Update November 2023
We are writing to highlight some of the recent progress that we have achieved by working together since our last update in June, and to highlight the priorities that we are taking forward now, and in the months ahead.
Key achievements – summer / autumn 2023
Work continues to progress on implementing National Planning Framework 4 (NPF4), and we published the second iteration of the NPF4 Delivery Programme in September.
With the new local development plan legislation and guidance now in place, we convened a workshop session with several planning authority representatives last month to explore early experiences with work to produce evidence reports. This is to be the first stage in the production of the new-style, evidence-led and place-focused LDPs to sit alongside NPF4, and maintaining good progress will be crucial for our stronger plan-led system.
A number of consultations closed over the summer. We are grateful for the responses we have received, which we are now considering carefully. Building on what you have told us, work is progressing to finalise guidance including on: 20 minute neighbourhoods and local living; engagement in development planning; and play sufficiency assessments. We have also now consulted on phase 3 of the review of permitted development rights and proposals for elected member training and are close to concluding guidance on chief planning officers. Following productive collaboration with stakeholders, we will shortly be finalising new guidance on housing land audits.
We are developing a structure for monitoring NPF4, but in the meantime we have been identifying aspects of policy which are generating greater than expected debate in the system.
- we are closely monitoring the application of Policy 16: Quality Homes in practice but cannot comment further on this at this point in time, given ongoing legal proceedings
- we recently discussed with planning authorities the application of Policy 17: Rural Homes. Whilst it is for decision-makers in each case to weigh up the factors for and against any proposed development, the policy intent, as set out in NPF4, is to “encourage, promote and facilitate the delivery of more high quality, affordable and sustainable rural homes in the right locations” and this will be essential to support rural repopulation, a key principle of the spatial strategy as a whole
- we will shortly convene a similar discussion focusing on: Policy 22: Flooding, involving colleagues from SEPA and the Scottish Government’s flooding team; and Policy 11: Energy and Policy 25: Community Wealth Building on economic impacts and community wealth in relation to energy developments
From our wider monitoring, discussions and correspondence in relation to the application of NPF4 policies, there have been recurring themes around the need to: (i) refer to the ‘policy intent’ for each of the NPF4 policies to support their interpretation in the circumstances of individual cases; and (ii) to consider the development plan, including NPF4, as a whole. In our letter of 8 February, we recognised that conflicts between policies can be expected – indeed that is normal. There remains a need to weigh up all relevant policies and factors in applying planning judgement, as always following the decision-making structure set by section 25 of the Planning Act.
Also supporting the delivery of NPF4, the Planning, Infrastructure and Place Advisory Group has met twice so far, with the second session exploring delivery issues and lessons learned from the large-scale development at Winchburgh, West Lothian. This December the group will agree a more detailed work programme for 2024.
In October we brought together planning authority committee conveners to update them on planning reform and explore issues they are grappling with on a day-to-day basis. As always this generated lively debate, sharing of experience and networking.
This year’s Programme for Government set out a number of priorities that will be led by our team including: to continue planning reform, including digital transformation and introduction of new regulations and guidance on masterplan consent areas; bringing forward further permitted development rights; continued delivery of the place based investment programme; and work to modernise compulsory purchase orders, as well as implementation of new infrastructure levy regulations by spring 2026. We are currently putting in place resources to support the latter commitments and expect to consult on proposed arrangements for masterplan consent areas around the turn of the year with a view to laying regulations and bringing this new proactive, development-facilitating power into effect in autumn 2024. Further work on regulations associated with amending NPF and LDPs is also progressing with the aim of consulting in the new year.
Continuing the work on implementing and supporting delivery of NPF4, we are making good progress with the production of guidance to support biodiversity policies and have commenced work on planning and climate change guidance. The Scottish Government has also published independent research on Approaches to Measuring Biodiversity in Scotland, the findings and recommendations of which set out pragmatic next steps to ensure a consistent, cross-government approach to measuring biodiversity at site level. NatureScot will shortly commence work to develop an adapted biodiversity metric suitable for use in supporting delivery of NPF4 policy 3b, engaging closely with all relevant stakeholders. In the meantime, a consultation on Scotland’s Strategic Framework for Biodiversity will run until 14 December seeking views on a range of topics and proposals related to biodiversity and tackling the nature emergency in Scotland.
Recognising the significance of providing more quality homes across Scotland, a joint Ministerial roundtable with both Planning and Housing Ministers is taking place in November. It will consider planning focused actions that different sectors can take, both individually and collectively, to support acceleration of delivery.
Resourcing of the planning system is a key priority for all of us. We have invited stakeholders to join us at a workshop in November to explore solutions to improve the capacity and capability of the system – including in terms of both people and finance. This will inform a consultation which we expect to launch in the new year. A letter was recently issued to planning schools in Scotland to underline the importance of the profession in supporting the delivery of our national priorities of equality, opportunity and community.
As you would expect, the National Strategy for Economic Transformation is a key priority for this Government. Planning has an important role as an enabler of economic development, and it is important that we make links with ongoing work to develop the potential of all of our places as part of our aim of growing a wellbeing economy. As well as statutory consultees including the economic agencies, we would recommend that planning authorities engage with their respective regional economic partnerships to inform plans and decision making on relevant areas. This is crucial for proposals for business and commercial development, but also for related planning land allocations and applications for other development types including housing, which can play an important role in supporting the development of the labour market in an area.
National planning case-handling
In terms of our day-to-day work, in the interest of sustainability we would like to remind authorities that sending hard copy documentation to Planning, Architecture and Regeneration Division for development plans or other planning casework is not necessary. Electronic submission is our preferred option in order to minimise printing and delivery costs for authorities, reduce any potential impact on the environment, and ensure safe storage of official documentation. Development plan casework should be submitted to us through the Development Plans Gateway at email@example.com. Notified Applications and any Orders can be submitted to our Planning Decisions team at firstname.lastname@example.org. For Notified Applications, Circular 3/2009 Notification of Planning Applications states that planning authorities should provide attachments or links to the relevant information for each case. We have updated our checklist of required information to help those submitting a notified application to us. The checklist is available on our website. Should you have any queries or wish to discuss options for document sharing particularly where there may be size restrictions, please get in touch. Please see our online advice on submitting applications to the Scottish Government Energy Consents Team and to the Directorate of Planning and Environmental Appeals.
Respect and collaboration
Planning has never been more important to Scotland’s success, and the potential of our places cannot be fully realised without the expertise and enthusiasm of a strong planning profession, now and in the future.
We know that planning authorities are under significant pressure and that this can lead to some frustrations, the effectiveness of our planning system depends on the co-operation and positive behaviours of everyone involved. Planning, by definition, generates different views and opinions, and healthy debate is to be expected. However, we are clear that planning authorities should not tolerate unacceptable behaviour including abuse or harassment of individual officers.
Our work will continue to be collaborative, based on mutual understanding and respect. We hope we can continue to depend on your input and co-operation to achieve this, in the interest of Scotland’s people and places.
With best wishes
Dr Fiona Simpson, Chief Planner
Joe FitzPatrick MSP, Minister for Local Government Empowerment and Planning
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