Local Living and 20 Minute Neighbourhood - draft planning guidance: consultation analysis

Appendix A: Other policies and policy-related issues to consider

This Appendix contains a list of policies that respondents felt could be usefully included in the guidance, as well as recommendations for linkages between policies or the potential for conflict between them. The categories reflect the main policy areas on which views were given. Each point was raised by one or a very small number of respondents.

Planning

• Greater alignment with the Place Principle and other policy aims would support a more whole-systems approach and broaden the concept beyond physical planning.
• The guidance should better reflect different sized places, including urban, town and rural contexts, using expanded graphics explained in a more structured way. This could assist planners' understanding and application of the ‘where relevant’ clause in Policy 15.
• It should be explained that Local Place Plans (LPPs) and Local Development Plans (LDPs), alongside NPF4, provide the basis for place-based and people-centred planning decisions created in line with the Place Principle. Local Place Plans will have a key delivery role and should be further emphasised.
• Closer links between the guidance and the Local Development Planning Guidance should be made. For instance, explaining what stage in the plan-making process information should be collected, for example, to inform the Evidence Report. A step-by-step guide, like that in the Local Development Planning Guidance, would be helpful in the context of this guidance.
• The need to prepare a Regional Spatial Strategy as part of an LDP should be mentioned, signposting to Annex C from NPF4 – Spatial Planning Priorities.
• Mentions of re-use could be further strengthened by clearer alignment to Infrastructure Investment Plan recommendations on existing housing, specifically ‘enhancing and maintaining existing assets ahead of new build’.
• Statutory Local Heat and Energy Efficiency Strategies (LHEES) should be included. The mention of ‘retrofitting and repurposing existing buildings’ and also ‘building social capital and creating resilient and diverse places’ should tie into relevant LHEES delivery plans at the local level.
• Consider how the approach can be linked to the Scottish Government’s Digital Transformation in Planning programme.
• Other policies that could be referred to more substantially or that could be reviewed to align with the living local model included: Infrastructure First, the NPF4 Sustainable Transport, Design, Quality and Place section and the UN Sustainable Development Goals.
• The National Strategy for Economic Transformation could be used as a way of asking how the 20 minute notion supports the wellbeing economy.
• Increase the focus on assets in line with the Infrastructure Investment Plan Investment Hierarchy, considering how services interact to provide a joined-up approach, including co-location of services.
• Potential for the policy to conflict with ‘town centre first’ principles if shops and services are sited elsewhere to meet the 20 minute neighbourhood approach.
• Aspects of economic policy may conflict; for instance, recently announced Investment Zones aim to attract high-value jobs but are unlikely to be aligned to 20 minute neighbourhoods.
• Conflict may occur between the policy and planning decisions that favour brownfield development over greenfield, which could hamper private-public partnerships to deliver local living. A solution may be to acknowledge the value of public space and parkland and create new public spaces in brownfield land in urban areas.
• More cohesive strategies between planning, housing standards and net-zero guidance would assist developers in meeting building requirements.
• Housing, particularly affordable housing, should be more centrally located throughout the guidance, e.g. emphasising the Scottish Government’s quality and affordability commitments in the Housing to 2040 strategy. The right to live safely in a home could be emphasised.

Comments on NPF4

• The guidance should be expanded to discuss the six overarching spatial principles and how they link to local living considerations.
• The reference to the six qualities of a successful place within the Place Context section would sit better in the policy section and links made between NPF4 Policy 14 and Policy 15.
• Relevant guidance on placemaking should be more prominently featured in the main body of the guidance, in addition to signposting to Appendix D of NPF4.
• A link could be made to Policy 27 of NPF4 that states drive-through fast food outlets will only be permitted where specifically supported within the relevant LDP.
• The NPF4 Policy Outcomes section could be strengthened by including considerations of how any neighbourhood work must be informed by communities

Transport

• Public transport should be more centrally located and aligned with the intent of NPF4, which covers using sustainable transport options and references mobility hubs and shared transport.
• The guidance could improve alignment between the outcomes presented in Figure 3 and those in the National Transport Strategy 2, 4 priorities.
• The role of Regional Transport Partnerships and their statutory requirements to publish a regional transport strategy could be added.
• Make more explicit links to the Active Travel Framework, for example, links to Cycling by Design, Designing Streets and the National Walking Strategy.
• The new flexible planning rules to relax outdoor seating rules for pubs and restaurants to allow seating to be placed on pavements could create accessibility challenges for those with mobility needs, at odds with the movement section.
• The role of appropriate and effective transport appraisals undertaken in line with relevant transport appraisal guidance should be strengthened. In line with NPF4, proposals should be informed by evidence of the area’s transport infrastructure capacity and an appraisal of the spatial strategy of the transport network.

Health and wider public services

• More detail on Public Service Reform would be welcomed, with better linkages between public services and the proposals and expanding on the paragraph to ensure all parties have an upfront understanding of obligations and responsibilities.
• The guidance could consider “health in all policies”, focusing on key sectors in local living such as planning, transport, housing, education and sports. “Health in all policies” is a cross-sectoral public policy approach that systematically considers the health implications of decisions.
• The alignment between active everyday journeys, local living and public health benefits should be explicitly referenced alongside other policies and strategies.
• Licensing and other planning contexts that can influence access to unhealthy commodities, e.g. alcohol and gambling, should be aligned.
• Culture could be incorporated into the outcomes by revising the wording: ‘Places that are planned to improve local living in a way that reflects local circumstances, culture and historic importance’ and ‘New and existing communities are planned together with homes and the key local infrastructure including schools, community centres, cultural venues, local shops, greenspaces, health and social care, digital and sustainable transport links.’
• ‘Quality of life’ could be considered alongside ‘decreasing health inequalities’ linked to the themes of people, liveable places, and social.

Community and community empowerment

• Include relevant policies, e.g., the Community Empowerment (Scotland) Act 2015 Parts 1,2,10, the Equality Act 2010, the National Standards for Community Engagement, Fairer Scotland, Principles for Positive Partnerships, National Youthwork Strategy, Adult Learning Strategy and Scotland’s Volunteering Plan.
• Scottish Government guidance ‘Planning with People’ (2023) sets out expectations and standards for health and social services consultations with communities that could be applied here.
• The link between other policies and community wealth building could be stronger. North Ayrshire Council launched Scotland’s first Community Wealth Building Strategy in May 2020.
• Local empowerment could be strengthened in this part by mentioning the participation (or people) ‘pillar’ of the 2010 Christie Commission Report, Volunteering Action Plan, Local Governance review and community empowerment agenda.

Environment

• Links to Scottish Biodiversity Strategy to 2045, Scotland’s Forestry Strategy 2019-2029, Water Resilient Places Policy Framework, forthcoming Flood Resilience Strategy and Cleaner Air for Scotland 2 strategy.
• Clarify how the guidance aligns with strategies on climate mitigation, carbon reduction, and a Just Transition and more explicit links to the UN Sustainable Development Goals and exemplar locations (cf. Ramboll Climate Exchange report.)