Part 1- Spatial Strategy
The draft national spatial strategy was themed around Sustainable, Liveable, Productive and Distinctive places.
Summary of representations
A number of the comments addressed the deliverability of Liveable places, with observations including that there is very little detail on how transformative social and economic change is going to be delivered. Respondents also commented on the importance of communities being empowered to be the key drivers of this change.
There was support for the focus on the just transition to net zero and a nature-positive economy. It was noted that the move to a greener economy could provide opportunities for business development, job creation and investment in communities, through community wealth building. In relation to rural, highland and islands settings, it was suggested that their distinctive socio-economic and market characteristics require a flexible, responsive approach to development, taking account of local context and need.
It was noted that the concept of Distinctive places is already well embedded in the planning system and there were concerns around how high level strategy translates into the individual policies required for delivery. There was support for a stronger commitment to placemaking, although it was argued that, at present, the design-led approach and quality outcomes identified do not feed through into policy.
Overview of changes
The spatial strategy section has been re-presented. We have moved from 4 themes to 3 to better reflect the three pillars of sustainable development. Narrative to each theme has been updated and wording sharpened. Clear linkages to other relevant policies and strategies have been added. Priorities for each theme along with National Developments that will help to deliver the theme have been more clearly presented. Text outlining cross-cutting outcomes and policy links has also been added.
|NPF4 needs to address the needs of all of Scotland's places and people and have clear outcomes and goals to deliver transformative change.||Detail of outcomes and addressing these aspects added and expanded upon upfront (from previously being in an Annex), clearer demonstration of how the spatial strategy supported by the policies can deliver on outcomes. Outcomes and policy intent added to every Revised NPF4 policy for ease of reference.||To respond to Committee (LGHP).|
|Reference to the Place Principle.||Place Principle references strengthened in Revised NPF4 including in relation to National Developments, design and local living. It is also a key element of the Delivery Programme.||To respond to stakeholder views.|
|Should be place based with rural, island, urban and peri-urban principles.||Revisions to the document as a whole have taken into account the varying need of different places.||Planning authorities can interpret the principles and provide further detail tailored to their specific needs if necessary.|
|Make connections to part 3 policies.||Spatial principles now embedded in thematic policies under Revised NPF4 'Policy Impact' sub-heading.||Responding to stakeholder views and ensuring ease of use of the document.|
|Gaelic – lack of reference or appropriate reference to the importance of the Gaelic language and culture in areas of the country.||Text added.||To respond to RAINE Committee.|
|Funding needed.||No change.||Delivery programme sets out information on infrastructure funding and finance.|
|Expand references to the pandemic.||References strengthened throughout document with particular emphasis on reflecting the impact of the pandemic under the narrative for each theme.||To respond to stakeholder views.|
|Should be a statutory requirement for planning decisions to favour net zero and nature recovery objectives.||Revised NPF4 Policy 1 strengthened to give significant weight to both the climate and nature crises.||To respond to stakeholder views.|
|National Spatial Strategy map should include further detail.||Maps have been updated. The strategy map now also shows the National Developments.||To respond to stakeholder views.|
Spatial principles for Scotland 2045
The Draft NPF4 set out that, in order to build a climate-conscious and nature-positive future, our strategy and the policies that support its delivery are based on six overarching principles.
Summary of representations
Although views were mixed, more respondents agreed that the spatial principles will enable the right choices to be made about where development should be located than disagreed. It was suggested that the spatial principles seem to encapsulate what NPF4 is seeking to deliver, including by recognising that a 'one-size-fits-all' approach would not be appropriate.
However, there was also a view that, as currently formulated, the spatial principles might not enable the right choices to be made. Related concerns included that the principles lack clarity and definition. There was a concern that it is not clear how this section is intended to be used by stakeholders of the planning system, what weight these principles will have, or how the spatial principles should or would inform consistent decision-making. Compact growth was the spatial principle that most divided opinion
Overview of changes
The spatial principles have been retained and better represented throughout the document. Table 1 in Revised NPF4 shows how they fit into the overall framework. A policy impact section for each themed policy in Revised NPF4 Part 2 shows which spatial principles the policy will help to deliver.
The narrative around each principle has been strengthened and 3 principles have been renamed to respond to stakeholder views.
|Not clear how spatial principles should be used/ what weight they will have.||Text added to the spatial principles section setting out how to apply the principles in practice. The updated 'How to Use this Document' section is now Revised NPF4 Annex A and provides further information.||To respond to stakeholder views and provide clarity.|
|More spatial principles should be added.||No change.||Suggested topics for additional principles are generally well represented in other parts of Revised NPF4.|
|Too urban-centric.||Text refreshed and updated throughout. Revised NPF4 includes new policy 17 on Rural Homes.||To respond to stakeholder views.|
|Consider how priorities and principles could be built upon to more clearly emphasise the contribution NPF4 makes to addressing inequalities, health and wellbeing and the needs of rural and island areas.||New sections on outcomes drafted and moved into themed introduction.||To respond to Committee (LGHP and RAINE).|
|Reference to the Place Principle.||Place Principle references strengthened as noted above.||To respond to stakeholder views.|
|Should be place based with rural, island, urban and peri-urban principles.||No change.||NPF4 is a place-based strategy for Scotland as a whole. More detailed place-based approaches are expected to emerge in subsequent LDPs, informed also be future Regional Spatial Strategies. Planning authorities can interpret the principles and provide further detail tailored to their specific needs if necessary.|
|Compact growth – not relevant in rural areas.||Amended and retitled to focus on Compact Urban Growth. Updated explanation provided.||To respond to stakeholder views and provide clarity.|
|Compact growth - not always appropriate to use derelict land.||No change.||Issue covered by themed policies including Housing and Brownfield Land.|
|Compact growth – delivery of housing will be reliant on land coming forward through LDPs.||No change.||Plan Led system. Issues covered by Revised NPF4 Policy 16 Quality Homes.|
|Local living – clarity needed on 20 minute neighbourhoods particularly in rural areas.||No change to spatial strategy but wording strengthened in the Glossary. The local living policy has also been revised referring to the principles of local living more broadly, this will allow the policy to be more readily applied to rural areas through alternative solutions.||To respond to Committee (LGHP and RAINE) and stakeholder views. Supporting guidance is in preparation.|
|Balanced development.||Renamed rebalanced development with updated explanation.||To provide clarity.|
|Balanced development - equality in digital needs to be recognised.||Digital equality now referenced.||To respond to stakeholder views and provide clarity.|
|Rural urban synergy.||Changed to 'rural revitalisation' to provide a clearer principle which complements the refocusing on compact urban growth.||To provide a clearer steer and embed a key statutory outcome across the document as a whole.|
|Definitions of terms.||Various terms added and defined in the Glossary.||To respond to stakeholder views and provide clarity.|
Action areas for Scotland 2045
The draft NPF stated that each part of Scotland can make a unique contribution to building a better future. It explains that our shared spatial strategy will be taken forward in five action areas and that each area can support all spatial principles.
Summary of representations
General comments included that the spatial strategy action areas provide a strong basis to take forward regional priority actions and that the Draft NPF4 does appear to have identified appropriate priorities for different parts of the country.
One of the most frequently-raised issues was the relationship between the action areas and other spatial areas, with respondents most likely to comment on their connection to Regional Spatial Strategies. It was noted, for example, that considerable work has been put into the preparation of Indicative Regional Spatial Strategies but that the extent to which those have played a part in the preparation of the Draft NPF4 is unclear.
A number of respondents thought that, rather than creating new action areas, it might be clearer if Regional Spatial Strategy areas were used as the spatial expression of policy approaches.
Another frequently-raised issue was the relationship between the action areas and local authority boundaries, with concerns raised about some local authorities being split between different action areas.
- North and west coastal innovation
General comments included that there is potential for conflict between the different strategic actions proposed for the North and west. In relation to creating carbon neutral coastal and island communities, the recognition that island and coastal communities will need a bespoke and flexible approach to the concept of 20 minute neighbourhoods was welcomed.
Four strategic actions were included for the North and west coastal innovation action area in the Draft NPF4. With reference to reversing population decline, there were questions about the viability of reintroducing people to previously inhabited areas. There was a call for existing communities to be supported prior to the development of projects aimed at reintroducing people to areas that are not currently inhabited.
- Northern revitalisation
A number of comments suggested that there is a great deal of crossover between the Northern and North and west action areas. Some respondents proposed combining them.
Four strategic actions were included for the Northern revitalisation action area in the Draft NPF4. There was support for the reference to the importance of renewable energy generation for climate mitigation, and the need for the repowering and extension of existing wind farms. However, there were also calls for clarity on what approach will be followed for new wind farm proposals.
- North east transition
A general comment was that the North east action area is very much focused on the energy transition, but that there is much more to this region. A connected concern was a view that there is a lack of ambition, vision and understanding of the region.
Four strategic actions were included for the North east transition action area. General comments about the transition to net zero (Action 9) included that it is applicable to whole of Scotland. There was also a call for the action to reflect the potential of the entire north-eastern coastline.
- Central urban transformation
Although there were some broad statements of support, a number of respondents raised concerns about either the size of this action area, or the diversity of the communities and places that it covers. There was a particular concern that there is a strong urban focus, and that the challenges and opportunities identified, along with the strategic actions, are less relevant to the significant rural population.
Nine strategic actions were included for the Central urban transformation action area. It was noted that realising a number of the strategic actions will require a regional and catchment scale approach and that the role of the Regional Spatial Strategies to spatially coordinate activities and guide delivery at scale and across authority boundaries, will be key.
- Southern sustainability
There was a concern that this action area is not ambitious enough and needs to better reflect the realities of the region. In addition to generally making the language more proactive, it was suggested that the region's contribution to achieving net zero, along with the economic ambitions of the region, should be referenced.
Four strategic actions were included for the Southern sustainability action area. General comments included that the strategic actions could also be more ambitious. Regarding innovating to sustain and enhance natural capital, there was reference to the UNESCO Biosphere and its role in delivery of ecosystem services.
Overview of changes
The principle of Action Areas is retained and refined. The areas are refocused as Regional Spatial Priorities, with an emphasis on context, challenges, priorities and delivery, and the detail moved to Revised NPF4 Annex C.
The approach to these responses reflects an appropriate level of detail for a national spatial strategy. Further detail is expected to emerge in subsequent Regional Spatial Strategies and Local Development Plans. It would not be appropriate for NPF4 to seek to pre-determine regional and local placed-based responses to the Scotland-wide priorities it sets out.
The changes do however, aim to provide a clearer direction on the distinct challenges facing rural and island communities, and other detailed comments and additions have been taken on board in both the main text and more detailed annexes.
|Spectrum of views of the utility of this part of the strategy including concerns that areas are untested and questions about application in practice. Views that interim spatial strategies are not reflected. Comments on varying regional geographies and the link between Action Areas and Regional Spatial Strategies, Regional Transport Strategies and local authority boundaries.||Amended. Action Areas refocused as Regional Spatial Priorities and the interaction with Regional Spatial Strategies is set out in the Revised NPF4 Annex A 'How to use this Document'. The Delivery Programme also makes connections with regional scale planning for example by setting out the geography of city and growth deals. Statutory guidance on Regional Spatial Strategies will be developed in due course.||The Regional Spatial Priorities give a clear steer on the strategic priorities for each area, which should be considered further through both future RSS and LDPs. This part of the document has been informed by indicative RSS, with NPF4 highlighting priorities from a broader, national perspective. The broader action areas are flexible, reflect cross-boundary issues and recognise the spatial issues span administrative areas.|
|Concerns raised about some local authorities being split between different action areas.||Amended. The maps are indicative and some authorities may have a role to play in more than one regional area in response to cross-boundary issues. Revised text in Revised NPF4 Annex A gives clarity on the extent of the Regional Spatial Strategy areas.||Refocused Regional Spatial Priorities set out how each part of the country can help to deliver the overall strategy. Boundaries are intended to be flexible, recognising that planning authorities will define the appropriate geography for Regional Spatial Strategies, and that this may change over time.|
|Distinct priorities (innovation, transformation, revitalisation, transition, sustainability) apply to other/all areas.||Amended. Descriptive subtitle for areas have been removed, recognising overlaps.||Amendment responds to stakeholder views.|
|North and west coastal innovation|
|Reasonable summary of the issues but should not be read as comprehensive.||No change.||The Revised NPF4 'How to Use this Document' Annex A provides further clarity on the role of this section.|
|This is a diverse area with differences including varying settlement patterns and population change.||Detailed amendments made to text.||To ensure that differences between the areas are noted and reflect stakeholder views.|
|Northern revitalisation/North West coastal innovation – suggestion to combine these action areas.||No change to broad areas. Amended North and West Coast and Islands remain separate from North to allow the strategy to reflect the particular opportunities and issues for coasts and islands. A stronger narrative on the links west and north to coastal and island communities is provided.||Regional Spatial Priorities sets out how each part of the country can use their assets and opportunities to help deliver the overall strategy. Within this broad framework, planning authorities are encouraged to work flexibly and to define the geography of their Regional Spatial Strategy as appropriate. The strategy has been designed to act as a clear but flexible framework for future RSS and LDPs to respond to.|
|Further places to be highlighted or included in the area.||Detailed amendments made to text. Removed strategic diagram showing boundaries to allow for flexibility in application.||To reflect additional priorities and areas highlighted by stakeholders.|
|Proposals to add further detail on a range of issues including coastal change, environment assets, climate adaptation, connectivity, population change; housing, community wealth/ownership, cost of living, Gaelic, aquaculture and employment.||Various amendments and additional text has been included add further detail on specific opportunities and challenges.||To reflect additional detail provided by stakeholders as far as possible, whilst maintaining a strategic perspective. RSS can address many of these issues in further detail as appropriate.|
|Concerns about conflict between strategic actions.||These tensions are noted. Policies have been reviewed to ensure trade-offs and synergies between objectives are clearer.||The planning system has a critical role to play in balancing competing objectives.|
|20 minute neighbourhood concept requires bespoke approach/ cannot be delivered in communities in this part of Scotland.||Amended text to provide greater flexibility.||To ensure that the policy intention of supporting local liveability is applied in a flexible way.|
|Questions about the viability of reintroducing people to previously inhabited areas.||Amended wording focuses on supporting existing settlements and where appropriate encouraging people to previously inhabited areas where it can be achieved in line with our climate commitments and wider aspirations to create sustainable places. This is now supported by updated policies on rural housing and development which reflect the role of LDPs in taking this forward.||This is a statutory requirement introduced by the Planning (Scotland) Act 2019. The changes aim to reverse past depopulation and support existing settlements in more peripheral and fragile areas in a way that is compatible with our low carbon agenda and which is driven by place-based LDPs.|
|Proposals to add further detail on renewable energy opportunities, innovation, ports, space ports, food and drink and tourism.||Amended text in Revised NPF4 Annex C reflects additional detail provided as appropriate.||To reflect additional priorities and areas highlighted by stakeholders.|
|Comprehensive summary but focus is on extracting benefit from the area's assets rather than creating vibrant and sustainable places. Revitalisation not the priority throughout the area.||Amended text including key priorities, aims to reflect the importance of strengthening communities.||To reflect stakeholder views on the overall tone of this section.|
|Further detail suggested on specific projects, environmental assets, landscape protection, forestry and peatland restoration, housing, tourism, flooding and water.||Some specific/targeted additions made to text.||While these projects are recognised as important, more specific detail is expected to be appropriate for RSS to take forward.|
|Calls for clarity on what approach will be followed for new wind farm proposals.||No change. The detailed policy framework sets out the approach to be followed for new wind farm proposals across Scotland.||The annex text acknowledges the area's support for renewable energy generation and the potential for repowering and extending existing sites.|
|Comments on the title of "strengthen networks of resilient communities."||Spatial priority heading amended.||To provide a more rounded description.|
|Comments on economic development: flexible approach, tourism impact, renewable energy and infrastructure, ports.||Some specific/targeted additions made to text.||While these projects are recognised as important, more specific detail is expected to be appropriate for RSS to take forward.|
|Comments on the environmental priorities under this theme including opportunities arising, questions about terminology and scope to align with Regional Land Use Partnerships.||Some specific/targeted additions made to text.||While these projects are recognised as important, more specific detail is expected to be appropriate for RSS to take forward.|
|Connectivity (digital and physical) is important. Proposals to include a range of specific transport improvements.||Spatial priorities reflect importance of connectivity. Some additional references added e.g. A82 and Oban airport.||Additional detail appropriate for STPR2 and RSS/Regional Transport Strategies.|
|North east transition|
|Too focused on the energy transition, lack of ambition, vision and understanding of the region.||Amended wording, with focus on context and priorities, gives a broader sense of the region's assets and potential and provides more detail on specific projects.||Regional spatial priorities sets out how each part of the country can use their assets and opportunities to help deliver the overall strategy. The strategy has been designed to act as a clear but flexible framework for future RSS and LDPs to respond to.|
|Questions about extent and boundaries.||Amended Regional Spatial Priorities highlight support for continued economic diversification and innovation.||Regional Spatial Priorities sets out how each part of the country can use their assets and opportunities to help deliver the overall strategy. The strategy has been designed to act as a clear but flexible framework for future RSS and LDPs to respond to.|
|Proposals for more specific detail/ commitments to a range of infrastructure/ development projects.||Some specific/targeted additions made to text.|
|Additions suggested including on biodiversity, housing, farming and crofting, aquaculture, timber production and processing, nature, community empowerment, skills gaps, city centres, coastal regeneration challenges, water supply delivery.||Some specific/targeted additions made to text.|
|Transition to net zero applicable to all of Scotland. Should recognise potential of the wider coastline.||Some specific/targeted additions made to text including reference to broader coastline.||Net zero has been considered across all action areas.|
|Detailed comments on green energy including hydrogen and CCS, solar. Opportunities from ScotWind for ports and harbours.||Some specific additions made, also acknowledging that wider consents are relevant.||Further detail is also included in the national development description.|
|Too great an emphasis on reducing car use/20 minute neighbourhoods in largely rural areas. Range of views on transport solutions.||Text amended to reflect flexibility of local liveability rather than only 20 minute neighbourhoods.||To reflect stakeholder views and recognise the diversity of the area.|
|Central urban transformation|
|Concerns about the size and diversity of the area.||No change to extent of the area. Additional guidance on how to use NPF4 has been provided in Revised NPF4 Annex A. Description revised to give clearer view on geographic extent – mapping is indicative. Diversity reflected in amended text.||The scale is recognised as significant, but the area is considered to be of an appropriate scale within a broad spatial strategy for Scotland as a whole. This provides flexibility for RSS to emerge within the area which will provide additional detail on strategic priorities over time.|
|A range of specific projects should be referenced.||Text amended to reflect projects as far as possible and appropriate.||To reflect stakeholder views as appropriate, whilst recognising that additional detail will be provided in RSS.|
|Contrasts between Glasgow and Edinburgh city regions should be amended.||Description amended to reflect local variations in levels of deprivation/ market.||To reflect stakeholder views whilst maintaining strategic point of variation across the area as shown in spatial evidence.|
|More emphasis on health and deprivation, town centres, tourism, renewable energy, energy efficiency, and food.||Additional text added as appropriate. Particular additions on health and wellbeing/inequality.||To reflect stakeholder views and ensure strategic challenges are reflected as appropriate.|
|Questions about whether all actions are relevant to all areas.||No change||The strategy is designed to provide a flexible framework within which more detailed RSS and LDPs can be developed.|
|More information on delivery required/ deliverability/ resources from Scottish Government.||A Delivery Programme sets out our approach to delivery, recognising the importance of partnership working in delivery.||To provide a clear pathway to support delivery.|
|20 minute neighbourhoods will be more deliverable here rather than in other areas. Public transport/active travel links between and within them will be important, as well as digital links.||The related policy has been updated to provide clarity on the relevant considerations for planning.||Recognition of the importance of this area in delivering 20 minute neighbourhoods is welcome.|
|Former coalfield communities should be prioritised||Now highlighted in the text.||To reflect stakeholder views.|
|Specific comments on cities and town centre challenges.||Minor changes incorporated.||Further development of this theme in regional spatial strategic are expected to take forward more detailed/ varying issues raised.|
|Green infrastructure – specific comments as well as emphasis on the need for collaboration and investment.||Some specific additions have been made to reflect additional projects.||To reflect stakeholder views.|
|Specific comments on strategic investment sites.||Additional text added to reflect investment opportunities.||To reflect stakeholder views.|
|Climate impacts on urban coasts and waterfronts should be acknowledged. Wider role of ports should be recognised/specific projects and priorities for ports in the area. Further specific locations and coasts should be mentioned.||Additional reference to climate adaptation and port based opportunities added.||To reflect stakeholder views as far as appropriate, recognising that some projects will be for regional and local scale planning to take forward.|
|Support for reusing sites/buildings, but support required for delivery including policy and infrastructure.||A Delivery Programme sets out our approach to delivery, recognising the importance of partnership working in delivery.||To provide a clear pathway to support delivery.|
|Net zero housing will be a significant challenge. More homes also required. More detail on retrofit/ development sector role required.||Minor amendments to text. A Delivery Programme sets out our approach to delivery, recognising the importance of partnership working in delivery. This priority is already reflected in wider investment programmes.||It is recognised that significant investment in existing homes will be required to achieve net zero.|
|Questions about the meaning and extent of the urban fringe and relationships between cities and rural areas.||Urban fringe removed and replaced with more descriptive text.||To avoid confusion around terminology.|
|Specific suggestions for including more detail on transport including public transport projects, active travel, roads projects.||No change.||The strategic projects noted are considered appropriate for inclusion in a national spatial strategy. Further detail will emerge in RSS and Regional Transport Strategies, within the context of both NPF4 and STPR2.|
|Community wealth building should be properly defined.||Policy amendments have been made, complementing the broad approach of the spatial strategy.||To provide clarity and respond to stakeholder views.|
|Strong urban focus, and that the challenges and opportunities identified, along with the strategic actions, are not relevant to the significant rural population.||Amended Regional Spatial Priorities for Central focus on tackling inequalities and building a new, greener, future for this part of the country.||The detail in revised NPF4 Annex C gives further guidance on spatial planning priorities.|
|More emphasis should be given to the role of the area in net zero and its economic ambitions.||Various amendments made to address both net zero and economic opportunities.||To reflect stakeholder views and ensure the tone reflects regional priorities/strategies.|
|Boundaries and extent of the area should be considered further.||Text as a whole reviewed to ensure geographic extent is more fully covered. Additional explanation provided. Cross border links also referenced.||To provide more clarity on the extent of the area.|
|Reference should be made to specific projects including the UNESCO Biosphere reserve and Galloway Forest Dark Skies Park.||References added.||To highlight additional opportunities/assets in the area and reflect stakeholder views.|
|More emphasis on natural capital for example peatland and competing land uses/biodiversity.||Additional references added e.g. to land based industries.||To reflect stakeholder views.|
|Further issues to be addressed: flood risk, onshore wind/ transport/Regional Transport Strategy, food and recreation/ tourism, blue green infrastructure, climate adaptation.||Changes made as appropriate for a national scale strategy. Many of these issues are addressed across the document as a whole.||To reflect stakeholder views whilst maintaining a broader perspective for the national spatial strategy.|
|More detail proposed on ambitions for settlements/wider coverage of low carbon towns. 20 minute neighbourhoods require tailored approach. Housing requirements of the area should be addressed.||Additional references made including to the importance of housing provisions and the importance of communities in shaping their future.||To reflect stakeholder views.|
|Further reference should be made to transport and travel||Broad reference to the importance of connectivity included/specific updates provided.||To reflect stakeholder views as appropriate at a national scale.|
|Range of comments on further opportunities for economic activity and education.||Additional projects added.||To ensure the extent of the area is reflected, for example with additional reference to projects in Ayrshire.|
|Concern that this action area is not ambitious enough – call for the region's contribution to achieving net zero, and the economic ambitions of the region, to be referenced.||Amended Regional Spatial Priorities for South set out a strategy which aims to ensure that the area fulfils its potential as a place to live, work and visit, with a focus on climate change, increasing the population and supporting economic development.||The detail in Revised NPF4 Annex C gives further guidance on spatial planning priorities.|
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