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

7. Impact assessment update report

This chapter presents an analysis of responses to Q9, which asked respondents for their views on the impact assessment update report. This included updates to the Equalities Impact Assessment (EQIA), Business and Regulatory Impact Assessment (BRIA) and Island Communities Impact Assessment (ICIA).

Almost three fifths left an open-text comment in Q9, mainly addressing the EQIA and BRIA. More generally, however, several respondents in Q1 and Q10 highlighted the importance of ensuring local living is equally available to all and does not worsen inequalities or outcomes for marginalised groups or those with protected characteristics. To avoid repetition, these comments are presented below alongside the analysis of Q9.

Two fifths (41%) of organisations who answered Q9 indicated that they had views on the impact assessment update report. Health and social care and transport organisations were most likely to have additional views (67% and 60% respectively) and Land management / planning / development / architecture organisations were least likely (31%). Individuals were evenly split, with 48% indicating they had further views and 52% not.

Greater consideration of equalities and unintended consequences

Several respondents felt the EQIA did not sufficiently address the needs of those with protected characteristics, particularly those with disabilities or older people. More broadly, a recurring theme highlighted by several respondents, was 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.

“After all, not all communities are the same and not all individuals in a community are the same. Much research has been undertaken about the implications of spatial planning policy and design practices on individuals of different age groups, genders, racial identities and disabilities (to name a few). For example, RTPI research on women, children, and individuals living with dementia reveals the many barriers that individuals can face because public spaces were not designed with their needs in mind.” - RTPI Scotland

Respondents felt that involving such groups at an early planning stage would assist their inclusion. The Scottish Community Development Centre suggested linking with Scotland’s Citizen’s Assembly and Climate Assembly to help address inequality, tax and spending and environmental sustainability. Differences in resources between communities, including investment, were also felt likely to result in varying outcomes for people across different areas. One felt, for instance, that the guidance did not reflect the capacity and resources required to enable communities to drive local change.

A few felt the evidence on which the EQIA was based should be highlighted in the guidance itself. RNIB Scotland called for explicit reference to be made to the need for accessible information and transport, as well as recognition that disabled people may need to travel beyond their neighbourhood to access support. A few felt the EQIA was too broad and generic in its assumptions.

“This is written from the perspective of people with no health problems. There is nothing to support disabled people having full access to the public sphere.” – Individual

“I would question whether enough assessment has been given for those members of our society with disabilities, mobility issues or the elderly.” - Individual

Strengthening the guidance in relation to accessible housing and transport was also recommended. Age Scotland noted that a range of accessible transport options enables independence for many older adults in a community. Public Health Scotland suggested cycling was not an accessible form of transport and should be removed. MACS argued that accessibility should be a criterion for determining if a community is a successful place and called for a definition of ‘Inclusive Design’ that advocated for the early involvement of the end user in the design process.

Another prevalent theme was that the Scottish Government should require LDPs to consider how local living can impact inequalities, with poverty, in particular, needing to be more explicitly referenced. A few noted potential negative impacts should be considered, with Tactran noting that the Local Living Framework will likely be more difficult to achieve in areas of deprivation. Whilst one local authority agreed with the decision to not produce a Strategic Environment Assessment and Fairer Scotland Duty Assessment, others felt inequalities should still be considered.

“It is disappointing not to see a full Fairer Scotland Duty assessment when transport access and usage, as well as road safety and air pollution, are so unequally distributed between poorer and richer individuals and communities in Scotland. While the scope of this guidance may be arguable in terms of its “strategic” nature, there is a missed opportunity to clarify the specific capacity of planning to address inequalities of outcome.” – Living Streets Scotland

A few also felt health inequalities could be better referenced, with Public Health Scotland arguing that health mentions in the EQIA “lacked mechanistic detail and consistently clear outcomes”. It suggested mentioning the benefits of a Health Impact Assessment (HIA) approach in the guidance when considering the impacts on different groups, highlighting their HIA on Road Space Reallocation in Scotland, published in 2022. Similarly, RCGP Scotland explored how current planning practices can lead to health inequalities through fewer public facilities and public and active transport options in more deprived areas.

“The guidance could usefully include and amend these impacts to focus more specifically on issues relevant to local living and spatial planning… We would support a clearer definition of health inequalities and more mechanistic detail outlining how local living interventions can lead to reductions in health inequalities… It would be helpful… to explain that health inequalities are the unjust and avoidable differences in people's health across social groups and between different population groups. The fundamental causes of inequalities are the unequal distribution of power, income and wealth. These inequalities can then influence the wider environment in which people live and work, and in turn shape their individual experiences and health.” – Public Health Scotland

The Health and Social Care Alliance highlighted the need to ensure that digital access to services is a choice for people rather than the only available option. Age Scotland and others noted that care must be taken not to assume digital literacy or access to IT equipment. They referred to their partnership work to develop five Human Rights Principles for Digital Health and Social Care. Aberdeen City Council also highlighted that access barriers are not only distance-related but include, for instance, safety factors. Diabetes Scotland cited evidence showing a higher prevalence of diabetes amongst people from ethnic minority backgrounds and, therefore, the importance of enabling access to facilities and spaces that can help reduce risk factors.

Incorporating intersectionality as an overarching principle was suggested by the Scottish Women's Convention. They and others called for community capacity building to strengthen community empowerment and ensure bottom-up solutions were found in local communities. The Scottish Women's Convention also highlighted that women frequently work in their local area, for instance, due to lack of access to a car or caring responsibilities. It was therefore felt important to ensure the guidance did not further compound the situation of women in low-paid, insecure but local jobs.

“It is therefore vital that the 20 minute neighbourhoods consider the types of employment available within the local community so that women can have access to better quality, better-paid work.” – Scottish Women’s Convention

One individual felt in order for children and young people not to be discriminated against, local facilities would also need to be provided for them. Another felt that the statement regarding the inaccessibility of facilities for pregnant women and mothers of young children did not provide reassurance for these women.

Positive views of the Equalities Impact Assessment

Some welcomed the inclusion of the EQIA and associated documents, with comments that the Assessment was clear and well-organised and provided a useful focus on equalities. It was also felt to be comprehensive, summarised key aspects relevant to local living from an NPF4 perspective, and gave helpful information.

“We welcome that the Equalities and Society Impact Assessment outlines the need to include under-represented and lesser heard voices, given the close links between health and social inequalities.” – Place and Wellbeing Collaborative

“The impact assessment reports provide a clear and progressive approach to the development of NPF4 and it is acknowledged that this guidance has been fully assessed as part of this process.” – Moray Council

Comments on the Business and Regulatory Impact Assessment (BRIA)

Several respondents disagreed with the assertion in the BRIA that the guidance “places no additional requirements on planning authorities”. As described in Chapter 2, it was felt that implementing the guidance could have considerable resource implications, with some noting that placemaking had tended to focus on individual, single neighbourhoods and had not been replicated at scale across local authority areas.

“The East Ayrshire Local Development Plan 2: Proposed Plan includes 47 designated settlement boundaries, and these settlements vary greatly in terms of size, number of residents, and services available. There will be significant resource implications associated with implementing this policy in a way that is uniquely suitable to each individual settlement.” – East Ayrshire Council

A small number also felt that insufficient attention had been paid in the BRIA to the risk of the planning process becoming so complex and burdensome that developers consider investing elsewhere instead, such as Northern England regeneration areas.

The Scottish Futures Trust welcomed the consideration of the impacts of proposed legislation in the BRIA. They argued that building upon existing policy frameworks should be explored first, with additional legislation only developed as a final solution.

Comments on the Island Communities Impact Assessment (ICIA)

Some mentioned the inclusion of the ICIA. It was felt that the Assessment covered its brief and raised clear issues associated with 20 minute neighbourhoods. However, it was argued that the guidance document itself could better reflect these issues, notably infrastructure challenges and the tendency towards centralisation in rural areas. Bòrd na Gàidhlig called for the final ICIA to include potential impacts on the Gaelic language, noting this was required under the Scottish Government ICIA guidance.

Other comments

A small number felt the consultation paper was unclear about which impact assessment update report was being referred, as the website link landed on a page containing multiple assessment documents.