On 7 February 2025, RTPI Scotland submitted a response to proposals by the Scottish Government to amend policy on the protection afforded to certain Ramsar features. Read the response below or access the PDF here.
1. Do you agree that all Ramsar natural features should be given the same level of scrutiny when assessing potential effects of any new plan or project, by treating all natural features on Ramsar sites in the equivalent way to European sites for the purposes of the Habitats Regulations Appraisal process?
Yes
Please provide any comments in support of your response:
RTPI Scotland broadly supports the proposal to amend current policy to treat all Ramsar sites/natural features as European sites for the purposes of the Habitats Regulations Appraisal process. We acknowledge the potential conflicts and contradictions that can arise from the current two tier system, and we would support the amendment of policy that aligns with current policy practice in England and Wales.
Notwithstanding the above, we note the intention set out above to "take forward proposed amendments to NPF4 at the next relevant and applicable opportunity". This is very vague and it is unclear what mechanism is to be utilised to make this amendment to NPF4.
We are aware that plans are underway to introduce regulations to enable amendments to the Development Plan without triggering a full review. The Scottish Government consulted on the proposed regulations in May of last year.
It is unclear from the current consultation if the proposed changes to NPF4 would be undertaken as an individual amendment utilising the powers of the forthcoming regulations, or as a part of a broader package of changes that would then trigger a full review of NPF4. In our response to the Development Plan Amendment Regulations consultation, we voiced our concern that adopting a 50% trigger for a full review treats all amendments the same without considering the potential implications of those amendments. It was our view that the trigger for a full review of the NPF should not solely be based on the quantity of proposed changes, but also on the potential significance of those changes on the intent, interpretation and implementation of the NPF.
Whilst the Institute is supportive of policies that enhance the protection of sites of environmental significance, any proposed amendment to NPF4 will need to be taken forward in line with the amendment process set out in future regulations.
