NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.

Town centres

Proposed key objective of NPF4: To ensure that planning policies recognise and address the challenges facing town centres so that they are better able to adapt and be vibrant, creative, enterprising and accessible places to live, work and visit.

There was support for the proposed objective, with a number of respondents commenting on the significant challenges town and city centres face, particularly in relation to changes to the retail sector and the growth of out of town and online retail. The likelihood of the COVID-19 crisis accelerating the pace of change was highlighted and there was an associated call for a review of the Town Centre Partnership's funding strategy by or in association with the Scottish National Investment Bank and for a revised Town Centre Action Plan.

It was also suggested that planning alone cannot address the challenges, and that a more holistic and collaborative approach between government, local authorities, agencies, stakeholders and partners will be required if city and town centre spaces are to stay or become more attractive places for both businesses and people. It was noted, however, that it would be helpful if an overall policy approach was set out at the national level and that guidance would be helpful in supporting a level of consistency. In particular, it was suggested that greater clarity and guidance on town centre health checks is required.

Many of those commenting went on to highlight the importance of taking a town centre first approach, including because of its focus on uses that attract significant numbers of people into town or city centres, and that the focus needs to include attracting people of different age groups.

It was suggested that NPF4 needs to continue to emphasise the town centre first principle, and that encouraging and enabling of a range of different uses will be key. It was suggested that town centres need to evolve away from their traditional retail role into hubs where the full range of social, health, cultural and leisure activities are concentrated. The type of activities highlighted included retail and commercial leisure, offices, community and cultural facilities, increasing residential use and creating better public spaces for social interaction and activity. It was reported that arts events and heritage schemes can promote local economic activity, as can relocating educational facilities into town centres.

One local authority respondent reported that their proposed LDP for 2020 sets out a revised policy position with regards to the primacy of retail in their city centre and that it embraces the trends away from traditional retailing and promotes uses which encourage vitality, viability and vibrancy of place. Other comments about creating well-functioning town and city centres included that:

  • The Agent of Change principle should be embedded in NPF4, with a focus on protecting existing uses but also ensuring appropriate amenity of new uses. It was suggested that the need for change in use of a wide range of property types will accelerate, and consideration will need to be given to the adaptability of existing and proposed floorspace to accommodate new uses. The need for a robust framework to promote the re-use and repurposing of vacant units was argued.
  • Simplified Planning Zones and Areas were suggested as a possible option, moving to Masterplan Consent areas.
  • Creating Low Emission Zones, with the development of Park and Ride systems, and reduced dependency on car travel through improved public transport should be considered.
  • In alignment with prioritisation of green infrastructure delivery, NPF4 should proactively promote the enhancement of town centres through creating new green infrastructure.
  • Housing may become more and more important to keeping town centres vibrant.
  • There should be continuing protection for listed buildings and conservation areas and a focus on property condition and improving properties, using mechanisms like the Conservation Area Regeneration Scheme.
  • Investment should be focused on improving the areas around Scotland's main stations and associated thoroughfares which see (or should be seeing) the highest footfall in Scotland.
  • Business rates should be aligned to underpin planning policy for example as a means to support the revitalisation of the high street, deliver more city centre housing, reuse of gaps sites and discourage 'edge' development.

Other comments focused on high streets and high street shops and business being prioritised relative to out of town, retail park style developments. It was suggested that out of town retail developments should only be acceptable in exceptional circumstances, including because rejuvenating and transforming existing areas makes better use of embodied energy, and existing infrastructure and services than does developing greenfield sites.

A connection was also made to maximising the potential of vacant properties and inactive land and it was suggested that there needs to be a greater focus on overcoming constraints on brownfield vacant and derelict sites, with additional funding to bring these forward and support the role of planning as an enabler. These issues are explored further under the Vacant and derelict land theme.

There were calls for the different role and circumstances of town centres in rural and island areas to be recognised. However, while it was reported that some may be prospering and continuing to play a vital role, others are suffering from economic and social decline. It was suggested that rural towns could play a key role, but that significant investment will be needed. There was a call for a major programme of rural town renovations, converting them into thriving service hubs for the green economy and into places that provide safe and healthy residential housing for the local community.

Finally, in addition to support for the town centre first principle, there was a call for continued support for the hierarchy of centres approach, including through national policy being flexible enough to accommodate different networks and hierarchies across Scotland.



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