carefully consider and justify any proposals for greenfield development in the context of brownfield land availability⁶.
Policy 12 Zero waste requires local development plans to identify appropriate locations for new waste management infrastructure to support the circular economy and meet identified needs⁷.
Policy 13 Sustainable transport requires local development plans to prioritise locations for future development that can be accessed by sustainable modes. It also requires best use to be made of existing infrastructure and services. This means allocating land well served by existing or committed infrastructure in line with National Transport Strategy 2⁸.
Policy 14 Design, quality and place requires local development plans to be place-based and created in line with the place principle⁹.
⁶ Matters relating to soils and brownfield, vacant and derelict land and empty buildings are covered in Schedule 8: Land use, soil and resources. ⁷ Matters relating to zero waste are covered in Schedule 10: Zero waste. ⁸ Matters relating to sustainable transport are covered in Schedule 11: Sustainable transport. ⁹ Matters relating to design, quality and place are covered in all topic papers, with Schedule 12: Local living and 20 minute neighbourhoods, Schedule 13: Housing, Schedule 17: Play, sport and recreation and Schedule 22: Town centres and retail being particularity relevant.
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Policy 15 Local living and 20 minute neighbourhoods requires local development plans to support local living through the spatial strategy, including, within settlements, 20 minute neighbourhoods. The preparation of the spatial strategy and identification of land allocations should support local living and 20 minute neighbourhoods.¹⁰
Policy 18 Infrastructure first requires local development plans to be based on an integrated infrastructure first approach. The site selection and assessment methodology therefore need to consider infrastructure capacity¹¹.
Policy 19 Heat and cooling requires the spatial strategy to consider areas of heat network potential¹².
Policy 22 Flood risk and water management requires local development plans to avoid development in areas at flood risk as a first principle. This should be supported by managing the need to bring previously used sites in built up areas into positive use¹³.
Policy 27 City, town, local and commercial centres requires local development plans to provide a proportion of their local housing land requirement in city or town centres and be proactive in identifying opportunities to support residential development.
Policy 28 Retail advises that when local development plans are allocating sites for housing, that they consider the need for further retail provision to both meet the need for neighbourhood shopping and to support local living¹⁴.
¹⁰ Matters relating to Local living and 20 minute neighbourhoods are covered in Schedule 12: Local living and 20 minute neighbourhoods. ¹¹ Matters relating to the provision and capacity of infrastructure are covered in the following evidence papers:
- Schedule 10: Zero waste
- Schedule 11: Sustainable transport
- Schedule 14: Education
- Schedule 18: Health and safety
- Schedule 19: Flood risk and water management
- Schedule 20: Digital infrastructure ¹² Matters relating heat and cooling are covered in Schedule 15: Heating and cooling. ¹³ Matters relating Flood risk and water management are covered in Schedule 19: Flood risk and water management. ¹⁴ Matters relating to the city, town, local and commercial centres and retail are covered in Schedule 12: Local living and 20minute neighbourhoods, Schedule 13: Housing and Schedule 22: Town centres and retail.
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Policies 3 Biodiversity, 7 Historic assets and places, 11 Energy, 13 Sustainable transport, 24 Digital infrastructure, and 33 Minerals require the cumulative impacts, in combination with other development, to be considered. In the context of the strategic transport network, the effect on the operational performance of transport networks of a number of developments in combination may mean that different mitigation is needed compared to when considered individually.
Legislation and national documents
National Park (Scotland) Act 2000
The National Park has four distinct aims as set out in The National Parks (Scotland) Act 2000 (CNPA004). As outlined in Schedule 1: Plan outcomes, the four aims will be amended by the Natural Environment Scotland (Scotland) Bill (CNPA634) once enacted. The aims, once amended, will be:
- To conserve and enhance the area’s natural and cultural heritage.
- To promote sustainable management and use of the area’s natural resources.
- To promote public understanding and enjoyment of the area’s natural and cultural heritage.
- To promote sustainable economic, social and cultural development of the area’s communities.
All of the aims are relevant to the matters discussed in this schedule. The aims are all to be pursued collectively. However, if there is conflict between the first aim and any of the others, greater weight is given to the first aim (as set out in Section 9(6) of the 2000 Act).
The Deliverability of Site Allocations in Local Development Plans 2020
Published in February 2020 by the Scottish Government the document (CNPA947) summarises a survey of the 32 Scottish local planning authorities and the two Scottish national parks. It explores the types of information provided by site promoters to demonstrate a development site’s deliverability and how that information is used by planning authorities. The research and report were prepared by Ryden LLP, with assistance from Neil Collar of Brodies LLP.
It concludes that the focus of site assessment, at that time, was on the initial deliverability of development land through assessment of constraints, and not upon the subsequent deliverability of development.
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It identified ‘a major and consistent gap’ between site assessment information requirements and the information typically provided by site promoters. It noted that information on physical constraints is ‘usually’ or ‘seldom’ provided, and market information ‘seldom’. It found that small towns and rural planning authorities receive less applicant information on site constraints than other authorities.
It found that site assessments by planning authorities share similar criteria, but the sieve order and weighting – by market factors, physical capacity / constraints, or spatial plan priorities – are not consistent and could potentially influence the short listing and thus the allocation of sites. In addition, it noted that weaker market areas can end up with a very limited choice of sites, so that the ‘best promoted’ sites are favoured.
The report advises that the concept of viability within deliverability is valid, but its application must be treated with caution. It highlights that many market sectors and locations in Scotland will struggle to fully fund all land assembly, site works, infrastructure, policy requirements and development on a ‘day one’ assessment and that seeking funding solutions and value engineering during and post allocation are normal activities.
It advises that the site allocation process should embed market realities but should not inadvertently place these ahead of spatial planning considerations. It advises that this will be particularly important as action / delivery programmes are bound more tightly into the process of land releases.
The research proposes a proportionate framework for assessing the deliverability of site allocations. It seeks to improve confidence in deliverability across different site types, uses, geographies, and through the planning system from local development plan allocation onwards.
It proposes a staged and scaled site assessment which applies as a site progresses through the planning system and is proportionate to different sites. This is illustrated in Table 3.
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Table 3 Staged and scaled sites assessment (Figure 1 of the deliverability of site allocations in local development plans report). Note that the ‘future approach’ identified in this diagram differs from the approach set out Scottish Government’s Local Development Planning Guidance and The Town and Country Planning (Development Planning) (Scotland) Regulations 2023 (CNPA684).
| Current approach: |
|---|
| Calls for Sites → Main Issues Report → Proposed Plan → Local Development Plan |
| Future approach: |
| Call for Sites and spatial plan → Gatecheck → Local Development Plan |
| Stage 1 | Stage 1 information | Stages 1 and 2 information |
|---|---|---|
| Stage 2 | Stage 3 | |
| Local, small, early, rural, passive / patient sites | Major sites | Strategic sites: high impact, complex delivery |
The first stage is intended to provide sufficient information to conduct a sieve of sites, including sites submitted through a call for sites, existing allocations and unbuilt sites with planning permission. It would include site information, land use proposals, descriptions and distances to facilities as well as an initial indication of issues relating to natural heritage and the environment, historic environment or other potential constraints. This first sieve would also be subject to a spatial planning approach to determine whether the site would be in broad accordance with the emerging local development plan.
The report highlights that deferring or demoting spatial planning considerations during the site allocation process risks skewing development planning towards a more market led process, however it does recognise that viability and funding are the lynchpin of deliverability, when the site is acceptable in broad policy terms, and therefore stage 1 should consider whether there is:
- A willing landowner.
- A willing developer or a note of market potential.
- Awareness of policy requirements and the infrastructure context.
- Confirmation that, in these contexts, the site is believed to be viable (or if not that there is a potential deficit funding solution).
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Stage 1 will yield three types of outcomes:
- Sites not suitable for development plan allocation.
- Sites suitable for allocation without further information being sought. In the interest of transparency and best information there may some minor further dialogue with promoters or other organisations. These sites could proceed straight to proposed allocation.
- Sites where further information is required via a Stage 2 assessment.
Stage 2 is intended for major sites (greater than 50 houses / 2 hectares) which are being promoted for development plan allocation. While stage 1 seeks information and land promoter awareness of factors affecting deliverability, stage 2 seeks evidence. This is likely to include requirements for layout plans, development mix and phasing, community engagement and site conditions. Evidence of development viability and target markets would be required for housing uses and target markets for employment and commercial uses.
The report also suggests a stage 3 site assessment for very large strategic sites, which, it advises, demands a much higher hurdle than local or major sites.
The report recommends that data is captured via spreadsheets that include some functionality, for instance with hyperlinks to policies, maps and infrastructure information and forms with minimal open-ended questions and free text (where possible yes / no fields or numerical answers).
Note that this research, and its recommendations, were produced prior to the adoption of National Planning Framework 4.
Local development planning guidance 2023
The guidance (CNPA009) sets out the Scottish Ministers’ expectations for new style local development plans. It advises that it should be considered together with National Planning Framework 4 and relevant legislation to give a full understanding of all requirements and expectations for local development plans. It replaces and repeals Scottish Government Planning Circular 6/2013 and the guidance states that it should be given the same weight as the repealed circular.
It is intended to assist and support planning authorities and others with an interest, rather than creating requirements in addition to those in legislation.
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Planning authorities are expected to consider how the guidance can be applied in a proportionate and place based way and to use their discretion in deciding which components of the advice are relevant to their plan preparation.
In relation to site selection, the guidance highlights National Planning Framework 4’s infrastructure first approach and advises that, in preparing local development plans, infrastructure considerations should inform site selection and the evolution of the spatial strategy, not be a by product of it (paragraph 41).
The guidance (figure 5, page 18) sets out the key stages and assessments of the local development plan process. At the time of writing, the Cairngorms National Park is within the first stage, evidence gathering, where the focus is on establishing the evidence baseline through collation of evidence and seeking the views of key agencies, children and young people, and the public at large. Following the gate check, plan preparation commences. This includes preparing a spatial strategy, early engagement, for instance through a ‘Call for Ideas’, and site assessment.
Paragraph 108 advises that ‘detailed policies and site proposals should not be included in the evidence report. Detailed site appraisal will not be appropriate at the evidence report stage, but the authority could usefully establish a site appraisal methodology that will be used to appraise sites and inform allocations for the proposed plan. This could also be linked or ideally integrated with the approach to Strategic Environmental Assessment’.
Paragraphs 141 – 190 provide a step by step guide to preparing proposed plans and advice on taking account of National Planning Framework 4 policies. While preparing the proposed plan is the next stage, following the approval of the evidence report, the guidance provides helpful guidance on how to establish a site appraisal methodology.
Paragraph 152 advises that all sites should be assessed using the site appraisal methodology agreed in the evidence report. This includes sites allocated in an existing local development plan; sites proposed through any call for ideas and any other sites the planning authority considers may have potential.
Paragraph 153 advises that the site appraisal process and the Strategic Environmental Assessment requirements can be helpfully linked as they cover similar environmental topics. It also notes that all ‘potential’ sites should be covered by the Strategic Environmental Assessment, so that if, at examination, it is considered that additional sites need to be identified, these have already been assessed.
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Paragraph 154 advises that no site should automatically roll forward from one plan to the next without being assessed. All sites proposed to be allocated for development in plans should have been assessed for their deliverability through the site appraisal process.
The document provides guidance on relevant parts of the national planning framework 4 in relation to each stage of local development plan preparation. In relation to Policy 16 Quality homes, it confirms that the location of homes should be in line with the plan’s spatial strategy and informed by engagement with public, private and community interests. It advises use of the Place Standard, consideration of local place plans and guidance on local living and 20 minute neighbourhoods can inform allocation choices.
In relation to Policy 26 Business and Industry, the guidance advises that all sites under consideration for allocation should be assessed for their ability to meet current needs and market expectations and that flexibility and resilience for business and industry should be built into site allocations. It advises that where existing business sites are underused, for example where there has been an increase in vacancy rates, reallocation to enable a wider range of viable businesses or alternative uses may be considered, taking careful account of the potential impacts on existing businesses on the site.
It also advises that ‘local development plans should encourage, including by use of the spatial strategy and site allocations, opportunities for homeworking, live-work units, micro-businesses and community hubs. In the past industrial and business areas have tended to be located at a distance from residential areas. As our economy continues to evolve, there may be scope for greater integration of work and living as inter-related land uses which will also support our ambition for net zero. This can help to tackle inequalities by providing more accessible, local job opportunities which reduce the need to travel’.
In relation to Strategic Environmental Assessment, paragraph 184 recognises that, if a planning authority undertakes a call for ideas stage, any site may be submitted. It advises that ‘it is legitimate for the authority to assess each site through the broad principles of the spatial strategy prepared as part of the work on the proposed plan’.
Paragraph 185 continues on this theme, advising that the place based approach to plans (for example on a settlement / neighbourhood basis), ‘allows the opportunity to reflect the broad environmental impacts and benefits of the policies and proposals
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rather than impacts of individual sites, which can support proportionality in terms of reporting and potentially a more engaging report as a consequence’.
Strategic Environmental Assessment
Strategic Environmental Assessment is a statutory requirement that aims to ensure the environment is a primary consideration in the preparation of qualifying public plans, programmes and strategies. The Environmental Assessment (Scotland) Act 2005 (CNPA946) requires those preparing qualifying plans, including the local development plans, to undertake a Strategic Environmental Assessment. Strategic Environmental Assessment can benefit the preparation of a local development plan, supporting better understanding of its environmental context and setting out steps to avoid, mitigate or reduce significant adverse effects, where possible, or enhance positive ones. Improving the consultation process lies at the heart of Strategic Environmental Assessment, ensuring the public and those who will be consulted are provided with the relevant environmental information relating to the plan to allow them to make informed choices.
The Strategic Environmental Assessment process is divided into five main stages which are:
- Stage A: Setting the context and objectives, establishing the baseline, and deciding on the scope.
- Stage B: Developing and refining alternatives and assessing effects.
- Stage C: Preparing the Environmental Report.
- Stage D: Consulting on the Environmental Report.
- Stage E: Monitoring implementation of the Local Development Plan.
The Consultation Authorities, who are NatureScot, Scottish Environment Protection Agency and Historic Environment Scotland, must be engaged on at each stage of the Strategic Environmental Assessment process. The assessment process will algin and form a key part of the site assessment process. The approach to this is set out within this schedule.
The Park Authority has already prepared and undertaken engagement on the Strategic Environment Assessment Scoping Report (Stage A) (CNPA211). Consultation responses have been received from NatureScot (CNPA339), Scottish Environment Protection Agency (CNPA340) and Historic Environment Scotland (CNPA338) and these will inform the preparation of the Environmental Report (Stage C).
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Habitats Regulations Appraisal
Those preparing a local development plan must also undertake a Habitats Regulations Appraisal in accordance with The Conservation (Natural Habitats, &c.) Regulations 1994 (CNPA226), if the plan is capable of having an adverse effect on a European site(s), either alone or in combination with other plans or projects. European sites are Special Areas of Conservation and Special Protection Areas. As of 9 July 2025 (CNPA234), Ramsar sites are also to be treated as if they were European sites for the purposes of land use change decision making.
In this situation the planning authority would have to undertake an ‘Appropriate Assessment’ of the implications for any designation(s) in view of the site’s conservation objectives, in order to avoid any adverse impacts, before the plan can be adopted. Where an appropriate assessment is required, the competent authority must consult NatureScot.
The Habitats Regulations Appraisal process sits alongside the Strategic Environmental Assessment and site assessment process. Further information on the considerations for Habitats Regulations Appraisal is set out within Schedule 5: Natural heritage.
Key agency documents
The Joint Local Development Plan Site Assessment and Strategic Environmental Assessment Checklist produced by the Government Key Agencies (February 2024)
The Scottish government key agencies group distributed their assessment checklist (CNPA206) in February 2024. The Key Agencies are: Scottish Natural Heritage; Scottish Environment Protection Agency; Historic Environment Scotland; Transport Scotland; Scottish Water; and Architecture and Design Scotland. The document covers the topics:
- Water
- Biodiversity, flora and fauna
- Climate factors
- Air quality
- Population and human health
- Soils
- Landscape
- Cultural heritage
- Material assets – deliverability / sustainability constraints.
These broadly follow the issues, listed in Schedule 3 paragraph 6(a) of the Environmental Assessment (Scotland) Act 2005 (CNPA946), on which development
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proposals (referred to as plans or programmes in the Act) are likely to have ‘significant effects on the environment’.
It asks open ended questions, linking these back to National Planning Framework 4 (CNPA008) policies. It requires scoring pre-mitigation, then details of mitigation and enhancement before requiring a second post-mitigation score, with a final column for comments / conclusions.
It highlights that there are many scoring techniques and gives the example of a coloured significantly positive (++) to significantly negative ( — ) system. It also includes an explanation of the key Strategic Environmental Assessment topics.
Guidance on Key Agency engagement with local development plan site appraisals (March 2025)
This guidance (CNPA207) sets out high level principles aimed at getting the best out of the key agencies in supporting