Cleaner Air for Scotland 2: consultation

Consultation on a draft new air quality strategy for Scotland, taking into account the recommendations arising from the independent review of the Cleaner Air for Scotland strategy.

3. Placemaking

49. There is a long history of spatial planning and design in Scotland. Early leadership, from those such as Sir Patrick Geddes, the Edinburgh based founding father of modern urban planning, has been recognised for a century.  In modern terminology we would probably refer to this as placemaking, with a focus on behavioural change and nature-based solutions.  Placemaking means working collaboratively across professions and communities to identify the best place based solutions for the issues that we face.

50. It is evident that many of the challenges we face in delivering air pollution improvements, especially in our towns and cities, result from multiple historical policies and decisions, providing us with an inheritance of built environments, road layouts and infrastructure.  Over the last 120 years the approach has been particularly shaped around our relationship with road transport, and in particular private cars.

51. Road transport will remain vital to the functioning of modern transport but a society built around car access and ownership is inherently unequal and can create constraints within our built fabric.  However we do have experience to help us build new places which can be more equal in how space is used, and can also use that experience in improving our existing places.  The key is ensuring that such approaches become embedded and normalised across central and local government, the private sector and for us as individuals within society.

52. It is also necessary to recognise the role of open space in the way we plan, design and manage our urban landscapes - as resources, as buffers and spaces for recreation, active mobility and nature.  The Planning Act (Scotland) 2019[40] makes it a requirement for planning authorities to prepare and publish an open space strategy covering their policies and proposals as to the development, maintenance and use of green infrastructure in their district, including open spaces and green networks. We are currently working to bring forward the secondary legislation on Open Space Strategies and Play Sufficiency Assessments.

53. The European Commission has highlighted the role that nature-based solutions can play in placemaking[41].  There is growing recognition and awareness that nature can help provide viable solutions that use and deploy the properties of natural ecosystems and the services that they provide in a smart, 'engineered' way.  These nature-based solutions provide sustainable, cost-effective, multi-purpose and flexible alternatives for various objectives.  Working with nature, rather than against it, can further pave the way towards a more resource efficient, competitive and greener economy.  It can also help to create new jobs and economic growth, through the manufacture and delivery of new products and services, which enhance the natural capital rather than deplete it.

54. Nature-based solutions aim to help societies address a variety of environmental, social and economic challenges in sustainable ways.  They are actions which are inspired by, supported by or copied from nature.  Some involve using and enhancing existing natural solutions to challenges, while others are exploring more novel solutions, for example mimicking how non-human organisms and communities cope with environmental extremes.  Nature-based solutions use the features and complex system processes of nature, such as its ability to store carbon and regulate water flow, in order to achieve desired outcomes, such as reduced disaster risk, improved human well-being and socially inclusive green growth.  Maintaining and enhancing natural capital, therefore, is of crucial importance, as it forms the basis for implementing solutions.  These nature-based solutions ideally are energy and resource-efficient, and resilient to change, but to be successful they must be adapted to local conditions.

55. If we get placemaking right, we can tackle air pollution, create better, more sustainable places, contribute to improved physical and mental health and provide high quality spaces for work, life and play. This in turn makes locations more attractive for business, too.  The report produced by the CAFS review placemaking working group[42] provides further background and context.

National Planning Framework 4

56. The Scottish Government is reviewing its national planning policies (National Planning Framework 3 (NPF3)[43] and Scottish Planning Policy (SPP)[44]) with a view to bringing them together into a single policy document (NPF4).  This provides the opportunity to change planning policies including with the aim of improving air quality outcomes from new development and planned changes in the built and natural environment.  Indeed, the Planning (Scotland) Act 2019 requires that the revised National Planning Framework has regard to any national strategy in respect of the improvement of air quality prepared by Scottish Ministers.  

57. The planning system as a whole works towards delivering the vision shared by the NPF and SPP by promoting good quality places through policy and regulation.  In this respect it also helps to link air quality to health, economic, and environmental outcomes.  NPF is the Scottish Government’s spatial strategy for Scotland’s long term development, identifying where opportunities and challenges exist.  SPP sets out national thematic planning policies to be taken forward through development plan policy and decisions on planning applications.  The development plan is the starting point for decision making on planning applications – decisions must be made in accordance with the plan unless material considerations indicate otherwise. 

58. Planning policy and regulation is implemented mainly through setting out a development plan that is then used as the basis of decision making on planning applications.  Local development plans are prepared by planning authorities across Scotland and decisions on planning applications are made in the first instance by those planning authorities.

59. NPF4 will be the fourth version of the long term spatial plan for Scotland that sets out where development and infrastructure is needed to support sustainable and inclusive growth.  NPF4 will look towards 2050, guiding spatial development, setting out our national policies, designating national developments and reflecting regional spatial priorities.  NPF4 will also for the first time incorporate SPP and will take on enhanced status as part of the statutory development plan.  This means the policies within NPF4 should be capable of day to day use by planning authorities in determining planning applications.  The spatial aspect of NPF4 has the capability of directing planning authorities to key challenges and opportunities in their areas.  

60. The Planning (Scotland) Act 2019 set out six outcomes that the National Planning framework should contribute towards, including improving the health and wellbeing of the people of Scotland, improving equality and meeting greenhouse gas emission reduction targets, that relate directly to the aims of CAFS 2.  

61. At present air quality is referenced in SPP in the Principal Policy on Sustainability.  This forms a potential material consideration in plan making and determining planning applications.  SPP does not currently set out what attributes of land allocations or individual development proposals lead to improved air quality, although does note for some development types that air quality is a matter to be considered.  SPP Annex A on Town Centre Health Checks and Strategies states that town centre strategies should identify how green infrastructure can enhance air quality as well as a range of other impacts.  The Planning for Zero Waste policy is clear that consideration should be given to buffer zones between sensitive receptors and dwellings and some waste management facilities.  SPP highlights that sensitive receptors are aspects of the environment that are likely to be significantly affected by a development including population and air.

62. The Scottish Government published in 2019 research on the ‘Adoption of Scottish Planning Policy in Local Development Plans’[45].  This research brings together details on all local development plan policies that are implementing SPP.  The research found that there is very little direction in SPP as to how development plans and development management can ensure planning development does not have a detrimental impact on local air quality.  Although air quality impacts may be considered in Environmental Impact Assessment and Strategic Environmental Assessment, the former does not apply to all developments and the latter applies only to plans, programmes and strategies.

63. Early engagement on the preparation of NPF4 was undertaken in 2020.  We are anticipating a draft NPF4 to be laid before the Scottish Parliament in autumn 2021, which will be accompanied by public consultation.  This provides an opportunity to review planning policy on air quality and provide a spatial planning policy response to CAFS 2.   The final NPF4 is anticipated to be published in 2022.

The Place Principle

64. In April 2019 the Scottish Government and CoSLA agreed to adopt the Place Principle[46] to help overcome organisational and sectoral boundaries, encourage better collaboration and community involvement, and improve the impact of combined energy, resources and investment in Scotland's regions, cities, towns, and neighbourhoods.  It promotes a shared understanding of place, to support inclusive and sustainable outcome improvement and the need to take a more collaborative approach to a place’s services and assets to achieve better outcomes for people and communities.  The Place Principle brings ideas about investments, resources and assets under one roof and is based on an understanding that decision making and delivery that is informed by the people who live and work locally is key to the economic, social, cultural and environmental success of places. The principle encourages and enables local flexibility to respond to issues and circumstances in different places.

The Place Standard

65. The Place Standard tool[47] was produced by the Scottish Government, Public Health Scotland[48], Architecture and Design Scotland and Glasgow City Council and launched in December 2015. The Place Standard tool supports individuals, communities and public, private and third sector organisations to think about both the physical elements and the social aspects of a place together in a structured way by asking a series of questions based on the evidence about which aspects of place are important to health and wellbeing, This provides a framework for evaluation, for assessing the strengths and weaknesses and for prioritising areas for action to improve new and existing places.  The Place Standard tool is designed to support a place-based approach and the delivery of high quality, sustainable places that promote community wellbeing and more positive environmental impacts, maximising the potential of the physical and social environment to support health, wellbeing and a high quality of life and reduce health inequalities.

66. A revised version of the Place Standard tool will be launched in 2020 to address gaps in the original tool identified in a changing climate, including enhancements to better enable place-based conversations to address climate change and improve environmental sustainability. The integrated approach offered by the Place Standard tool to understanding the physical, social and economic aspects of a place provides a holistic means of assessing and taking action on issues such as travel and transport, green infrastructure, place design and layout, that can deliver co-benefits such as air quality improvements. A ‘Design’ version aimed at designers (architects, planners), developers and clients is also being created to support the design process to deliver healthier places, including the delivery of air quality improvement co-benefits. 

67. Furthermore, an air quality ‘technical’ version of the Place Standard tool has also been piloted. This provided additional prompts and guidance to support a stronger focus on air quality within a holistic assessment of a place, which can support specific action to address air quality concerns.


We will:

  • Ensure that NPF4 has regard to CAFS 2 in its preparation.
  • Continue to promote the use and role of the Place Standard tool(s) in place-based approaches, enabling delivery of air quality improvement as a co-benefit of delivering high quality sustainable places that support health & wellbeing and reduce health inequalities.
  • Work with local authorities who wish to develop a targeted approach where appropriate for utilising the Place Standard tool with an air quality focus.
  • Undertake a review of nature based and green infrastructure interventions which can benefit air quality, using the outcomes to develop a database of potential solutions.
  • Work with local authorities to assess how effectively air quality is embedded in plans, policies, City Deals and other initiatives, and more generally in cross departmental working, identifying and addressing evidence, skills, awareness and operational gaps.

Questions on placemaking

4. Do you agree with the package of actions put forward in the placemaking chapter?

A) Yes

B) No

C) Neither agree nor disagree

Additional comments in support of your answer 

5. Do you have any suggestions on the role of place-based approaches in delivering targeted air quality improvements?



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