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.

Community facilities

Proposed key objective of NPF4: To promote and support the provision of accessible community facilities where a need has been identified in local development plans.

Many of the comments addressed the importance of certain types of facilities and services, including suggesting that the COVID-19 crisis has highlighted the importance of local services. Type of facilities or services seen as important included:

  • Health services, including GPs, health centres and chemists.
  • Care homes and nursing homes. It was suggested that NPF4 offers an opportunity to consider how planning can influence provision. It was reported that, in light of COVID-19, Health and Social Care Partnerships are already considering new models of care and that NPF4 could help shape the national conversation on this issue.
  • Education services, including schools.
  • Community centres and public halls.
  • Libraries.
  • Places of worship or multi-faith spaces.
  • Local hubs with office space.
  • Shops. Specifically, small scale markets, allowing local food producers a route to market. It was also suggested that the planning system should allow a greater range and coverage of local convenience stores across all communities.
  • Banks.
  • Restaurants or pubs. It was suggested that planning policy should recognise the role of restaurants and public houses as community facilities contributing to the sense of place, and that developments should not jeopardise them if already present and should be required to provide land to enable them where possible.
  • Allotments and community growing spaces. This issue is covered further under the Green infrastructure theme.
  • Safe play spaces. There was a call for NPF4 to include a recommendation around ensuring that play, recreation, leisure and assembling in public space is at the heart of Scottish planning policy, including by ensuring the use of Play Sufficiency Assessments and Actions Plans. It was suggested that local authorities should have the freedom to determine what 'sufficient' means in their local area.
  • Sports facilities, including sports pitches. Further comments included that the loss of any playing fields through change of use needs to be given very careful consideration. The importance of the wider, physical infrastructure of community sport and recreation, combined with the societal arrangements in place for their usage, was also highlighted. These issues are covered further under the Health theme.
  • Public toilets. Both rates reductions for premises providing maintained public access to toilet facilities that are not just for customers and an online register of public toilets were suggested. In terms of NPF4 doing more to promote Changing Places Toilets, it was noted that fully accessible toilets require more space, and this should be reflected in Building Standards.
  • There were also references to the importance of having access to quality greenspace and green networks, including because of the health and wellbeing benefits to local communities. This is covered further under the Green infrastructure theme. It was also suggested that facilities must be easily accessible to all, for example by creating safe streets and pavements, and that active travel infrastructure should encourage safe cycling and walking. This issue is covered further under the Transport theme.

In terms of the range of community facilities it was suggested that existing developments that lack such facilities should be upgraded.

Respondents also highlighted the importance of considering particular groups of people when planning community facilities. Suggestions included:

  • The ageing population, with the planning system needing to think carefully about how we plan for the needs of older people and recognise the merits of older people's proximity to services.
  • Young people, including through providing youth clubs and other facilities for teenagers.
  • Women, including in relation to their safety when using public spaces. It was suggested that places that have not been designed to enable access by those with a variety of access needs become inaccessible, including for disabled women, carers, older women, pregnant women, and mothers of young children.

Impacts of new development on existing community facilities

Comments included that NPF4 should require developers and planning authorities to consider the impact of new development on existing community facilities, and any requirement for new facilities that the development may generate. One suggestion was that, wherever possible, new homes should be built within the existing boundaries of towns and villages to allow easy access to existing community facilities. There was also a view that development obligations and conditions should be used to provide facilities if capacity would otherwise be exceeded.

There were also calls for a community-led approach, including by placing a greater emphasis on community priorities as demonstrated by consultation processes. The introduction of the concept of LPPs in the 2019 Act was welcomed and it was suggested that a development's impact on community welfare needs to be considered at the design stage, with local communities engaged in the process.

However, there was also a concern that a plan-led approach does not lead to investment and delivery of building and projects. For example, it was reported that developers have experience of being required to make section 75 contributions towards community facilities that a local authority has subsequently not taken forward under its obligations in the same agreement. It was suggested that NPF4 could take the opportunity to drive a holistic approach to place making which carries through to development and investment decisions.

Other comments included that:

  • Authorities should liaise with Community Planners at the LDP stage. Development Management must refer to LDPs and LPPs in the area (and Community plans).
  • A settlement first approach should be taken, with a policy criterion for locations outwith settlements that would have to be supported by a statement on locational requirements and a business plan.
  • There should be a prescribed set of information contained within settlement statements outlining the impacts of new development on existing facilities and requirements for community facilities. This should be provided in consultation with, for example, NHS Trusts.
  • There should be greater consideration of Delivery Programmes and the role they can play, particularly as they are updated annually.
  • There could be requirements (similar to those relating to demolition of listed buildings or loss of outdoor sports facilities) to show a building to be demolished is no longer fit for purpose or no longer needed or that the facilities provided will be equivalent or better than the existing facility and, if not at the same site, with a reasonable travelling distance.
  • Some community facilities will be provided during the lifetime of an LDP that have not been identified as an allocated site. This could be because planning the community facility project was at an early stage during the preparation of the LDP and the site was not known or had not been secured. Policies should be flexible to allow new facilities to be provided, even if they are not a proposal site.

However, there was also a view that individual local authorities have different standards for the provision of community facilities, and that these standards are a local matter. It was suggested that, if the Government intends to introduce standards for the provision of different community facilities, the initial consideration is whether NPF4 is the best place to consult on and provide these. It was argued that the role of planning is to provide land for community facilities, and that any quantitative standards for the community facilities required are perhaps best considered by other professionals with specific knowledge of the service to be provided.

In relation to the need for planning guidance, comments included that:

  • Guidance on requirements for new education and health facilities as a result of new development would be helpful and would help standardise the approach across the country.
  • NPF4 should give examples of the types of community facilities to which any requirements will apply.

Rural areas or island communities

Particular issues raised in relation to ensuring that rural and island communities have the facilities they need included that:

  • It will be important to define what is rural and sustainable to target provision of community facilities. It was suggested that places that are too remote or locations where there are few job opportunities may be unsustainable.
  • The school catchment area could help with identifying the catchment of a rural area.
  • There are areas with a track record of community land owning and enterprise trusts being the main developer of a range of developments including community facilities. There is scope to share and showcase good practice.
  • For remote non-linked islands, an approach that co-locates facilities so that limited resources can be pooled, through a community hub type approach, could be looked at.

Other issues

Other issues raised included that:

  • To ensure community facilities are resilient to the impacts of climate change, facilities, including refuse facilities, should not be built in areas at risk from flooding.
  • There is a need for a national planning policy on cemeteries and crematoria. An alternative view was that, while a separate policy on cemeteries is not required, NPF4 could clarify the remit for LDPs to consider the need for additional facilities and allocate land for these where necessary.



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