2. Overarching views
While the consultation questions focused on individual parts of the draft planning guidance, some themes were evident in response to multiple questions. To avoid repetition, this chapter outlines these prevalent overarching themes. We highlight both positive views on the guidance and areas where improvements were repeatedly noted.
Positive feedback on the guidance
As will be evident in subsequent chapters, organisations typically viewed the draft guidance positively. Many caveated their support with requests for additional information but nevertheless rated the guidance as somewhat or very helpful.
When explaining the reasons for their support, many organisations 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. Another prevalent theme among organisations was that the guidance was clear and helpful. It was felt to be presented in a simple, concise way, which would be useful when implementing approaches locally.
Many others felt that it set out the Scottish context and direction of travel well. There was an appreciation of the recognition that flexibility is needed when applying the concepts depending on the location and context of different places. Some found the consideration given in the guidance to rural and semi-rural settings particularly valuable.
“Part 1 is helpful in setting the overall context and notifies intent to public, private and community sector bodies of what is expected for future development proposals set within a strong place-making context.” - Scottish Futures Trust
“The guidance supports understanding of how local living could look within the context of Scotland in both urban and rural contexts, which is helpful for strategic decision making and also staff working operationally.” - NHS Lanarkshire Health Improvement Department
“We welcome the guidance, which is clearly well-intentioned and has been progressed quickly following the adoption of NPF4. It is a positive step forward.” – Hallam Land Management
“The information set out in [Part 3] is very helpful. To some extent, it could be too simplistic, trying to implement the same approach to all different communities across Scotland, but by this being a flexible approach, it offers that potential of adaptability to each scenario and reality.” – Dumfries and Galloway Council
Many organisational respondents supported the direction of the policy and felt it aligned with and complemented existing place-based approaches, aligned to their organisational goals and was in keeping with existing work being undertaken across Scotland. The inclusion of relevant policies and clear links to the Place Principle were welcomed. Respondents felt the approach taken in the guidance gave good, useful context which was aided by the inclusion of the ‘Policy Context’ section.
The importance of effective community empowerment and collaborative working
Many welcomed the focus on community engagement and the emphasis on the need for collaborative working. The clear way the guidance was written was considered helpful in enabling meaningful conversations about placemaking with a range of relevant stakeholders. However, there were frequent calls to embed this within the guidance further and emphasise its importance. As these calls often related to specific aspects of the guidance, they are noted at the most relevant points in subsequent chapters.
“The SURF network warmly welcomes the increased focus on places and communities across multiple public policy themes. The provision of an accessible, well-written guide, designed for a generalist, is particularly useful for colleagues operating in environments that have been historically distant from community regeneration.” – SURF, Scotland’s Regeneration Forum
Support for 20 minute neighbourhoods and local living
Several organisations and a few individuals expressed support for the concept and agreed it could produce useful outcomes. One researcher who had conducted research on 20 minute neighbourhoods in England felt it resonated with the research findings that it could provide a useful planning model to meet a broad range of everyday needs locally. Others felt the concept could promote the shift towards prevention, encourage physical and mental wellbeing, and improve local economies and environmental benefits.
“[We] welcome the guidance and supports the principles it seeks to apply.” – Sustrans
“I think this is one of the best initiatives I have seen. I am an advocate but It’s overall premise is admiral. And the objectives are both essential and exciting.” – Individual
“We agree that living well locally, if driven by genuine community-level engagement, could be a useful tool to bring together the many strands that need to work to make thriving, liveable and resilient communities.” – Scottish Islands Federation
“Part 1 is helpful as the pandemic stressed the need for more localised access to facilities and amenities as a means to encourage physical and mental health as well as making more efficient use of infrastructure and resources. Healthy, sustainable places and the opportunity to create conditions required to support economic growth, whilst at the same time contributing to the climate change agenda and protection of the environment, are crucial matters.” – East Renfrewshire Council
Areas for improvement
Providing more detail and examples
A prevalent overarching theme across the consultation, raised by both individuals and organisations, was a call for more information, detail or examples to expand on the guidance and to help it be used in practice. The draft version was felt to be largely aspirational and did not adequately address the diverse nature of neighbourhoods nor how to overcome challenges and obstacles in placemaking initiatives.
While many individuals requested more detail, few elaborated on what additional information was required. Specific points raised by those who did, as well as requests from organisations, have been included in this report where they are most relevant.
A small number of individuals repeatedly called for more balance in the guidance, as they felt that it was too focused on the positive benefits of the approach and did not cover potential negative aspects. However, they did not provide more detail or explanation of what those negative aspects were.
Accessibility and use of plain English
Many respondents, mostly individuals, commented on how the guidance was presented. Views included the need to make the guidance clearer and more concise, better structured and written in Plain English. It was argued that the guidance could be shorter, remove repetition, and the language simplified with jargon avoided. Several queried the terminology used and felt more explanation could be given of terms such as ‘quality of public realm’, ‘climate resilience’, ‘liveability’ and ‘supporting wellbeing creation’. There was also a call for more consistent and careful alignment of the language and terms used when discussing benefits. For example, Part 1 refers at different points to ‘people, place and planet’; ‘Sustainable Places’, ‘Liveable Places’, and ‘Productive Places’; and ‘environmental, social and economic circumstances’.
The guidance was seen to be targeted at professionals, as it appeared to assume an understanding of terms such as place context and spatial strategies. One felt that extensive references to other documents and policies were overwhelming. A few highlighted repetitions, especially when discussing policies, with one preferring these to be condensed and focused on a list of outcomes required to deliver the benefits of local living.
Some diagrams were seen as unnecessary or not relating well to the text, e.g. one stated that the illustrations on pages 16,17 and 18 were not helpful. A few, including RNIB Scotland (Royal National Institute of Blind People), highlighted concerns about whether the guidance and diagrams such as the Local Living Framework are accessible to those with visual impairments. They noted alternative text and descriptions would help accessibility amongst those using screen-reading software.
More generally, many other individuals frequently criticised the clarity of the guidance in broad terms. For example, it was described as ‘nonsense’, ‘meaningless’, ‘complicated’, ‘confusing’, using ‘flowery language’ and ‘lacking in substance’. However, these individuals did not explain why they felt this way, or suggest how the guidance could be improved.
Further flexibility for both urban and rural areas
Another prevalent theme across the consultation was the need for the guidance to allow greater flexibility when applying the concept, particularly in rural and semi-rural areas. While many respondents, particularly local authorities and organisations involved in land management, planning, development or architecture, welcomed the acknowledgement of differences by location already in the guidance, this was often as a prelude to requesting further flexibility.
Many argued that the concept was less likely to work in rural and semi-rural areas, but a few also highlighted issues for urban areas. It was felt the guidance was urban-centric and did not adequately reflect the realities in many communities, with some calling for separate guidance for those in rural areas. It was also highlighted that most of Scotland is rural or semi-rural, with calls for more flexibility to accommodate all areas, including towns.
“However, many places fall somewhere in between. We would suggest further consideration given to the diverse types of settlements we have in Scotland. This could perhaps align with the Scottish Government Urban Rural Classification which categorises settlements based on population and accessibility (e.g., Large Urban Area, Accessible Small Towns, Remote Small Towns).” – Geddes Consulting
“The setting feels largely urban, with island and rural places confined to a few add-ons…. If the shift in policy is intended to be Scotland-wide, we would like to see guidance developed that is as relevant to island and rural places as it is for urban.” - Scottish Islands Federation
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. There were also calls for greater recognition of links between places and that there will likely always be a need for individuals to travel to nearby towns or cities to access specific services. It was also noted that areas required sufficient people living within them to justify providing amenities, considered especially problematic in rural areas prone to population decline.
“[Part 1 of the guidance] fails to recognise that development in rural areas will be required as many urban/semi-urban areas are reaching capacity, and this may have to be at a high density to achieve many of the important contributors to local living mentioned in this paragraph. For instance, how can better public transport be implemented in rural areas without a sufficient population to use such services and justify a business model in a more isolated area?” – Angus Council
“There should be… a cross-reference to the ‘Town Centre First’ policy within NPF4, which puts the health of town and city centres at the heart of decision-making. A city such as Aberdeen can't surrender its economy entirely into 20 minute neighbourhoods - city centres play an important role as a result of being a destination in their own right with an economy built around this.” – Aberdeen City Council
Greater recognition of the infrastructure needed to support local living
A recurring theme across the consultation, raised by individuals and organisations, was ensuring that the necessary infrastructure is in place to support the local living concept. Many raised this concern in broad terms, arguing that the lack of infrastructure meant implementing the approach would be challenging or even unrealistic. There was a sense that the quality of infrastructure and provision of local facilities had been declining, and there is a need to invest in this area. Another concern was the lived reality of changes in services due to a lack of funding or changing consumer habits.
“We need to be realistic and practical. We need to work together. We need to recognise that the facilities that make up 20 minute neighbourhoods do not exist in every town or village in Scotland (and where they do, their quality varies significantly). These public and commercial facilities have declined over 50 years plus of under-investment, economic challenges, and changes in lifestyles.” – Hallam Land Management
Additionally, many community-based housing associations are grappling with conflicting contexts: 20 minute neighbourhood guidance encourages local living and promotes easy access to services, but many services are becoming increasingly centralised and moving away from neighbourhood branches. This reportedly includes bodies like police, banks, and health services that are trending away from local offices and high street fronts and towards online or centralised locations. While housing associations and co-operatives largely welcome 20 MN principles, there are difficulties in delivering them in practice, absent appropriate funding, support, and public service reform. The guidance on collaborative practice is somewhat helpful in principle, but delivery partners like [Registered Social Landlords] are facing practical challenges in implementing local living on the ground due to wider challenges that are not addressed under this guidance.” – Scottish Federation of Housing Associations (SFHA)
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. There were calls to clarify what infrastructure was needed to achieve successful local living.
“Outlining the infrastructure required to support the delivery of 20 minute neighbourhoods and, in particular, the role of smart local energy neighbourhoods and mobility hubs would help illustrate how delivering the ambition ('benefits') of 20 minute neighbourhoods requires integrated energy and transport infrastructure at a scale relative to the location.” - Ristol Consulting Ltd
Access to public services
The need to ensure good access to public services, such as healthcare, education and leisure facilities, was also mentioned by some. Healthcare issues identified included accessing specialist medical care and maternity care in some remote and rural areas. Achieving robust infrastructure was felt to require a whole-systems approach, strong leadership, effective cross-sector working, particularly between public-private sectors, and commercial acumen amongst those with responsibility for developing LDPs.
“The core tenant of the 20 minute neighbourhood concept is that individuals have access to key amenities and services close to them, to underpin a healthier lifestyle and more active communities. General practice is the central pillar of healthcare provision in Scotland, and in order to fulfil the promise of the ‘20 minute’ concept, access to local GPs is essential.” – RCGP Scotland (Royal College of General Practitioners)
Some stated that private newly built housing developments typically did not provide local access to a range of community facilities, such as dentists, doctors, shops, etc., nor were they close to public transport links. The Robroyston estate in Glasgow was mentioned by a few as an example of a development that did not provide basic amenities for residents.
A greater focus on sustainable transport in the guidance was suggested to acknowledge the importance of travel in connecting people with places. Calls were made for an integrated transport system, addressing connectivity within and between places. Other suggestions included subsidizing public transport, cross-local authority planning for public transport, ensuring buses offered safe, regular and reliable services, providing travel information, e.g. at bus stops and recognising the role that community transport plays. The need to improve walking infrastructure was also noted, but again it was felt this would be a particular challenge in rural areas.
“We consider that access to public transport should be included in the definition of a 20 minute journey. Access to services via public transport should, therefore, be taken into account when applying the 20 minute neighbourhood concept.” - Hallam Land Management
“It would be helpful for the guidance to state the need to integrate local living plans with the local transport policy including the Local Transport Strategy and Active Travel Strategy. Many of the policies included in this draft guidance need to be part of an integrated transport strategy to achieve the wider strategic outcomes/targets set out in the guidance such as 20% reduction in car km.” - Strathclyde Partnership for Transport
The development manager of a large urban expansion development highlighted current issues with public transport systems were adversely impacting the ability to achieve local living principles. This respondent called for service providers, including NHS, Network Rail and public transport providers to work in an active improvement programme to improve services. Aberdeenshire Council felt, if realised, local living would place unreasonable demands on public transport systems. The Scottish Futures Trust argued that revenue funding for improved bus services was likely to be more cost-effective than the capital investment required to provide services and facilities in multiple locations.
Other infrastructure issues
Achieving the optimal mix of facilities, including residential, affordable and commercial properties and amenity space, was felt to be a challenge by several. These respondents felt consideration of public transport links between and within areas - whilst outwith the planning domain - was crucial. Without sufficient demand, it was noted services could be withdrawn. This could impact urban as well as rural areas, with one highlighting a recent decision by one bus company to stop providing a night bus in Glasgow which could impact the night-time economy.
Other issues highlighted included: that differences between areas could cause disparity in terms of access to facilities; difficulties reversing previous planning decisions; and a recognition that some types of services, such as hospitals, could not all be provided locally. Respondents felt such challenges should be more explicitly acknowledged within the guidance, with an indication of how they could be addressed.
Funding and staffing concerns
Many respondents 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 (see Chapter 5) and was also raised in relation to the Business and Regulatory Impact Assessment accompanying the draft guidance (see Chapter 7). It was noted that some areas would require more investment and development than others or were more asset-rich, which could lead to disparities between areas.
“Whilst delivering new 20 minute neighbourhoods in the context of new housing developments could be funded directly by developers, it is less clear how they can be delivered in existing built-up areas where public sector organisations are under significant financial constraints.” – City of Edinburgh Council
Staff resources were also mentioned, with calls for more skilled planners and data experts or for more training and practical guidance. For instance, local authorities may not have the resources or staffing to use spatial mapping and GIS or to create sufficient baseline data, with qualitative data gathering, ongoing monitoring and reporting, and effective community engagement felt to be particularly resource intensive. Wholesale changes to the planning system were also considered likely to require staff training and upskilling. The Royal Town Planning Institute Scotland (RTPI) argued that implementation would be hampered by insufficient resources and called for the Scottish Government to publish a comprehensive resource and skills strategy as part of the Delivery Programme of NPF4.
CLD Standards Council suggested referring to the new National Occupational Standards relevant to Community Learning and Development (CLD) practice, which could be used alongside the CLD Competencies. Volunteer Scotland highlighted recent findings from the Scottish Third Sector Tracker that almost a third of organisations reported their organisation was in jeopardy as a result of rising costs. A few felt such challenges should be acknowledged in the guidance.
“Clarity on the resourcing and delivery of the guidance is essential to ensure it can be implemented effectively at the local level. This should include consideration of what skills are needed and how these will be provided, and by whom; and how barriers to implementation can be overcome.” – Scottish Futures Trust
“Unless public sector bodies have the skills and resources to engage in the process delivering new 20 minute neighbourhoods will be a challenge, especially if there is no funding to deliver or operate the facility.” - Persimmon Scotland
“West Dunbartonshire Council is very concerned that the level of information being suggested is far more detailed and resource-intensive to collect than the plan-making cycle would allow. It questions whether this is proportionate to expect at a local authority-wide level when preparing the next local development plan. It is recognised that the Local Development Planning Guidance states that “planning authorities are not expected to collect this information as primary data”, however, this should also be clear in the Local Living and 20 Minute Neighbourhood Guidance.” – West Dunbartonshire Council
Alignment with other policy areas
References to NPF4 and other policies in the guidance, and consideration of how local living could impact other policy areas, were welcomed. However, many respondents called for greater alignment between the guidance and other policies they felt were particularly relevant. Comments ranged from suggesting other strategies or frameworks which could be cited in the guidance, to calls to clarify specific points where respondents felt there were discrepancies between different policy positions. For example, it was argued that the Public Service Reform information sat better in the context of the Place Principle section, with a clearer connection made between the two.
“We believe that Part 1 of the guidance could be improved by offering more comprehensive context by showing how it clearly aligns to wider strategic or legislative agendas outwith that of NPF4, as is done in Part 3 of the guidance under the ‘Implement and Review’ section… it would be beneficial to see how ‘Local Living’ and ’20 Minute Neighbourhoods’ align with other relevant strategies set by the Scottish Government, including but not limited to: Housing to 2040, Just Transition plans, National Plan for Scotland’s Islands, Dementia in Scotland: Everyone’s Story, Scotland’s National Strategy for Economic Transformation, and A Scotland for the future: opportunities and challenges of Scotland's changing population.” – Age Scotland
The vast majority of these comments were made by one or a few respondents, often reflecting their specific area of expertise. These have been grouped by policy area where possible e.g. transport, health, the environment, etc, and summarised in Appendix B. However, points raised by multiple respondents have been noted in the main report.
More specifically, the Improvement Service, Place and Wellbeing Collaborative and Public Health Scotland suggested a new paragraph to emphasise policy alignment at a local level: “Local living can equally be bolstered when the policies, strategies and investments of local government and their stakeholders align around its delivery. This can include Local Outcomes Improvement Plans, Housing Plans, Climate Strategies, Economic Strategy, Masterplans, Development Frameworks, Community Wealth Building, Equality Outcomes and Fairer Scotland Duty and local neighbourhood plans, including Local Place Plans. Each can consider its impact on the key considerations that enable local living.”
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