moray local development plan 2020 · national coastal change assessment has highlighted that parts...

MORAY LOCALDEVELOPMENTPLAN 2020

EnvironmentTOPIC PAPER

DECEMBER 2017

CONTENTS1 Introduction 12 National Planning Policy 13 Providing Green Infrastructure 24 Nature Conservation 65 Safeguarding & enhancing biodiversity

in new developments 46 Protecting landscape quality 57 Environmental resources 68 Built heritage 69 Environmental protection 610 Coastal erosion 611 Delivering on climate change 612 Renewable Energy and low carbon technology 713 Developing Heat Networks 814 Sustainable construction & use of local materials 815 LDP 2020 Outcomes 9

Photo acknowledgements: Thanks to Scottish National Heritage and

AES Solar for permission to use their photographs

IntroductionThis paper is one of a number of core backgrounddocuments prepared to support the Moray LocalDevelopment Plan 2020. The opportunities to addressenvironmental issues and maximise opportunities forthe enhancement of the natural environment throughthe planning process are explored within this paper.

National Planning PolicyThe environment is an important part of our culturalidentity and contributes to our health and wellbeingand economic prosperity.

Scottish Planning Policy (SPP) seeks to supporteconomically, environmentally and socially sustainableplaces by;

l supporting climate change mitigation andadaptation including taking account of flood risk;

l having regard to the principles for sustainableland use set out in the Land Use Strategy;

l guiding renewable energy proposals to the leastenvironmentally sensitive locations;

l protecting, enhancing and promoting access tocultural heritage, including the historicenvironment;

l protecting, enhancing and promoting access tonatural heritage, including green infrastructure,landscape and the wider environment;

l reducing waste, facilitating its management andpromoting resource recovery; and

l avoiding over-development, protecting theamenity of new and existing development andconsidering the implications of development forwater, air and soil quality.

INTRODUCTION

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Environment Topic Paper

Moray 2026 - A Plan for the FutureMoray 2026 seeks to promote Moray as an area ofdiverse natural beauty where people choose to live,learn, work and enjoy. The protection andenhancement of Moray’s distinctive high qualityenvironment is considered to significantly contributeto achieving this ambition.

ContextMoray’s high quality environment is a valuable asset.The natural and historic environment contributessignificantly to the distinctive character of the area.Protecting and enhancing nature is an essential part ofdelivering sustainable development. It is essential tocreate places that are more resilient to climate change,that have distinctive local character, and in whichpeople want to live, work and visit, places thatpromote wellbeing, productivity, educational benefitsand places where communities can actively engagewith their local environment.

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Your place, Your plan, Your future - Moray Council

From wind farms to housing in the countryside thereare many environmental challenges and pressures. Thecurrent policy framework provides policies that guidedevelopment proposals in respect of a whole range ofenvironmental issues ranging from climate changeand flooding to pollution and drainage.

In general the policy framework is operatingeffectively and the main challenges for the next planare identified below.

This paper sets out: -l A review of the key environmental issues.l How to identify, expand, protect and enhance

green infrastructure.l How to promote and enhance biodiversity and

better connect people with nature.l How to protect and enhance Moray’s urban and

rural landscape.l How to embed climate change and deliver

sustainable development. l Outcomes for LDP 2020.

Providing Green InfrastructureMoray’s towns and villages benefit from good accessto high quality greenspace providing recreationalopportunities. The existing policies protectgreenspaces and provide a framework to ensure newprovision is well located and to a high standard. Therecently adopted Open Space Strategy SupplementaryGuidance sets out standards for quality, accessibilityand the quantity of open space to deliver high qualitygreenspaces and will be embedded into policy.

Green infrastructure is a network of multi-functionalgreen space, both new and existing, both rural andurban, which supports biodiversity and ecologicalprocesses and is integral to health and quality of life. Itdelivers a broad range of functions and providessocio-economic, cultural and health and wellbeingbenefits. Green infrastructure includes all greenspaces,woodlands, parks, allotments, sustainable urbandrainage systems, green roofs and street trees.

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Green Infrastructure is a cross cutting topic andoverlaps with many policy areas within the LDPincluding climate change, biodiversity, open space andplacemaking. The current LDP does not set out astrategic approach to plan positively for the creation,protection, enhancement and management of greeninfrastructure.

The LDP2020 should aim to create and enhance greeninfrastructure across the area and maximise thepotential to meet a diversity of functions, includingwildlife habitat, recreation, flood alleviation andplacemaking. Green infrastructure should aim toenhance the character and distinctiveness of an areawith regard to habitats and landscape type and shouldthread through and surround the built environmentand connect towns and villages to the widercountryside.

There are a number of ways to embed greeninfrastructure into the LDP as follows:l Embed green infrastructure delivery into

Placemaking and Green Spaces policies.

l Identify and map existing green networks in aneffort to preserve and prevent fragmentation.

l Identify broad areas where green networkscreation/expansion opportunities exist.

l Identify settlement level mapping at individualtown level.

l Identify local green network opportunities for keysites for inclusion in masterplans, developmentbriefs and site designations.

It is proposed to prepare greenspace mapping for themain towns, identifying green infrastructure thatneeds to be provided, taking account of opportunitiesto enhance linkages to create connected greennetworks.

Reference to the provision of green infrastructureshould also be added into policy and included withinthe following policies; placemaking, developmentprinciples and green spaces. For example “Newdevelopments must provide green infrastructure asrequired in the green network mapping.”

Example of Greenspace mapping

Nature conservationThe diversity of habitats and species in Moraycontribute towards the overall high qualityenvironment. Moray has a number of international,national and local conservation area sites and is hometo a number of iconic protected species. These arevaluable assets that need to be protected frominappropriate development. There are establishedpolicies in place that are working well to safeguardthese natural assets.


4 Safeguarding and Enhancing Biodiversity in NewDevelopments.The provision of green infrastructure and biodiversityare closely related. The current natural heritagepolicies ensure that the effect of developmentproposals on important species and habitats is takeninto account. There is however a lack of guidance onhow to promote and enhance biodiversity and haltbiodiversity decline. Biodiversity is important toenvironmental, social and economic wellbeing andtherefore needs to be considered strategically.

New development will have an impact on wildlife andnature conservation and therefore, there is a need toplace greater emphasis on identifying and promotingopportunities for improving biodiversity. Providinggreen infrastructure would bring biodiversity benefitsthrough the creation, expansion and enhancement ofgreen networks. New development must do more byplanting diverse species to promote and enhancebiodiversity. The recently published PollinationStrategy for Scotland identifies the need to addressthe decline in populations, diversity and range ofpollinator species. Actions include promoting,restoring and creating flower rich habitats in thecountryside and in urban areas to support ecologicalnetworks to help them thrive in the future.

Considering green infrastructure, biodiversity andopen space collectively allows a more strategicapproach to natural heritage to be taken, in whichwildlife corridors, landscape features, watercoursesand areas of open space are linked together. This willalso help to ensure the protection and enhancementof biodiversity, minimise further fragmentation ofhabitats and realise benefits in terms of climatechange and placemaking.

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Protecting Landscape QualityMoray’s high quality landscape helps to create aunique place that is locally distinctive. There arepressures on the landscape from wind energy, inparticular on the edge of the Cairngorms National Parkas well as proposals for solar arrays, grid connectionsand housing in the countryside. Safeguarding is inplace with Countryside Around Towns (CAT)designations around the main towns restrictdevelopment and require careful planning in thetransition area between the town and country,preserving the connection between communities andthe wider countryside. The Coastal Protection Zone(CPZ) seeks to safeguard the special qualities of thispart of the Moray landscape by seeking to preventinappropriate development on the coast.

At present there are identified Areas of GreatLandscape Value (AGLV’s) that cover a significant partof Moray, these are areas where the scenery is highlyvalued and the landscape should not be damaged byinappropriate development. Scottish Natural Heritageis undertaking work to produce a revised landscapecharacter assessment for Moray and Nairn. This raisesthe relevance and function of the broad brushapproach currently taken to landscape issues andwhether AGLV’s should be renamed as SpcialLandscape Area’s (SLA’s) and replaced with alandscape character area based approach thatrecognises the distinctive character and speciallandscape qualities of the particular landscape typesacross Moray.

Woodlands and forests cover 33% of Moray and makean important contribution to quality of life, landscape,health, wildlife and biodiversity, recreation, educationand local amenity, flood management and reducingthe impacts of climate change. These woodlands andforests need to be protected and carefully managed todeliver multiple benefits. There are policies in place todeliver compensatory planting to mitigate woodlandremoval. The Moray Woodland and Forest StrategySupplementary Guidance seeks to promote newwoodland creation adjacent to settlements and willoffer the opportunity to link these to proposed greennetworks threaded through the main towns.

Environmental ResourcesThe current policies provide an effective framework toensure the sustainable use of natural resourcesincluding prime agricultural land, woodlands, mineralreserves and consider opportunities for renewableenergy generation. There is limited vacant andderelict brownfield land, so the nature of Moray withrelatively small urban areas means the release ofgreenfield land to meet housing land requirements.This approach impacts upon the countryside aroundour towns and therefore the transition from urban torural areas is important. The natural environment isalso recognised as a resource for recreation,biodiversity and associated health benefits.

Built HeritageMoray benefits from a number of important sites forcultural heritage, townscapes and buildings havedistinctive characteristics and provide variety acrossthe area. This heritage contributes greatly to thecharacter of Moray and provides a sense of place andidentity. The current policy framework is working wellto protect, conserve and enhance the historicenvironment; it is proposed to condense the policiesinto a single succinct and focused policy.

Environmental ProtectionThere is a policy framework in place to protect theenvironment from adverse impact. Flooding policiesseek to direct development away from areas offlooding and ensure new development does notincrease the possibility of flooding elsewhere. Newdevelopment must enhance the water environmentthrough the use of sustainable urban drainagesystems (SUDS). These policies are well establishedand it is not proposed to significantly amend them.

Coastal ErosionThe recently published Dynamic Coast: Scotland’sNational Coastal Change Assessment has highlightedthat parts of the Moray coast are eroding more quicklythan anticipated. This needs to be recognised inpolicy as it has potential implications for agriculture,tourism, transport, infrastructure, buildings, culturaland natural heritage interests.

Delivering on Climate ChangeDespite being a primary policy in the current LDP, it isnot considered climate change has been effectivelyembedded or delivered through the current plan. Therequired sustainability checklist has not advanced thedelivery of sustainable development in Moray.Developers have instead continued to meet or slightlyexceed the current Building Standards Regulationsand there has been no significant increase in the useof renewable technologies, sustainable constructiontechniques or use of local materials.

Consideration needs to be given to embedding climatechange across the LDP, possibly by strengtheningdelivery through all policies. There is obvious overlapwith the primary policy on placemaking and there maybe an opportunity to strengthen climate change withinthe quality audit process. Many aspects of the identifiedactions to address climate change can beaccommodated in the quality audit process includingpassive solar gain, use of sustainable materials, SUDSand sustainable transport. It is important that these areincorporated in a meaningful way.

The proposal for a strategic approach to greeninfrastructure is seen as having potentially significantlocal climate change benefits in terms of natural floodmanagement, biodiversity and habitat creation.


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Elgin Skyline

Hopeman coastline

Renewable Energy and Low Carbon TechnologyStrengthening climate change across the policies andseeking climate change action through the placemakingpolicy and quality audit process does not deal with allaspects of the current climate change policy.

In particular there is a desire to support and promotezero and low carbon technologies in newdevelopments. It is acknowledged that the absence ofa target within the current LDP has made it difficult torequire developers to install these technologies.

The 2008 Moray Development Plan included a carbonemission reduction policy related to delivering therequired Building Standards emission reductionsthrough the use of low and zero carbon technologies.Reintroducing a policy of this nature has resourceimplications in terms of assessing calculations toconfirm compliance.Set out below are examples of approaches fromelsewhere.

Dundee Local Development Plan 2014Low and Zero Carbon Technology in NewDevelopment

Proposals for all new buildings will be required todemonstrate that at least 10% of the carbon emissionsreduction standard set by Scottish Building Standards(2007) will be met through the installation andoperation of zero-carbon generating technologies.This percentage will increase to 15% from thebeginning of 2016 and will be reviewed in 2018.

This requirement applies to all new buildings with thefollowing exceptions:1) Alterations and extensions to buildings. 2) Change of use or conversion of buildings. 3) Ancillary buildings that stand alone and cover an

area less than 50 square metres. 4) Buildings which will not be heated or cooled,

other than by heating provided solely for frostprotection.

5) Buildings which have an intended life of less thantwo years.

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A statement will be required to be submitteddemonstrating compliance with this requirement.

Fife Plan 2017Planning permission will only be granted for newdevelopment where it has been demonstrated that;The proposal meets the current carbon dioxidereduction target (as set out by the Scottish BuildingStandards) and that low and zero generatingtechnologies contribute at least 20% of these savings.

Edinburgh City Council Local Development Plan2016Planning permission will only be granted for newdevelopment where it has been demonstrated that:the current carbon dioxide emissions reduction targethas been met, with at least half of this target metthrough the use of low and zero carbon generatingtechnologies.

Solar panels in Forres

Developing Heat NetworksMoray relies on centralised gas and electricity, and oilin rural areas, for most of its heating needs. TheScottish Government is promoting local heat networksas a feasible and efficient way of providing heat andelectricity. District heating is most suitable wherethere is a high density of built development and ananchor development creating a constant demand forheat. Moray has a significant number of heat sourcesin the form of distilleries; however these are remotefrom populations and in areas that lack identifieddevelopment sites.

At present insufficient research has been undertakento identify district heating/heat network opportunitiesin Moray. The Scottish Government has produced theScotland Heat Map and this will be used to screen sitesand identify opportunities to utilise excess heat. Thereis a requirement for Phase 2 of the Elgin SouthMasterplan to investigate the feasibility of utilisingexcess heat from a nearby distillery.

Sustainable Construction and Use of LocalMaterialsMoray has an excellent resource in the form of theFindhorn Ecovillage which is an internationallyrecognised leader in sustainable design andconstruction. The LDP policies should do more topromote sustainable construction techniques and theuse of locally grown timber in new developments.

The Moray Woodland and Forestry Strategy highlightsthe opportunity to promote the use of locally growntimber in new buildings. The strategy recognises thereare specialist architects throughout the area who haveconsiderable expertise in using local timber andencouraging this through policy offers theopportunity to develop demand for locally growntimber. Opportunities for this will be explored withlocal architects with a specialism in the use of localtimber.


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Findhorn Ecovillage

Identified outcomes based on the key issues are setout in the table below. 9


Outcomes for LDP 2020

Embed green infrastructure into policy (openspace/green space, development proposals orplacemaking)

Prepare mapping to support identification andexpansion of green infrastructure.

Delivery of green infrastructure and connectingblue and green networks will have positiveimpacts on biodiversity. Biodiversity benefitsshould be highlighted within approach to greeninfrastructure. Embed enhancing biodiversity inthe quality audit process.

Revisit climate change as principle policy.Consider alternative means of embedding climatechange through the LDP (placemaking).

Consider incorporate/strengthening essentialclimate change principles into quality audit anddesign principles for new developments.Investigate options for requiring use ofrenewable/low carbon technologies and the use oflocal timber.

Require large scale developments to investigatefeasibility of energy centres etc. utilising Scotland’sheat map.

Environmental Issues

Green InfrastructureProvision

EnhancingBiodiversity

Delivering on ClimateChange

Assessment

Lack of policy to promotestrategic approach to thedelivery of green infrastructure.

Need to strengthen approach tobiodiversity enhancement

The current policy is notworking as intended and notimproving the sustainability ofnew developments in Moray.

LDP 2020OUTCOMES 2


10 Outcomes for LDP 2020

Consider revised landscape character assessmentsto replace blanket AGLV designation.

Review Countryside Around Towns (CAT)boundaries.

Prepare new housing in the countryside policy.

Amalgamate into single policy.

Environmental Issues

Protecting LandscapeQuality

Built Heritage

Assessment

The current Areas of GreatLandscape Value are blanketdesignations that cover largeareas of Moray and do not focuson the special qualities ofspecific parts of Moray and whyit is important to protect them.

Cumulative build-up of housingin the countryside is having anegative impact on landscapequality.

There are well establishedpolicies covering build heritagethat are working well.

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