Business & Regulatory Impact Assessment (BRIA)
Title of Proposal
Guidance on Local living and 20 Minute Neighbourhoods
Purpose and Intended Effect
The fourth National Planning Framework (NPF4), adopted by the Scottish Ministers on 13th February, contains policy on local living and 20 minute neighbourhoods. NPF4 forms part of the statutory development plan.
The concept of local living and 20 minute neighbourhoods is intended to support places where people can meet the majority of their daily needs within a reasonable distance of their home, preferably through active travel modes or by public transport.
The draft local living and 20 minute neighbourhood guidance aims to support the implementation of the existing policy framework within NPF4. The preparation of NPF4 involved extensive consultation and parliamentary scrutiny as well as the development of a comprehensive Integrated Impact assessment. A full BRIA was undertaken for NPF4 and this covered the policy framework, including content on Local living and 20 minute neighbourhoods (Policy 15).
This impact assessment report update has been produced to support the public consultation on the draft guidance and will be finalised prior to publication of the final guidance document
This update report relates only to draft guidance, and not to new policy content. The draft guidance does not introduce any additional policy requirements or duties and is simply intended to provide additional detail and clarification of existing policy in order to support effective and efficient implementation.
The finalised NPF4 BRIA considered that overall, costs involved in delivering NPF4 are outweighed by the strong justification for proceeding with the intended approach, in particular the contributions to national outcomes.
The draft guidance on local living and 20 minute neighbourhoods places no additional burden on planning authorities, communities or business and will have no material impact on the assessment and conclusions of the NPF4 BRIA.
Draft guidance to support NPF4 Policy 15, Local Living and 20 minute neighbourhoods, has been developed to support interpretation and implementation of NPF4. The draft guidance sets out details on the benefits, key characteristics, and delivery approaches to support local living and 20 minute neighbourhoods.
Rationale for Government intervention
NPF4 Policy 15, Local Living and 20 minute neighbourhoods, is a new policy and although it is aligned with previous policy on placemaking, there is a role for guidance to provide more details to support implementation of the policy.
- Within Government
The NPF4 IIA sets out the wide ranging approach to government consultation in preparation of NPF4. Officials from Scottish Government's Planning, Architecture and Regeneration Division have discussed the draft document with officials in Climate Change, Transport Scotland, Rural Communities, Land Use Strategy, Housing, Retail policy, and Health.
- Public Consultation
Call for Ideas
Between January and April 2020 the Scottish Government held an open call for ideas to hear views on what Scotland should be like in 2050 and the changes needed to get there. Some of the main themes that emerged from the call for ideas included NPF4 as:
- an opportunity to refocus planning on place, by applying approaches including the 20 minute neighbourhood concept, town centre renewal and a stronger emphasis on reusing vacant and derelict land and buildings to achieve multiple benefits for health and wellbeing, as well as climate change.
A Position Statement was published in November 2020. This reflected on the information received through the call for ideas engagement programme. The Position Statement confirmed expectations for NPF4, which included development that reduces the need to travel, in line with the concept of 20 minute neighbourhoods.
Draft NPF4 was laid in the Scottish Parliament on 10 November 2021 for Parliamentary scrutiny. Alongside Parliament's consideration of the draft NPF4, the Scottish Government invited comments from all stakeholders. The public consultation was launched on 10 November 2021 and closed on 31 March 2022
One of the six principles of the spatial strategy set out in the draft NPF4 was:
- Local living. We will create networks of 20 minute neighbourhoods to support local liveability, reduce the need to travel unsustainably, promote and facilitate walking and cycling, improve access to services, decentralise energy networks and build local circular economies.
As part of the development of NPF4, background information on the BRIA and a questionnaire was sent to around 33 key stakeholders from across Scotland, including key business and industry representatives. Additionally, the RTPI held a range of consultation events on behalf of the Scottish Government including a business roundtable. Further meetings took place during the consultation period with key groups where business and regulatory issues were discussed. This included meeting with the housing industry's representative body as well as rural economy and communities representatives.
This section looks at each of the measures and the options explored.
Option 1: Do nothing
The National Planning Framework 4 Delivery Programme sets out the approach for implementing NPF4 and includes key actions to be taken forward over the short and medium term. The delivery programme contains a commitment to developing guidance on local living and 20 minute neighbourhoods with a consultation to be launched following laying of NPF4 and finalisation of guidance in 2023. Failure to deliver this guidance will impact negatively on stakeholder expectations and compromise the effective implementation of NPF4.
Option 2: Preferred option - Developing guidance
Under this option guidance will support the effective implementation of the policy intent and outcomes on local living and 20 minute neighbourhoods within NPF4. This will strengthen the ability for policy to be correctly interpreted and applied and is an important element in delivering the ambitions of NPF4 and the associated impacts assessed as part of the IIA.
Sectors and groups affected
NPF4 is a strategic document and its policies are likely to impact on all business sectors across Scotland who are likely, in the future, to engage with the planning system through the submission of a planning application or commenting on applications that affect them. It may also influence businesses' decision-making on what they do with their land.
Planning authorities are affected in that they are required to take account of NPF4 in preparing their local development plans. Previously, those plans would include planning policies specific to the development plan area. However, the intention is to reduce the need for local policies by introducing national planning policies that apply across Scotland, while still leaving scope for local variation in policies where appropriate.
NPF4 will impact on communities as it will influence the future development of the places where people live. In addition, those community bodies which are preparing Local Place Plans will be required to have regard to the NPF in preparing such plans.
Further information on the sectors and groups affected by NPF4 policy is contained within the full NPF4 BRIA.
Costs and Benefits
Option 1 : Do nothing
This would require planning authorities and communities to interpret the policy framework for local living and 20 minute neighbourhoods with the high level information contained in NPF4. Although this may provide some local flexibility, it would lack consistency in application. There is an expectation through the published delivery programme that guidance will support NPF4 policy implementation.
Option 2: Preferred option - Developing guidance
Developing guidance will support consistency in application of the policy across Scotland. This will allow businesses to have increased certainty on the expectations on them in aligning with policy, helping to deliver efficient processes and a level playing field across planning authority areas. Guidance will support planning authorities to undertake consistent, thorough and robust processes in plan development and also support consistency in decision-making processes.
The full BRIA for NPF4 involved a Competition Assessment, a Consumer Assessment, Test run of business forms, a Digital Impact Test and a Legal Aid Impact Test. None of these assessments indicated adverse impacts.
- Intra-UK Trade - The guidance is not likely to have an impact on intra- UK trade.
- EU Alignment - This guidance is unlikely to impact on the Scottish government's policy to maintain alignment with the EU.
Summary and recommendation
The draft Local Living and 20 minute neighbourhoods guidance aims to support the implementation of the existing policy framework within NPF4. The preparation of NPF4 involved extensive consultation and parliamentary scrutiny as well as the development of a comprehensive Integrated Impact assessment, including a full BRIA.
The finalised BRIA considered that overall, costs involved in delivering NPF4 are outweighed by the strong justification for proceeding with the intended approach, in particular the contributions to national outcomes.
The draft guidance on local living and 20 minute neighbourhoods places no additional burden on planning authorities, communities or business and will have no material impact on the assessment and conclusions of the full BRIA.
Declaration and Publication
Partial Business and Regulatory Impact Assessment
I have read the Business and Regulatory Impact Assessment and I am satisfied that, given the available evidence, it represents a reasonable view of the likely costs, benefits and impact of the leading options. I am satisfied that business impact has been assessed with the support of businesses in Scotland.
Tom Arthur MSP
Minister for Public Finance, Planning and Community Wealth
Scottish Government Contact point: firstname.lastname@example.org
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