COVID-19 and development planning
The restrictions and wider impacts arising from the ongoing COVID-19 situation are raising practical and wider challenges for the current planning system. We know that planning authorities are experiencing significant pressures and appreciate that they will inevitably be finding it difficult to discharge some of their responsibilities at the present time. We also understand that there may be more limited capacity in the development sector to engage with planning authorities and that this could be compounded by current uncertainty in the wider market and financial environment.
We are therefore writing to provide informal advice on development planning in the period ahead of the National Planning Framework 4 (NPF4) and new system of local development plans emerging. This aims to continue a plan-led system that is well placed to enable good quality development that meets Scotland’s needs, as we begin to recover from the current restrictions.
Planning reform timescales
Recognising the competing pressures on individuals and organisations at this time, and the need to continue to collaborate to inform the content of NPF4, we have extended the timeline for this work and now expect to lay the draft in the Scottish Parliament in September 2021. Ahead of this, we expect to publish an interim position statement on NPF4 this autumn and use this to inform further early engagement at that stage. Subject to Parliamentary timetabling, we anticipate this resulting in the Scottish Ministers adopting NPF4 in spring / summer of 2022.
The preparation of development planning regulations and guidance associated with the Planning (Scotland) Act 2019 will also work to this anticipated timescale. In light of the new context, we are considering our approach to ensure this work can still be undertaken in a collaborative way over the coming months. Further information on the work programmes will be published in due course. In the meantime Scottish Government officials would be happy to discuss any issues arising for specific development plans on a case by case basis.
Consultation and engagement in local development plans
In view of the current exceptional circumstances, we have issued interim guidance on consultation in local development planning to assist authorities and their stakeholders.
We recognise that many people and organisations may have limited scope to engage in development planning at this time, and would therefore ask all planning authorities to consider allowing longer timescales and more flexible arrangements for engagement in development planning in the coming months. Whilst the system must remain open for business, and development plans will no doubt play a vital role in supporting our future economic recovery, the Scottish Ministers would not wish to see plans being progressed through the system without sufficient or inclusive engagement. Opportunities for stakeholders to feed in changes to their context will ensure we have plans that are relevant.
This may mean that in the months ahead more local development plans could remain in place for a longer period of time than usual. Scottish Ministers have discretionary powers under the 1997 Act (as amended) to require planning authorities to prepare a report setting out why a local development plan has not been reviewed within appropriate timescales. In view of the current circumstances we can reassure authorities that Ministers are not minded to require such reports at this time.
We are also aware that the COVID-19 situation will be making it difficult for planning authorities and the development sector to undertake annual housing land audits. These audits provide important evidence to inform judgements as to whether or not an authority has a 5 year effective land supply in place. We would expect planning authorities to take a pragmatic approach to this work, recognising and fully adhering to the Covid-19 guidance, and accepting the limitations arising from social distancing and restrictions to site visits.
We hope that all interests in planning will continue to work together effectively to support development and the contribution of the construction sector to our future recovery. Planning authorities will benefit from strong communication and co-operation with their stakeholders. The Scottish Government’s ongoing liaison with the Construction Leadership Forum is providing invaluable insights on the challenges facing the construction industry as it progresses to a restart on non-essential sites in line with the RouteMap published on 21 May 2020. We look forward to further positive discussions to help inform any additional action that ensures planning in Scotland remains relevant, responsive and agile in the months ahead.
We recognise and appreciate the positive response planning authorities have made to adapt service delivery and to provide assistance in challenging times. We have an opportunity to learn from that and use it to our advantage in continuing to pursue planning reform. As part of this, our work on National Planning Framework 4 will continue to progress over the coming year. We would encourage all stakeholders to continue to play a positive and active role in this work.
For the longer term, there are lessons emerging from the pandemic about the way we live our lives and the quality of our places, which could usefully inform development planning for the future. More time will be needed to reflect on this, but we look forward to more creative thinking, innovation and debate on the implications for Scottish planning policy and practice in the months ahead.
We trust this is helpful and would encourage you to contact officials in Planning and Architecture Division if there are further issues for the planning system arising from the current situation which should be brought to our attention.
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