SWLG response to Government's 'Sustainability and Planning' consultation
December 2013
A Scottish Government consultation on 'sustainability and planning' ran between October and December 2013. The Scottish Wild Land Group responded to express our concern about the use of the term 'sustainable economic growth' (instead of 'sustainable development') at several key points in planning policy, and the implied prioritisation of economic growth over social and environmental issues. Our full response is below.
Consultation Question 1
Do you think the SPP should include a presumption in favour of development that contributes to sustainable development?
No, we do not. It is clear that sustainable development is a major aim of planning policy (except where undermined by the phrase ‘sustainable economic growth’), and we do not think it is necessary to introduce any kind of presumption beyond this. The use of the term ‘sustainable development’ clearly suggests that social, environmental and economic factors should be given equal weighting, while a ‘presumption in favour of development that contributes to sustainable development’ suggests that undue weight will be placed on the very fact of a development being proposed. Furthermore, the phrase will tend to favour developments where social and environmental costs are difficult to quantify, because the presumption in favour of development will outweigh any desire to use the precautionary principle where substantial social or environmental costs might occur. We therefore suggest that the inclusion of this presumption will further undermine the achievement of sustainable development through Scottish planning policy.
Consultation Question 2
Do you think the proposed approach to sustainability and planning is appropriate?
No, we do not. We are concerned about the continuing emphasis on ‘sustainable economic growth’, defined in the consultation document as “Building a dynamic and growing economy that will provide prosperity and opportunities for all, while ensuring that future generations can enjoy a better quality of life too.” We do not consider this definition to be coherent, but it does reinforce our existing impression that ‘sustainable economic growth’ is actually used to mean – and, in practice, only interpretable as – ‘sustained economic growth’ (i.e. economic growth above all else; “a growing economy…ensuring that future generations can enjoy a better quality of life”). Unless a definition of ‘quality of life’ based on something more than economic prosperity is included here, the obvious implication is that sustainable economic growth simply means an economy that grows consistently. Indeed, if social and environmental factors were included, the term would become synonymous with ‘sustainable development’, but this has deliberately not been used. We suggest that it should have been, and that planning policy that prioritises sustainable economic growth will, in practice, be fundamentally incompatible with sustainable development, as defined in the consultation document.
We also challenge the statement that “The Government Economic Strategy (2011) indicates that sustainable economic growth is the key to unlocking Scotland’s potential” (point 3). We do not believe that sustainable economic growth is the key to anything other than simple, unrestrained economic growth, with all of its negative social and environmental implications (and, indeed, likely negative economic implications for some sections of society). We also contend that the Government Economic Strategy simply asserted the above, and did nothing to indicate that it was true.
We are very concerned by the use of the phrase ‘sustainable economic growth’ in the Government’s ‘central purpose’, and in Scottish planning policy. We believe it should be recognised as unclear and indistinguishable in its application from ‘unsustainable economic growth’, and a highly inappropriate phrase to put at the centre of policy.
Consultation Question 3
In relation to the Equalities Impact Assessment, please tell us about any potential impacts, either positive or negative, you think the proposals in this consultation document may have on any particular groups of people.
We believe that the emphasis on sustainable economic growth will have negative impacts on groups of people who have indirect economic, social or environmental interests in particular developments. This is because there is nothing in the term or its definition that would prompt, or even allow, planning authorities to give appropriate weight to anything other than the direct economic prospects of individual developments (in contrast to the term ‘sustainable development’, which explicitly takes account of other interests).
Consultation Question 4
In relation to the Equalities Impact Assessment, please tell us about what potential there may be within these proposals to advance equality of opportunity between different groups and to foster good relations between different groups.
The use of the term ‘sustainable development’ has some potential to advance equality of opportunity, where implemented correctly, as it allows for the economic, social and environmental interests of different groups of people to be considered during the planning process, so preventing the prioritisation of the economic interests of developers.