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National Planning Framework 4 - draft: consultation analysis

Independent analysis of the responses to our consultation on the draft fourth National Planning Framework (draft NPF4), which ran from 10 November 2021 to 31 March 2022.


Part 4 – Delivering Our Spatial Strategy

Delivering our strategy and realising our collective ambitions requires collaborative action from the public and private sectors and wider communities. Actions will range across different scales and include a mix of strategic and project investments. It will be important to focus implementation and monitoring on delivering strategic actions and key developments.

Question 54 – Do you agree with our proposed priorities for the delivery of the spatial strategy?

Question 55 – Do you have any other comments on the delivery of the spatial strategy?

Around 350 respondents made a comment at one or both of Questions 54 and 55. A single analysis of themes raised across these two questions is presented below.

General comments in support of the proposed priorities included that they represent a pragmatic approach to securing and prioritising sufficient resources to ensure delivery of the spatial strategy priorities and proposed national developments. However, it was also suggested that the proposed priorities are not clear, or that Part 4 is probably the weakest section of the draft NPF4. A connected concern was that it is short on detail and does not give confidence around moving forward with what is a very ambitious strategy.

It was suggested that there are a number of different components to effective delivery, not all of which are captured within the current draft NPF4. There was reference to: good practice delivery approaches; the consistent and rigorous translation of NPF4 policy to Regional Spatial Strategies and LDPs; policy alignment and delivery questions raised by the individual proposed policies; and ongoing delivery and oversight of NPF4.

A number of respondents commented that a delivery plan would have been helpful to support the draft NPF4. The importance of the delivery strategy was highlighted, including to provide confidence to all sectors involved in the built environment and to demonstrate that the relevant actions, mechanisms, and responsibilities are clear. There were also references to the need for clarity over: the timetable and milestones; resourcing; staff capacity; oversight; how policy tensions may be addressed; partnerships; cross-sectoral working; and the expectations of all parties in delivering the spatial strategy.

The absence of a delivery plan was described as disappointing, especially when local authorities are required to publish a delivery programme alongside their proposed LDPs. Associated comments included that without a proposed delivery plan or programme it is difficult to comment on the proposed priorities that have been set out and to understand:

  • The Scottish Government's role in delivery when most of the spatial strategy prescriptions are regionally and locally based.
  • The role that the LDP Regulations consultation plays in the delivery programme for NPF4.

There was a call for a detailed delivery programme to accompany the final NPF4, with some respondents noting that they would welcome the opportunity to be involved in its development. It was suggested that the development of the delivery programme would benefit from input from a range of stakeholders and that further thought should be given to how representation from the likes of business and transport bodies can sensibly be incorporated.

In terms of its content, there was a call for the interrelationships, synergies and resource alignment requirements at the national level to be articulated; this would provide a blueprint for LDP delivery programmes, signalling to local government what is expected and required to support the long-term spatial strategy for Scotland.

Joined-up, partnership approach

Respondents welcomed recognition of the broad range of partners, including development agencies, to be involved in the delivery of the spatial strategy, and again some went on to note that they looked forward to engaging constructively in the process.

In terms of a successful partnership approach comments included that planning authorities will play an essential role in delivering NPF4, and also that it is not just about planners, but all the essential internal and external inputs from other professionals. Groups referenced included other local authority services, central government departments, key agencies, the Infrastructure Delivery Group, the Scottish Futures Trust, Scottish Enterprise and investors and developers.

With specific reference to the role of the key agencies, it was suggested that they will have a critical enabling role to play in ensuring the successful delivery of many aspects of NPF4. It was noted that this would also extend to supporting the development of a full suite of NPF4-compliant LDPs as soon as possible. There was specific reference to maximising the opportunities presented through the digital planning programme, capacity building and supporting tools and guidance.

Other comments about working together to deliver NPF4 included that:

  • The pace and scale of change needed will require a culture change in how planning stakeholders work together.
  • Recognition of the need to work closely with marine planning authorities at the national and regional scale as these authorities are being rolled out, is welcome.

Aligning resources

It was agreed that a collaborative approach that aligns interests will play a central role in delivering the spatial strategy. This was seen as a crucial aspect of how a radical and ambitious strategy can be effectively delivered by the practitioners tasked with management and delivery. It was suggested that aligning resources will require clear committed leadership from the Scottish Government for national agencies to work with planning authorities, given that each authority will be working to different timescales.

However, there was a concern that the alignment of different policy frameworks and NPF4 is currently an area of weakness. Further comments included that there needs to be a focus on:

  • Alignment with the Programme for Government. The role of the National Investment Plan and the Islands Connectivity Plan should also be considered.
  • The hierarchy of national, regional and local policies and their interaction. It was noted that for many NPF4 policies there are a number of related government policies, and providing clarity and guidance on their role and relationship to NPF4 would be valuable.
  • How future policy developments will be captured in the spatial strategy and vice versa.
  • The alignment of different legislative frameworks.

In terms of key elements that will need to be considered when aligning resources, there was reference to capital and revenue resources, and to NPF4 needing to set out a clear Capital and Revenue Investment Programme. It was suggested that being clear on how the delivery programme will be resourced and enabled going forward will support both market confidence and the practical approaches to effective delivery that are needed. There were also references to the need for:

  • Clarity on the respective roles and funding streams available from central government, multi-agency, private sector, and partnership arrangements.
  • The delivery programme being phased and aligned with public sector expenditure plans.
  • Closer alignment of NPF4 to the Infrastructure Implementation Plan to facilitate funding certainty.
  • City Region Deals paving the way for a much-needed greater scale of investment.
  • Engagement with investors and developers to ensure that resources are not only effectively focused but also effectively phased.

Picking up on the theme of investing in planning services (also discussed further below), it was noted that success will depend on sufficient funding and support for planning authorities. More generally, it was noted that whilst alignment of resources is important, the scale of resources required to deliver the strategy receives little mention.

The need to support communities to engage effectively was also highlighted, with resources set aside by public and private sectors to provide support to local communities to engage in a meaningful way, through the application of suitable place tools and best practice community engagement processes.

Infrastructure first

Respondents often noted their support for the principle of infrastructure first, with associated comments including that it puts climate change and sustainable development at the centre of capital planning and investment decisions and seeks to ensure the most effective use of infrastructure as possible. Reflecting themes raised in the analysis for Policy 8 (Infrastructure first), it was thought that infrastructure first should be a Universal Policy, and that a definition of the approach and the types of infrastructure it covers is required.

It was suggested that the IIP provides a useful basis for defining and developing the approach to be set out in NPF4, and that there needs to be more explicit interlinkages to the IIP. However, there was a concern that the current IIP is not due for renewal for another year which may make it challenging to deliver many elements of NPF4. An associated suggestion was the publication of an annual National Infrastructure Assessment which, if integrated with NPF4's delivery and monitoring programme, could improve ongoing understanding of national infrastructure requirements and actions necessary to support delivery.

More generally, there was a call for greater detail on the delivery of the infrastructure first approach, including the proposed Infrastructure Levy set out in the Planning (Scotland) Act 2019. It was suggested that work on the introduction of an Infrastructure Levy is crucial and that the lack of clarity on funding needs to be addressed.

In terms of delivering the infrastructure first approach, it was suggested that there needs to be:

  • A robust structure for early stakeholder engagement. It was suggested that transparency and collaboration from all stakeholders at all stages will be important.
  • A clear financial strategy for front funding and cost recovery. It was suggested that very often the quantum of infrastructure funding required can only be provided by the Scottish Government and that the funding criteria for this needs to be set out.
  • Recognition of the role of LDP delivery programmes and also public sector investment mechanisms and funding to prime development which can be recovered through obligations and agreements with developers.
  • More information on how the approach will link with planning obligations, including to maintain the delivery of new housing.
  • Specific reference to delivery models, including approaches that will work in areas with lower land values.

There was a concern that if infrastructure first cannot be implemented effectively, it could become an obstacle to development, and that the lack of a central co-ordinating authority could be an issue. As in relation to Policy 8, there was a call for a new Scottish National Infrastructure Company to be established.

Delivery of national developments

It was noted that there are high expectations for successful outcomes from the delivery of the national developments and that, of necessity, this will involve positive collaboration between all the key partners within local and central government, key agencies, investors and developers. There was a concern, however, that a delivery programme for national developments appears to be somewhat of an afterthought and that this could bring the reality of delivering some of the projects into question.

In terms of collaboration, there was a concern that only a handful of the national developments reference STPR2 or City Region Growth Deals and that very few are mentioned in the IIP. It was suggested that this calls into question the reliability of the delivery strategy in the 'aligning resources' section which sets out the intent to primarily utilise these plans and programmes for delivery.

There was a call for the precise delivery mechanisms to be set out in the next version of NPF4. Reference was made to an agreed set of roles for the different stakeholders, along with funding, timescales and clear monitoring and updating procedures being put in place. A need to de-risk the national developments was also highlighted, and there was reference to setting out costs, phasing and public sector contributions to ensure public sector developers and investors buy in to the projects. In relation to funding commitments, it was suggested that if project-specific commitments cannot be made, then a commitment to pursuing innovative approaches, like the Community Wealth Fund, should be given.

In terms of overall approach, it was thought that a whole system, place-based approach to delivering the national developments will help ensure wider place benefits for local communities. There was reference to how the six spatial principles can be best reflected in their design and delivery. It was also suggested that NPF4 should:

  • Highlight the interconnections between national developments.
  • Cross-reference to both the spatial strategy and the policy handbook. The expectation was that this cross-referencing will make it easier for planning authorities and others to identify and articulate their role in delivering the national developments.
  • Set out any links to the action areas.
  • State any related expectations of Regional Spatial Strategies and LDPs. It was also suggested that Part 2 should state that national developments must be incorporated into all relevant LDPs, and each national development should clearly state which LDPs are relevant.

Other comments on delivery included that:

  • Community engagement must be a key element.
  • Early and ongoing collaboration with key agencies will help remove risks and identify opportunities for innovation.

From a planning resource perspective, it was noted that consideration of national developments will require input in terms of time and resources from planning authorities, but that they would not be in receipt of any portion of the planning fee as they would not be the determining authority. It was suggested that the consequence of this is likely to increase pressure on already stretched planning authorities.

Development plan policy and Regional Spatial Strategies

A specific suggestion was that including a coherent organisational chart which sets out the context, roles and interactive relationships between the key documents and strategies would be helpful.

Reflecting themes raised in the analysis for Part 1 of the draft NPF4, a number of respondents commented on the role of Regional Spatial Strategies and their relationship to the delivery of NPF4 and LDPs. A concern was that a lack of clarity around the relationship between NPF4 and Regional Spatial Strategies could risk the latter becoming meaningless. However, it was also suggested that work on the interim Regional Spatial Strategies has been helpful and constructive, and that ongoing work will continue to provide more clarity on respective roles and be able to set out a clear, functional and operational role for Regional Spatial Strategies, which is complementary to both NPF4 and LDPs.

Also in relation to Regional Spatial Strategies, it was noted that the Scottish Government has indicated that draft statutory guidance is to be published late in 2022. There was a call for this timeline to be brought forward to allow regional groupings to progress the development of their strategies as soon as practically possible, and to more closely align with the approval of NPF4.

City Region or Regional Growth Deals

Comments on the City Region Growth Deals included that, as a funding and governance model, they can manage investment and coordinate the delivery of development opportunities at a strategic scale. However, there was also a concern that referencing growth deals does not lead to their delivery, and that the draft NPF4 seems to be focusing on what is already committed, rather than providing a lever to allow its new vision to be achieved.

In relation to growth deals playing an important role in delivering NPF4 it was suggested that:

  • The relationship between Regional Growth Deals and development plans needs to be agreed, explicit and clearly understood. There was a call for NPF4 to state clearly that growth deals should reflect spatial strategies and emphasise the need for a reciprocal and iterative relationship between strategic development plans and growth deals over time.
  • It will need to be clearly articulated that growth deals must be aligned with spatial strategies given their different origins from UK and Scottish Governments respectively.

STPR2

In terms of STPR2's relationship to measures identified through Regional Spatial Strategies and the transport assessment part of LDPs, there was a concern that they will not be supported if they are not included in either STPR2 or future IIPs.

In relation to STPR2, there was a view that it is not as inclusive as it should be and that it will not play the role it should in supporting the delivery of draft NPF4. An associated view was that the infrastructure first policy could fall at the first hurdle for those parts of Scotland where the Scottish Government sees no strategic case for transport-related investment in its broadest sense.

Other comments included that the NPF4 delivery strategy needs to fully reflect the role that Scottish Government and Transport Scotland need to play in considering the implications and opportunities that the trunk road and rail networks have for ensuring quality of place and liveability in many communities.

Local Development Plans

General comments about LDPs included that their action programmes may provide an opportunity to support the effective implementation of NPF4 ambitions. It was suggested that it would be helpful to have some explanation as to how the various components of the LDP would interact with the content of NPF4.

It was acknowledged that recently published draft local development planning regulations and guidance has addressed this to some extent, but there was a concern that there is potential tension whether planning authorities will want to adopt NPF4 policies in full or adapt them for the local circumstances. There was a call for clarity about the extent to which planning authorities will be able to adapt policies. It was noted that this will also be relevant to how Regional Spatial Strategies are to align with NPF4.

In terms of the impact of NPF4 planning policies on LDP delivery, there was also a concern that most of the policies have a criterion outlining requirements for inclusion within LDPs, but that their inclusion as policy criteria could complicate the assessment of planning applications. It was suggested that the LDP requirements should be separated out in NPF4, as their inclusion could lead to potential challenge and issues with the delivery of the spatial strategy.

Many of the other comments addressed the delivery of land for housing, and included that:

  • The preparation of LDPs should have regard to the economic realities of housebuilding and housing markets. It was suggested that there is an opportunity for local authorities to take a more proactive role in infrastructure planning but this will require them to be resourced appropriately and be willing to draw on funds.
  • Policy 9 (Quality homes) must align with the LDP Regulations consultation and focus on remedies when a housing land pipeline is not being delivered. Tools such as Housing Land Audits and two-yearly delivery reviews will be essential as part of this evidence checking and must be undertaken transparently and consulted on properly.
  • There should be a policy basis for Scottish Ministers to require local authorities to address the under-delivery of an LDP, or an LDP being out of date. It was suggested that this would support the proposed NPF4 policy change in relation to the need for a longer-term housing perspective which states that 'future plans can promote immediate deliverability and viability'.

Local Place Plans

There was support for highlighting the importance of Local Place Plans and their role in identifying the needs and priorities of communities. There was also a concern, however, that the reference feels like an afterthought, despite their prominence in the Planning (Scotland) Act 2019.

It was suggested that with Planning Circular 1/2022: Local Place Plans having now been published, it would be helpful for this to be linked to NPF4. In terms of other aspects that should be covered, there was reference to the options available when communities have their ambitions frustrated and are not able to develop and improve their area as they would like.

Others were looking for clarity around how Local Place Plans relate to development plans and especially how much influence they will have on LDPs. It was noted that this is being taken forward under separate consultation arrangements, with some noting that they look forward to being involved in that process. In terms of specific issues that respondents wanted to see resolved, the following were highlighted:

  • How Local Place Plans will support delivery, rather than merely reflecting local opposition to development. It was suggested that there appears to be no scope to incentivise local groups preparing such plans to include an element of development within their area.
  • Circular 1/2022: Local Place Plans, needs to be amended to confirm that Local Place Plans sit outwith the development plan. It also needs to clarify exactly the weight a registered Local Place Plan can have upon LDP preparation.

It was suggested that, as further guidance on Local Place Plans continues to be developed, this should include a recommendation for developers to respond to ambitions set out therein. Other comments included that the importance of engagement with older people should be emphasised. It was noted that older people in Scotland represent a diverse demographic of our population and, as such, engagement must be a core theme running through the planning process. More generally, however, there was a concern that it will be a challenge to encourage as many different members of the community as possible to get involved in producing a Local Place Plan.

Planning obligations

General observations included that planning obligations could play a key role in placemaking and ensuring the delivery of community infrastructure. It was noted that there is reference to a review of the effectiveness of developer obligations, but also that work has already been undertaken and published (The Value, Incidence and Impact of Developer Contributions in Scotland, July 2021) and that the next step is to move forward.

In terms of moving forward, the Scottish Government was encouraged to ensure that any potential infrastructure levy supports the provision of vital community infrastructure, including open space, green infrastructure and sustainable drainage and is not used to backfill items such as under-provision of affordable housing.

There was reference to the current system of Community Infrastructure Levy in England, and to it being considered overly complex. There was a call for the Scottish approach to not be overly burdensome, with further comments including that:

  • Greater detail will be required to provide clarity for planning authorities, communities, and developers.
  • The critical issue with any levy is the amount of capital provided. This must be sufficient, target its original purpose and be fair.

An alternative view was that the legal requirements related to planning obligations are a barrier to delivering meaningful large-scale infrastructure, because:

  • It is difficult to establish that major new infrastructure is required to mitigate local development, and there is a prohibition on the pooling of financial contributions towards new large-scale infrastructure; and
  • In consequence, financial contributions are funnelled towards piecemeal local infrastructure rather than transformational new infrastructure, particularly, but not exclusively, new transport infrastructure.

Connected to this was the suggestion was that NPF4 makes no attempt to address this issue or align policy with changes proposed under the Planning Act (Scotland) 2019, including the infrastructure levy, or with other forthcoming legislative priorities including in respect of land value capture.

In terms of challenges that will need to be addressed, it was noted that:

  • Areas which experience lesser demand can be further hampered by low levy income.
  • There have been issues when trying to secure developer contributions to deliver healthcare facilities, and there is an opportunity through NPF4 to address the importance of healthcare-related infrastructure to deliver local, liveable, compact, healthy places.

It was also argued that the overlap and interface between existing planning obligations and the proposed Infrastructure Levy should be carefully considered and clearly articulated to avoid developers incurring additional costs through double charging.

Land Assembly

Comments on compulsory purchase powers included that they are an effective means of supporting a range of policy intents and outcomes, and could play a key role in freeing up land for housing and other priorities. There was also a view, however, that the compulsory purchase order process is not fit for purpose, although it was noted that reform of the compulsory purchase system is planned.

Further points included that there is no reference to compulsory sales orders and, more widely, that there is no detail on how a more positive and proactive approach to land assembly will be implemented. Moving forward, it was suggested that the increased use of compulsory purchase powers will rely on adequate skills and resourcing within local authorities and must be reinforced by clear and accessible funding initiatives.

It was also noted that there are avenues such as the Community Right to Buy for the Furtherance of Sustainable Development which provide a potential route for communities who wish to acquire land. It was suggested that this community right should be part of the delivery mechanism for local plans, as a legal backstop when other avenues have been frustrated.

Masterplan Consent Areas

It was suggested that Masterplan Consent Areas should be an effective way of providing the outline parameters and confidence to grasp investment and job creation opportunities if they are operationalised in a similar way to corresponding mechanisms, such as Local Development Orders, in other jurisdictions.

In terms of the approach, it was suggested that:

  • NPF4 should be clear that 'partners' should include landowners, whose interests should be protected in preparing, proposing and approving masterplan consent areas.
  • Any regulations developed must ensure that detailed schemes are developed in consultation with the relevant transport/road authority and that transport needs and connectivity requirements are fully identified and approved prior to the publication of any detailed scheme.

Further comments included that the approach could potentially cover industrial estates and land suitable for the zoning and development of waste management facilities. These should in turn be able to benefit from up-front planning permission. However, there was a concern that without a significant shift in culture within planning authorities, it is difficult to envisage a situation whereby detailed planning permission could be obtained for a waste management development by any means other than an application for full planning permission.

Investing in the planning service

A number of respondents commented on investing in the planning service, with acknowledgement of the need to invest welcomed. In terms of the scale of investment required, it was reported that the Planning (Scotland) Act 2019 has led to 49 new, unfunded duties and that there is a need to take account of the context of diminishing resources and increased workloads in planning authorities.

With specific reference to NPF4, it was noted that the draft introduces many elements that will require particular specialist skills and areas of expertise, and that resources will be required for reskilling and upskilling. There was also a view that the need for investment is exacerbated by the multidisciplinary requirements of NPF4 and the Planning (Scotland) Act 2019.

In terms of specific topics on which learning support and training may be required, there was reference to:

  • The impact of, and adaptation to, climate change.
  • Placemaking and landscaping.
  • Health and well-being requirements.

It was also noted that training requirements will extend to both local authority planners, elected members, and community council members.

It was suggested that the Scottish Government should look to work with professional bodies to provide training, skills and people to enhance a planning department's capabilities to support this ambitious agenda. It was also noted that delivery of NPF4 will require collaborative partnership working with a range of organisations and stakeholders who will assist with professional knowledge on needs, future provision, finance and provision of infrastructure.

In addition to requirements for reskilling and upskilling, it was also suggested that the following will be required:

  • Clarity on the respective roles and funding streams available from central and local government, multi-agency, private sector, and partnership arrangements.
  • External expertise for a range of specialist assessments.

It was also reported that experience suggests that the delivery of projects absorbs much more resource than the initial conceptual and planning stages of a project.

Given existing pressure on services, combined with the new duties arising from the Planning (Scotland) Act 2019 and NPF4, there was a concern that the only route to extra resourcing referenced is through an increase in planning fees. It was reported that recently published research from RTPI Scotland suggests this will not bring in adequate resources for the planning service to undertake its statutory duties and deliver NPF4.

There was a call for more fundamental reform of how planning authorities are resourced, including with more powers being devolved to local authorities to properly fund planning services. There was also a call for a comprehensive resource and skills strategy to be published as part of the delivery programme.

A very different perspective was that proposals to increase planning fees do little to address the root causes of inefficiencies and over-spends within some planning authorities, and that there also needs to be a focus on establishing standards of efficiency. It was also suggested that NPF4 should make provision to allow an applicant to appeal against fees which increase above recovery cost, and to allow those authorities which under-spend against expected cost recovery, to reduce planning fees accordingly.

Other suggestions included that:

  • Planning fees should be ring fenced by local authorities purely for resourcing the planning service.
  • Any increase in fees must be met with an associated improvement in the quality of service provided. There was specific reference to current planning authority resourcing acting as a significant constraint upon the rapid development of renewable energy infrastructure.

Monitoring

There was broad agreement that monitoring will be an essential part of the NPF process, and also that it will be a significant and challenging undertaking. Another general observation was that any monitoring programme should look very different to that carried out for NPF3, not least because it should include an approach to monitoring Part 3 of NPF4. In relation to NPF3, it was suggested that without very clear analysis of its success or otherwise, it is very difficult to consider the likelihood of success of NPF4.

Further comments included that while planning authorities will engage, their resources will be focused on LDP monitoring processes. It was suggested there should be a consistent methodology and that this will be particularly important if three levels of plan are to be monitored – NPF4, Regional Spatial Strategies and LDPs. In terms of overall responsibilities, it was suggested that monitoring of NPF4 should be led and undertaken by the Scottish Government as the coordinating authority.

For the purposes of monitoring whether the six outcomes are being met through the national planning policies, it was suggested that the Scottish Government will need to devise indicators for the application of these policies which can track change over time. It was also suggested that change needs to be attributable to planning decisions that are being made as a result of the planning policies.

There were also comments about the difficulty in measuring some of the concepts referred to in the draft NPF4, such as improvement in the 'quality' of places or whether they are more 'vibrant' or 'creative'. It was suggested that to be successful, effective monitoring needs to be based on clear targets set against an evidence report/base.

Other comments and suggestions included that the approach should prioritise measures of effectiveness and monitor impacts and outcomes of policy integral to the system. This could include broader metrics capturing progress on placemaking, environmental and socio-economic development and the alleviation of deprivation. There was also reference to: landscape quality standards; indicators to deliver positive health and wellbeing; environmental outcomes to address climate change action and biodiversity; and measures of inclusive growth and reduced inequalities. Other comments included that the approach:

  • Could be managed by setting short-, medium- and long-term targets.
  • Include regular reporting, perhaps on an annual basis in the form of a Delivery Programme and Annual Monitoring Report or similar. It was suggested that reporting should be to the Scottish Parliament.
  • Include a mechanism for the review and adjustment of any policy that is underperforming. In particular, there was a call for clarity on what circumstances might trigger the need for NPF4 to be amended.

With specific reference to infrastructure investment it was suggested that there need to be indicators covering: housing needs and demand; longer term healthcare provision; changes in air travel and tourism; and educational and utility requirements. It was also suggested that average distances travelled for shops, work and active travel would be a metric that will inform current and future IIPs.

It was suggested that the different monitoring roles of central and local government need to be aligned, and a consistent methodology adopted to provide a 'best fit' approach to avoid duplication of resources. Finally, there was a request for engagement and consultation on the development of a monitoring system and, more widely, on an expanded section on Monitoring and Delivery in the final NPF4.

Other themes to be covered in the delivery programme

Respondents also highlighted a number of themes that they wanted to see covered or reflected in the delivery programme developed. These included:

  • Local Outcome Improvement Plans. It was noted that these are a well-established and key feature driving the work of Community Planning Partnerships. It was considered surprising that they have not been referenced as playing a role in delivering the agenda set in NPF4, particularly when so many of the policies and outcomes require some form of partnership working.
  • Mediation. There was disappointment that NPF4 does not reference mediation as an aid to delivery through collaboration rather than conflict, as set out in the recent Planning Circular 2/2021: Guidance on the Promotion and Use of Mediation in the Scottish Planning System. It was suggested that NPF4 would offer an ideal opportunity for the Scottish Government to underline its real commitment to widening the use of mediation at a national level.
  • Community involvement and engagement. A collaborative approach involving communities was seen as key, and it was suggested that there needs to be more reference to how communities, particularly disadvantaged and marginalised communities, are supported to contribute at a strategic level. There was specific reference to exploring the introduction of public interest panels.

Other strategies, plans or statements

Respondents also referenced a range of other strategies, plans or statements that they wanted to be considered, either in developing the delivery programme or more generally across NPF4. These included:

  • The Digital Planning Strategy. There was a call for clear consideration of how this can support the implementation of NPF4, and it was reported that RTPI Scotland's research on behalf of the Scottish Government sets out the economic and societal benefits arising from digital transformation.
  • Water Resilient Places Policy Framework 2021. It was suggested that the management of our water system and water environment, in the face of climate change, will be a key challenge for the delivery of NPF4, and that its delivery framework should incorporate the Water Resilient Places recommendations.
  • The Land Use Strategy and the Land Rights and Responsibilities Statement. It was suggested that NPF4 provides a spatial strategy that delivers on the Land Use Strategy and that embedding the Scottish Government's Land Rights and Responsibility Statement in NPF4 would provide the parameters for 'managing land use in the long-term public interest.'
  • Scottish Building Standards and associated regulation. It was suggested that the delivery of NPF4 will be facilitated by aligning with these statutory obligations and legislative requirements.

It was also noted that a number of other methodologies, plans, and guidance will need to be updated to support planners in the delivery of NPF4. There was reference to:

  • Scotland's National Marine Plan (2015).
  • Designing Streets (2010).
  • Creating Places (2013).
  • Development Planning and Management Transport Appraisal Guidance (2011).
  • Town Centre and Retailing Methodologies (2007)
  • Historic Environment Scotland Managing Change Guidance Notes.

Next steps for NPF4

In addition to comments on the development of, and consultation on, the delivery programme there were other references to the next steps required to deliver NPF4. They included that:

  • Policies will need to be backed up with further guidance on their interpretation and implementation. It was suggested that NPF4 should set out topic areas which need such further guidance and interpretation, and identify who is responsible for providing it.
  • Where guidance exists, it should be signposted in the policy. It is possible such guidance could be delivered through a refreshed set of planning advice notes, but the guidance would have to have the requisite status and weight in decision-making.

It was also suggested that as the Scottish Government moves towards approval of NPF4, arrangements to cover the transition between the previous legal framework and the Planning (Scotland) Act 2019 will be crucial. There was a call for clear guidance on:

  • How NPF4 will be introduced to the planning system and how it will interact with live planning applications.
  • As per S13 of the Planning (Scotland) Act 2019, the status of NPF4 in the event of 'any incompatibility between a provision of the National Planning Framework and a provision of a local development plan'. It was suggested that clarity will be critical for both development planning and development management functions.

Finally, and as referenced at various other questions, there was a call for a new national agency/delivery vehicle to be established. It was suggested that this approach could help bridge the gap between the Scottish Government's vision and already stretched local authority resources. Further comments included that:

  • A delivery agency should support, rather than displace, regions and local authorities to deliver complex projects and interventions.
  • The precise scope and purpose of such an agency requires further consultation.
  • This is not a start-from-scratch project, as Scotland has many of the resources and assets needed to do this, but existing expertise is dispersed across different silos and levels of government.

It was also suggested that the general concept of a national team of people with the skills and experience to oversee major infrastructure, energy, digital, housing, and capital programmes, enjoys broad-based support among those involved in planning for and delivering homes and places in Scotland.

Contact

Email: scotplan@gov.scot

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