Cleaner Air for Scotland strategy: independent review
Conclusions and recommendations from the independent review of the Cleaner Air for Scotland strategy.
8. Placemaking, Planning and Local Government
8.1 The Placemaking Working Group prepared headline observations for this review. The group advocated the view presented in CAFS and endorsed by the Steering Group that good quality Placemaking can and will help to deliver improvements in air quality. It was also acknowledged that these were not quick fixes and that collaborative working was required between all communities of interest.
8.2 The locus of local authority planners, the structure and multiple functions of local government and the challenges faced in engaging in this review both shaped and constrained aspects of our findings. Early limited access to senior decision makers led to useful dialogue with local authority colleagues in individual authorities and in the Convention of Scottish Local Authorities (CoSLA) and the Society of Local Authority Chief Executives (SOLACE). Our experience of engagement in this review suggests that air pollution is not currently a high priority for local government and it must move up the agenda and become more of a priority for the future. The working group made it clear, and the Steering Group agreed, that land-use planning, careful and integrated development implementation and public engagement issues lie at the heart of delivering a progressive framework for tackling air pollution. Planning affects how we live, work, shop, play and move now and will do so in the future. It must shape and support the delivery of a clean, healthy and safe environment for all. A number of related and complementary recommendations are also presented in the transport, emissions and health sections above.
8.3 There is a long history of spatial planning and design in Scotland and 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, behavioural change and nature-based solutions. It means working collaboratively across professions and communities to identify the best place-based solution for the issues that we face.
8.4 Taking a long-view, it is evident that many of the challenges we face in delivering air pollution improvements, especially in our towns and cities, result from the inertia and frictions of past economic geography, providing us with an inheritance of built environments and road and pavement layouts, dynamics, infrastructure and substructures and adjacencies. Much of that also shows the dominance over the last 120 years of the car, lorry and bus and the internal combustion engine driving them. There is even evidence of the role of draught horse and first generation tram in some locations. The cumulative impacts of these modes and telecoms, electricity, gas, water and other infrastructure interventions is also frequently a constraint and a disruptor as well as a service deliverer. These various inheritances can to a degree be adapted and improved but, especially if we wish to address our heritage as well as costs, and the impacts of disruption, constraints abound. Only with wholly new build do we have the opportunity more comprehensively to address improvements by designing them in. Unless effectively future-proofed, even these may prove short-lived successes.
8.5 Section 7 in CAFS set out some of the significance and dimensions of placemaking, essentially the way we plan, design and manage our towns and cities. The role of greenspaces was clearly identified in and around new developments as resources, as buffers and spaces for recreation, active mobility and nature. It was seen as imperative that new developments be designed to better manage vehicles in our towns and cities, generating less traffic, linking to bus, walking and cycling routes and wherever possible prioritising active travel over vehicles. Clearly we have opportunities to get this more right in all new developments but large challenges remain when it comes to adapting existing places to contemporary and future needs and priorities. If we get placemaking right, we can tackle air pollution, create better, more sustainable places and contribute to better, healthier lives and higher amenity and improved conditions for work, life and play. This in turn makes locations more attractive for business too.
8.6 In CAFS, arguably, the main deliverables connecting environment, transport emissions and place were the modelling of air quality for the four main cities, and (although not itself a deliverable of CAFS) the Programme for Government (PfG) commitment to LEZs. This review has concluded that a further focus on placemaking is still, and urgently, necessary. The national and international policy context to the recommendations that follow can be found in Annex 8, with further detail in the placemaking Working Group’s report.
Creating Places, the Place Standard and the Place Principle
8.7 Creating Places is the Scottish Government’s policy statement on architecture and place, published in 2013. It contains a commitment to develop the Place Standard assessment tool, which will be the hallmark of well-designed places. The purpose of the Place Standard is to maximise the potential of the physical and social environment to support health, wellbeing and a high quality of life. In order to achieve this, it provides a framework for:
- Evaluation and improvement of new and existing places;
- Structured conversations through which communities, the public sector, private sector and third sector work together to deliver high quality places;
- Consistency across Scotland in the delivery of high quality, sustainable places that promote community wellbeing, and more positive environmental impacts;
- Maximization of the contribution of place to reducing health inequalities; and
- Consideration of social aspects of place alongside physical.
8.8 As part of the original Placemaking workstream for CAFS, the use of the Place Standard tool to initiate conversations around air quality was piloted in Glasgow, Edinburgh and Crieff. The pilot was led by Planning Aid Scotland (PAS) and a full report of the findings is available. An air quality technical version of the Place Standard tool was created by shifting the main focus to “improving air quality”. The prompt questions that sit under each of the tool’s headline questions were adjusted to bring air quality and health to the fore. The intention was to enable better conversations between communities of interest that would lead to the identification of solutions that went beyond the normal environmental health or transport solutions. The pilot recommended that the Place Standard was a good tool for starting conversations about air quality and it showed how thinking about the issue in terms of ‘place’ can result in a more holistic conversation. The review of the Place Standard, which is currently ongoing, will take on board the recommendation in the report.
8.9 In April 2019 the Scottish Government and CoSLA agreed to adopt the Place Principle to help overcome organisational and sectoral boundaries, to encourage better collaboration and community involvement, and improve the impact of combined energy, resources and investment in Scotland's regions, cities, towns, and neighbourhoods. This provides a good basis around which to frame the placemaking aspirations of the revised air quality strategy for Scotland.
8.10 Some of the recommendations and suggested deliverables emanating from the Glasgow Connectivity Commission and the Horizon 2020 (H2020) Connecting Nature project provide inspiration for the way forward to identify actions that are place based; that can improve air quality and shift the focus from traditional transport solutions. There may be merit in all of Scotland’s cities and larger towns looking at a similar connectivity and integrated place based planning approach, factoring air pollution management into their approaches.
Evidence Gaps and Priorities for action
8.11 Placemaking actions as well as others described above are fundamental to delivery of LEZs in the four big cities by the end of 2020. We appear to know enough, subject to delivery commitments to take these forward urgently and effectively. Focusing on these LEZs is therefore a clear and achievable priority. Given the intended benefits and the legal and policy dimensions, they must come at the top of the recommendation list. The second NTS is also clearly a framework for identification of priority deliverables.
8.12 From a placemaking perspective, other supporting dimensions also come into play. Areas of multiple deprivation, where transport poverty adds to existing disadvantage, identifiable in SIMD data; community engagement generally; mobility planning for all city and wider Scotland, including rural, island and remote users; refinements to development planning to support placemaking that address air pollution and mobility objectives – active and sustainable option “design-in” as well as actions to address emerging pollution sources such as woodburning stoves, etc. These all require policy and practice guidance refinement or development and narratives for leaders, staff and the community. Some of this will require establishment of baseline knowledge in order to target effective interventions and it is in some ways surprising how poor the knowledge appears to be of the air pollution issues in some areas.
8.13 There are also increasing examples of good and less effective placemaking effort, with calls (and responses) for design standards and guidance to improve placemaking approaches. For example, the Improvement Service produced Place-based Approaches to Joint Planning, Resourcing and Delivery: An overview of current practice in Scotland. Whilst not a systematic digest of good and bad examples, which would be very useful to have, it is an identifiable part of what we should in future assemble to guide better practice.
8.14 Future policy and practice guidance for projects in planning processes and facing assessment could also consider the current discussion on revisions to Health Impact Assessment (HIA) guidelines. For example, Worcestershire Council developed a toolkit taking on aspects of equalities assessment and the advocacy of its use in pre-master-planning work. Paralleling Strategic Environmental Assessment (SEA) in some respects, this could ensure or at least encourage the consideration of health and environment quality for infrastructure, transport and use planning and design work, especially in cities.
8.15 There is also continuing creation of guidance at the national and local level relevant to planning for better air quality, such as in Perth. Whilst place and economy are well flagged in some recent policy, and a link between public health and public place is also sometimes cited, there are also examples where air quality and planning are not yet seen as fundamentally and causally connected in policy making.
8.16 During this review, members have considered a range of anecdotal examples of developments. A systematic assessment would clearly strengthen our impressions but we have seen new developments emerge, since the CAFS strategy was published, that do not have bus routes or improved traffic management or any street or path provision for active travel and connection to existing – or proposals for new - public transport options. There are also examples of new developments with clear priority for more car parking, not even including significant bike, shelter, solar covers or e-power (charging) facilities. To have gained planning consent, it is assumed that these developments are consistent with development plans and policies. This suggests that these plans and policies need to be the urgent target of change to help deliver pollution and health objectives as well as development ones.
8.17 Where developments were approved some time ago and are only now being built, there should be a need and trigger to revise these plans to take account of national policy as well as local air quality/LEZ status and other contemporary strategic priorities as well as some consideration of future-proofing design standards. Some additional placemaking perspectives can be found in Appendix 8.
8.18 The achievement of clean air will be much easier if planning policy and approaches to placemaking are more holistic and integrated, both nationally and within local authorities. Policies also need to be reflected in actual planning decisions. They need to reflect better how we live, what we value and how we approach mobility, health and environmental quality as well as the utility and quality of our living, work and recreational spaces in future. This requires the active integration of planning, transport, environment, health and economic policies at policy making and implementation stages. This appears, despite some good examples, to be some way off.
8.19 The Placemaking Working Group’s recommendations focused on further research and developmental effort to increase awareness of the pressures and impacts of air pollution amongst planners, local authorities and other stakeholders, and how these could be mitigated and reframed in future by placemaking approaches. These recommendations are somewhat less mature than others in this report and a core observation is that a deeper, multi-disciplinary and delivery-focused approach is urgently needed. It is also noteworthy that local government colleagues, in a response to the Infrastructure Commission for Scotland, made a number of connected observations, with which this review would agree, amongst which were:
- the need for infrastructure skills and experience to be engaged in the work;
- a longer term planning time horizon, beyond 30 years;
- digital and smart technology focus;
- priority for maintenance and renewal of key existing rather than new infrastructure (transport, buildings and utilities);
- an appropriate and sustainable funding model;
- the need for a zero carbon focus and steps to adapt to new energy models;
- plans for removal of redundant infrastructure;
- proper fit with development planning;
- better use of planning tools;
- integration across transport modes;
- a constructive approach to rurality and connectedness;
- a strategy for international connectedness;
- enhanced focus on and investment in resilience;
- fit with health strategies and integration of these and active strategies across LA boundaries;
- tackling skills and demography issues in the sector;
- public safety priorities better addressed; and
- a more robust governance approach.
P1. Overarching emphasis on Placemaking
Urgent consideration by the Scottish Government and local government, involving all relevant functions, of how to achieve a pragmatic and integrated strategy for placemaking in policy-making and implementation generally. This must address the question of how placemaking works in practice, identify and acknowledge its role and drive Scotland-wide implementation. Tackling rural and urban needs, population growth targets, active and improved mobility generally and improved public health as well as environmental outcomes requires a more visibly interconnected and effective strategy. How therefore in this case does the Place Principle align with CAFS and deliver future improvements? This should also engage different professions and promote increased partnership working, identify actions on air quality that are placemaking based and embrace the outcomes from the test of the pilot Place Standard for air quality.
P2. Integration across Local Government
We urge local government to look at its own functions and consider how to ensure better recognition and integration of the different disciplines and inter-connected policy and delivery areas where stronger alignment and better engagement would more effectively and efficiently deliver air pollution reduction actions and benefits. This would include assessing legal drivers and policies, national, regional and neighbour “fit”, design capability, strategic and development planning and building control functions as well as environmental and public health, economic development, transport planning and service operation, environmental monitoring, function skills and training, etc. The existing linkages between policy areas and the role of National Planning Framework (NPF), NTS, Place Principle and the individual authorities’ priorities need to be seen in the round.
P3. Local Authority Air Quality Performance Specifics and Knowledge Exchange
A report on current air quality policy effort in local government should be prepared. This should address how many councils have air quality policies within their Development Plans or other statutory documents, how many City Deals have air quality objectives and initiatives and what are they, do they align with and impact on regional policies and Scottish outcomes and what has been the impact of pilot air quality training for planners and should this be rolled out to other partners and the community. It would also be very useful to have case study examples of successful approaches and actions and where interventions have and haven’t worked.
Additionally, it would be useful to have and share successful initiatives tackling air pollution issues across Scotland, from AQMAs, for example, and in relation to nature based solutions. Approaches to mobility behaviour motivations as well as any cost-benefit assessments of interventions would be very useful for future policy development and learning. This latter might benefit from Scottish Government and SEPA inputs.
P4. Local Government Delivery, Governance, Performance and Communications
An overarching plan for how local government engages, delivers, measures progress and gains credit for delivering change on air pollution issues is needed. It is clear that local government has several key delivery roles in relation to both placemaking and tackling air pollution. Successful delivery will be easier with a clearer understanding and statement of the services involved and the services we need as well as the behaviours we wish to influence and change. It is also clear that local government faces a range of pressures around competing demands and limited resources. A delivery plan would help manage delivery and expectations. A communications strategy, setting out what will be delivered, how and where would engage the public and increase outcome ownership.
Placemaking and air pollution in the broad Local Government context.
8.20 Looking specifically at local government, there are emerging observations relating to placemaking that are required to ensure air pollution strategies can be effectively developed and delivered. These relate to functional connection, alignment and integration, and specifically to how planning actually works, the various policies to be implemented, delivering LEZs, tackling existing and continuing AQMA challenges and ensuring data collection, monitoring, reporting and regulatory functions are discharged and coherent in deployment, operation and impact. Aspects of achieving this relate to leadership, systems, skills, resources and governance and this will be pursued later in this report, but some overarching recommendations are made below:
LG1. Realising effective Placemaking in practice
Much of which relates to a higher degree of coherence in the land use planning system in strategic and development planning terms combined with aligned development management/control processes that deliver national, strategic and development plan policies effectively on the ground. Policy needs to be better and regulatory roles need to fit with those. Commitments to, and processes to achieve, integration will be needed.
The four first round LEZs need to follow legal and policy timetables and be in place and delivering within 4 years. Visible commitments to this and evidenced delivery will be required. Where planning and bus management effort is required, this needs to move as quickly as possible. And for business as well as the citizen, Scotland-wide coherence in the systems implemented will be needed. Some of this connects directly to LG3.
LG3. Local Air Quality Management
Some sectoral, organisational and environmental media issues come together under the umbrella of local government LAQM powers and roles. Where AQMAs have been declared, these need to have active plans that deliver the intended outcomes within a reasonable timetable. Some have existed for a considerable time without improvement. When done they need to be revoked. If not delivered, powers of intervention by SEPA/SG can and should be applied. Also issues of permitted development and domestic combustion and public health, etc., as well as identified increasing pressure from wood burning stoves, for example, or previously approved developments that have not yet been implemented but where no public transport or active travel provision was made, highlight specific policies that may require to be addressed for local air quality. This of course then relates back to LG1.
LG4. Robust monitoring and reporting
A review of air quality monitoring may be needed to ensure that we are consistently gathering meaningful data in a uniform and appropriate way to meet current EU and Scottish/UK requirements as well as being future-proof in both a Brexit context and in relation to such future Scottish Government environment and climate strategy as may apply. All monitoring of the pollutants we consider important needs to be done at the right places in the right way at the right time. We then need both to use these data for reporting and modelling work for LEZ and AQMA planning and delivery as well as for compliance and public information purposes.
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