A public consultation on the Local Living and 20 Minute Neighbourhood: Draft Planning Guidance ran between 27 April and 20 July 2023. The 10 consultation questions aimed to gather a broad range of public and stakeholder views on each element of the guidance. In total, 615 responses were received from 509 individuals and 106 organisations.
Organisations viewed the draft guidance positively, almost always rating it as somewhat or very helpful; however, many caveated their support with requests for additional information. Many described the guidance as providing a good overview to understand local living and commented on its usefulness in setting out the broad characteristics of local living. Other prevalent themes included that the guidance was clear and helpful, that it set out the Scottish context and direction of travel well, and that there was a welcome focus on community engagement and the emphasis on the need for collaborative working.
However, there were repeated calls from individuals and organisations for more detail or examples to expand on the guidance and to help it be used in practice. Many respondents, mostly individuals, commented on how the guidance was presented, suggesting it should be clearer and more concise, better structured and written in plain English.
Another prevalent theme was for the guidance to allow greater flexibility when applying the concept, particularly in rural and semi-rural areas. While many welcomed the guidance’s acknowledgement of differences by location, this was often as a prelude to requesting further flexibility. Reasons given for the need for more flexibility related to the lack of nearby facilities in large parts of Scotland and that local communities were best placed to determine approaches based on their local population needs and access to facilities.
A recurring theme, raised by individuals and organisations, was ensuring the necessary infrastructure is in place to support local living. Many argued that the lack of infrastructure meant implementing the approach would be challenging or unrealistic. Respondents described the need for improved bus, rail and ferry transport, more investment in public services such as hospitals, the need for better digital connectivity, and the perceived lack of services in residential development areas.
Many commented on the need to consider the resources required to implement the policy - such as the investment in infrastructure and other facilities - at a time of pressure on local authority budgets, cuts to local services and amidst a cost of living crisis. The potential additional workload for local authority planning departments was frequently cited as a concern, particularly around implementing the structured approach outlined in part 3 of the guidance. Specifically, several respondents disagreed with the assertion in the BRIA that the guidance “places no additional requirements on planning authorities”.
References to NPF4 and other policies in the guidance, and consideration of how local living could impact other policy areas, were welcomed. However, many called for greater alignment between the guidance and other relevant policies. Comments ranged from suggesting other strategies or frameworks which could be cited, to calls to clarify specific points where respondents felt there were discrepancies between different policy positions.
Part 1 – Local living
Many organisations called for a clearer definition of 20 minute neighbourhoods. There was a feeling that the ’20 minute’ idea was too prescriptive, did not aid flexibility or reflect lived experiences. There were also calls for the guidance to address misconceptions about local living and 20 minute neighbourhoods. Several felt the guidance should contain more evidence regarding benefits and outcomes associated with the local living approach, demonstrating how benefits and positive outcomes can be achieved in communities.
Some felt that the intended audience for the guidance was unclear. Some also highlighted that the concept required effective and improved multi-agency working and felt the guidance was too focused on local authority planning considerations. In particular, strengthening involvement by the business sector was recommended.
Part 2 – What local living looks like
While almost all organisations agreed in the closed question that the Local Living Framework diagram is helpful, views expressed in comments were mixed. Many commented that the framework was not straightforward to understand, for example, that it appeared to show each component as equivalent in status or was too high level, cluttered with icons and caused confusion. Requests were made for more specificity to allow it to be used, including providing more illustrations, examples or case studies of how it can be applied to differing types of communities or populations.
Conversely, however, the next most prevalent theme was many positive comments about the framework diagram. Comments described it as helpful, comprehensive, a useful visualisation and enabled an easy understanding of the main features of local living. Organisations commonly indicated it would be useful for operationalising the guidance at local level, for instance, by helping identify gaps or opportunities, facilitating community and stakeholder engagement and providing a basis for assessment of local living.
Aligning the guidance with the Place Standard Tool was positively received by several. However, several others felt the Tool and Local Living Framework were too similar or required more distinction. Some felt the guidance and the Local Living Framework should determine which themes or considerations were essential for local living, or how aspects should be prioritised, as this better reflected reality and assisted planning decisions.
The most prevalent theme in relation to the categories and key considerations in part 2 was many suggestions about other aspects to include in the Local Living Framework across all of the five overarching themes. The next most frequently raised comments related to the five themes in the Local Living Framework: Movement, Space, Resources, Civic and Stewardship.
Part 3 – Ways to support local living and 20 minute neighbourhoods
The most common theme in response to Q4 was agreement with the structured approach presented in part 3. Many respondents either agreed, or supported the approach while also noting areas for improvement. Some noted that they particularly liked the flexible and iterative nature of the structured approach, which would help take into account the changing characteristics of living spaces and the diversity of different places in Scotland.
Potential improvements to part 3 were suggested by many. Some organisations requested more detail on how the approach would work in practice such as who should be involved and their roles and responsibilities, expected timescales, details of the positive outcomes that could be expected to arise from using the approach, and more examples of how the approach could, or has been, applied.
Many agreed with the importance of gathering and using data to understand the context of a place, and to create baseline measures which could be monitored over time. Several called for the guidance to set out a preferred methodology for data collection, or provide more information on gathering, analysing, and presenting data, which some noted would help with consistency. Many agreed that using qualitative data is a good way to understand how people live in communities, though others asked for more information about how to collect, analyse and use qualitative data. Some suggested that guidance was needed to ensure qualitative data is up-to-date and representative of a community. Several respondents supported the use of quantitative data, or mentioned the importance of using detailed, high-quality data that is comprehensible to all.
Agreement with the emphasis on engaging with communities and listening and responding to public feedback was another prevalent theme. Several respondents suggested that while they approved of the structured approach, they wanted to ensure that the process started with communities and avoided a top-down approach, with some individuals expressing concern that community opinions may not be taken seriously. Many asked for more guidance about how to collaborate with communities, while others noted that there are existing models for collaboration and engagement but called for them to be more explicitly referenced in the guidance. Several stressed the importance of including third sector and private stakeholders in both the collaborate, plan and design and the implement and review phases of the approach. Churches, schools, shops, wider industrial companies, supermarkets, and healthcare facilities were some examples of stakeholders respondents were interested in involving.
There were repeated calls for more information on the implementation and review section. A few individuals and organisations described this section of the guidance as lighter than other sections or lacking practical detail. This included greater clarity over who would be responsible for review and how accountability would be applied, what frequency and timescales were considered most appropriate for a review, and how any learnings or good practice would be identified and shared. However, several organisations welcomed the inclusion of guidance on how development managers and planning authorities should judge applications against Policy 15 of NPF4.
Part 4 – Case studies
Among organisations who answered Q8, 88% indicated that the case studies were a useful and appropriate range of examples. The case studies were well-received and were frequently described as helpful, interesting and useful. Many felt the case studies were comprehensive and wide-ranging, appreciating the variety of different approaches, locations, community sizes and geographies they covered. However, many others did not consider the case studies to be a useful tool for communicating information about local living, with some describing them as vague, generic and one-dimensional. Several called for more detail to be included.
A number of improvements to the case studies were suggested. For example, a few respondents said they would have preferred the case studies to follow a more uniform structure, and others felt an introductory contextual paragraph explaining how and why each case study was chosen would have been a useful addition. Respondents commonly welcomed the ‘lessons learned’ section in the Stewarton case study and called for this to be replicated in the other case studies.
Impact assessment update report
Several felt the EQIA did not sufficiently address the needs of those with protected characteristics, particularly those with disabilities or older people. More broadly, several respondents highlighted the importance of considering the potential impacts of implementing local living. Some reflected that, given the complex nature of inequalities, it should not be assumed that the guidance would improve outcomes for those experiencing disadvantage. Respondents called for greater emphasis on how those with protected characteristics should be involved in decision-making, how they navigate local spaces, and how they access relevant facilities and services.
Individuals’ perceptions of local living and 20 minute neighbourhoods
The vast majority of the 510 individuals who responded to the consultation expressed negative views towards the principle of local living and 20 minute neighbourhoods. However, many individuals’ comments stemmed either from a concern that the policies will be implemented or imposed to restrict people from travelling more than 20 minutes from their homes, or from a misunderstanding that all services people need should be accessible within 20 minutes.
By far the most prevalent themes raised by this group of respondents related to their perception of the anti-democratic nature of local living and 20 minute neighbourhoods. Comments fell into three strands: how the policy restricts movement, general comments, and the perception that it has been decided to implement the policy without consultation.
Many individuals repeatedly expressed negative views across the consultation. These comments were often brief, but typically expressed a view that local living and 20 minute neighbourhoods are a bad idea and neither wanted nor needed in Scotland. As a result, they called for the plans to be stopped or cancelled, or highlighted that they would continue to strongly oppose the implementation of the policy. The impractical nature of the proposals was also repeatedly raised by many individuals.
Many individuals and stakeholders with detailed knowledge took part in the consultation, sharing their views on the Draft Planning Guidance which will be used to assist the delivery of local living and 20 minute neighbourhoods in Scotland. Overall, the key message was that there is support for the draft guidance among stakeholders and likely users of the document, with a desire to see a future version which includes more detail and examples. The findings from this analysis will be used by the Scottish Government to revise and finalise the guidance.
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