Print

Print


Can i ask for what purpose would a consultant table the use of C4SL in Scotland at the moment?   to make a planning argument (i.e below C4SL= acceptable for planning) or to argue around a P2A determination (below C4SL = Site is not PIIA?)

Whilst (in my own personal opinion) i don't think the C4SL appear unreasonable in their method of derivation, it is also my opinion, discussion on the acceptability of C4SL in Scotland is premature at the moment for a number of reasons :

*The C4SL were derived to assist with E&W Statutory Guidance, which is divergent from Scot Stat Guidance;

*There appears to be a lively debate (with no consensus to date) within the E&W ConLand Community (evidenced by discussions on here) on whether C4SL are appropriate or not for use within the Planning context - until the practitioners within the regulatory regime which they were drafted (i.e E&W) take a position with respect to the acceptability of the C4SL in planning, i don't think regulators operating under a different set of Stat Guidance (both Planning and P2A)  from that which the C4SLs were derived for (i.e Scot) , should be required to make that judgenment.

* The Scot Gov has comissioned PIIA work which is currently underway and until this is published and the findings known it may be ill advised to make decisions based on E&W C4SL values . I have very little insight into the Scottish research and don't know if it will produce any meaningful output, however it could transpire that Scot Gov values which are deemed to represent P2A could be uncomfortably close to the C4SL values (or heaven forbid.... lower than the C4SL) - this would raise the prospect that land which passes the C4SL in E&W as "essentially safe" being "PIIA" land north of the border.  Whilst this situation is unlikely, until the outputs are knowm, it cannot be discounted.  If there is clear blue water between the C4SL and the Scot PIIA output, this would be easier to overcome.

*I envisage a proposal to use of the C4SL in Scotland could require the collective thoughts of the Scot Gov, Health Protection Scotland and others (?) to decide whether the C4SL approach is transferable northwards across the border as there are a number of policy decisions contained within the C4SLs which would need to be considered by the devolved govermernt (or post independence) by those and such as those who are accountable at a policy level.  And those decisions are taken way above our heads and these type of decisions don't come quickly or easily. as above,  If there is clear blue water between the C4SL and the Scot PIIA output, this would be easier to overcome.


my 2p