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.


Key objective of NPF4: To ensure that the planning system supports the Scottish Government's purpose of focusing on creating a more successful country with opportunities for all of Scotland to flourish through increased wellbeing, and sustainable and inclusive economic growth which is achieved with a view to achieving net-zero emissions by 2045.

Importance of, presumption in favour of sustainability

In addition to sometimes offering support for the objective, general comments included that sustainability will be even more important looking further into the future and that the presumption in favour of sustainable development should remain a component of national planning policy. It was suggested that the overarching principle of the planning system should be sustainable development, and this like climate change, should run as a thread through the entirety of NPF4.

One perspective was that the current presumption in favour of sustainable development, as both a concept and a material consideration, is a source of confusion and does not work well. It was noted that 'sustainability' is a wide-ranging term and there was a concern that this could result in a lack of clear direction on priorities or how sustainability can be measured or assessed.

Specifically, it was seen as helpful to clarify:

  • What is meant by sustainable and inclusive economic growth?
  • What constitutes sustainable development?

There was a call for any definition of sustainable development to align closely with NPF4's defined outcomes, with emphasis in particular on climate change, inclusive growth and wellbeing.

However, it was also suggested that a catch-all outcome of sustainability remains appropriate because it is broad in scope which allows new and emerging issues to be addressed over the lifetime of NPF4.

United Nations Sustainable Development Goals

There was support for NPF4 being aligned with the United Nations Sustainable Development Goals,[33] although it was suggested that not all the goals may be appropriate, including because some are very much focused at a global level. Nevertheless, the potential for NPF4 to translate some of the goals into a Scottish context was highlighted. Specific suggestions included that:

  • Goal 7: Affordable and Clean Energy, is relevant to the climate emergency.
  • Some goals should be given particular attention. These included Goal 3: Good Health and Wellbeing; Goal 5: Gender Equality; Goal 7: Affordable and Clean Energy; Goal 8: Decent Work and Economic Growth; Goal 9: Industry, Innovation, and Infrastructure; Goal 10: Reduced Inequalities; Goal 11: Sustainable Cities and Communities; Goal 12: Responsible Consumption and Production; Goal 13: Climate Action; Goal 14: Life Below Water and Goal 15: Life on Land.
  • The historic and built environment has the potential of the to contribute to Goals 3, 7, 8, 9, 10, 11, 13, 15 and 17.

Relationship with addressing climate change

The main analysis of comments relating to climate change is presented under that theme. With specific reference to and in connection with sustainability, points raised included that:

  • 'Sustainability' effectively captures the policy drivers of climate change, inclusive growth and human wellbeing as it is based on social, economic and environmental pillars.
  • The concept of sustainability needs to acknowledge the immediate nature of the climate emergency.
  • NPF4 needs more detailed policy positions on matters including carbon emissions, biodiversity and development, rather than the more general outcome of sustainability.

There was reference to the proposed key objective of NPF4 in relation to climate change[34] and it was suggested that the relationship between the climate change and sustainability objectives reveal tensions in the general direction of travel of national planning policy. A connected point was that, if climate change targets are to be achieved, NPF4 will need a new hierarchy, which puts improving the environment and society first, setting an ambitious, optimistic and co-ordinated vision for a sustainable Scotland and providing a route map for the economic strategy to follow. Similarly, there was a call for NPF4 to set out a vision of a Scotland where the economy is sustainable and aligned with climate targets.

The two possible meanings of sustainability were highlighted - one being 'environmentally-aware' and the other being 'capable of continuing'. It was argued that the usual usage of 'sustainable economic growth' is growth which continues, but that the inclusion of 'sustainable' adds an aura of growth which is environmentally respectful. It was suggested that pure growth should not be the nation's primary economic objective - rather, the aim should be a sustainable society and economy. There was an associated call to replace 'sustainable economic growth', with a term such as 'sustainable society'.

With specific reference to carbon emissions, it was suggested that the strongest influence planning can have is directing development to locations that are sustainable or can be made sustainable, with regard to how people travel to these places or how they are powered and heated. It was noted, however, that sustainability relates to more than carbon emissions, but includes the creation of successful places that will endure and enhance the economic and social wellbeing of communities. It was considered important for NPF4 to be clear about what sustainable development is and how it is to be measured.

A number of the National Development proposals submitted, including some of those involving the use of brownfield and former industrial sites, focused on sustainability and the creation of low or zero carbon sustainable communities which provide healthy and inclusive places to live and work.

Sustainable economic growth

The connection was often made between inclusive economic growth and reducing inequality and tackling deprivation and it was noted that sustainable and inclusive prosperity is a central objective of the NPF[35] towards which all policies should work.

It was also reported that in some areas, including parts of the west of Scotland, the current economic system has reinforced inequality. It was reported that in the past the role of planning has been diluted and is often restricted to facilitating the market, meaning its role in the delivery of sustainable economic growth has focused disproportionately on short-term economic outcomes. Going forward, the concern was that without a coherent and co-ordinated realignment of all drivers of the economic system, any realignment of the planning system will be an isolated and ineffective exercise.

It was also suggested that any review or realignment should consider inequality based on protected characteristics and socio-economic status and not just based on regional or geographic inequality. A place-based deprivation approach was preferred, with the PSED and 'Fairer Scotland' duty seen as providing a structure to support planning, inquiry, assessment and monitoring to ensure that spatial policies address inequality successfully.

It was also suggested that NPF4 should support inclusivity and community wealth building, including by ensuring that communities are all benefiting from the local economy through support for a diverse range of local businesses and approaches to create a resilient community. Other proposals for how NPF4 could support the building of a sustainable economy included:

  • Taking a 'Community Wealth Building', people-centred approach to local economic development, which redirects wealth back into the local economy, and places control and benefits into the hands of local people.
  • Ensuring that economic success is built into place-based decisions. It was observed that the Place Principle and Place Standard are important for an economic vision which recognises health and wellbeing.
  • Providing the framework for a more active regional policy including regional prospectuses.
  • Pursuing a more structured approach to national and regional development that recognises the complexity of economic challenges and opportunities and which delivers added value to place through development gain, jobs, skills and training.
  • Supporting the protection, restoration and facilitation of investment in nature that can help support a new, socially just economy which responds to the challenge of climate change.
  • Emphasising that growth and investment in key sectors relies on environmental quality, infrastructure and the sustainable use of natural resources.
  • Encouraging much greater public participation at a local and national level in planning decisions likely to affect them. Community engagement is covered further below.

Specific suggestions as to how sustainable economic growth could be progressed through NPF4 included:

  • Changing the way in which grants, incentives and subsidies are administered so that they level up the gross inequalities between communities, public services and large business and landowners.
  • Ensuring a diversity of ownership and investment when approving developments and, where appropriate, requiring community involvement and public benefit.
  • Linking initiatives such as community benefit clauses to procurement to help support local economies.
  • Directing provision, including of large public sector developments and possibly National Developments, towards areas most in need of an economic boost.
  • Promoting the wider application and use of Sustainable Growth Agreements to promote sustainable development and low and zero carbon design principles and good practice.
  • Continuing to invest in housing as an infrastructure priority and building homes with consideration of the wider infrastructure and facilities that are required for communities to flourish.
  • Supporting the development and enhancement of hubs and creating conduits for entrepreneurship, workers, skills, training, goods and services.
  • Promoting growth corridors as a means of linking hubs of economic activity and generating stronger outputs and improved outcomes for areas experiencing economic challenges.

Sustainable development and resource use

With particular reference to developing in a sustainable way, it was suggested that a whole systems approach that considers the environmental, social and economic impact of any planning decision should be presumed. The Brundtland report[36] definition of sustainable development was seen as helpful: 'sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs'.

It was suggested that delivering sustainable development is a key function of the planning system but that the planning system still requires support and guidance on this matter. In terms of key considerations or features of the approach, comments included that it should:

  • Balance the total economic cost and social change together with the inevitable environmental consequences.
  • Be built around an ecosystems services/eco-security approach that reflects best land use practices (at the national level for integrated decision making and the local level for practical implementation) to ensure that the collective pressure of all development and activity is kept within levels compatible with the achievement of good environmental status.
  • Ensure that scarce and/or finite resources, such as land or minerals, are not squandered either deliberately or through ignorance.
  • Recognise that different approaches may be appropriate to different locations and should allow for a degree of flexibility.
  • Maximise opportunities for repurposing of existing assets. Specifically, it should support the reuse of existing buildings to support new economic activity and should explore a sequential approach to support this.

In terms of the repurposing of existing assets, further comments included that:

  • A sequential approach could be based on developers being expected to rule out viable options for conversion and repurposing existing buildings in the proximity before they are able to construct new development.
  • New approaches to building and retrofitting will be required.
  • The Scottish Infrastructure Commission[37] has recommended utilising existing facilities and assets wherever possible. Promoting reuse of existing facilities could constrain the ability to direct development to new locations and a flexible approach will be required.

Other specific comments as to how any approach should be framed, and sometimes with particular reference to current SPP, included that:

  • SPP should be updated to reference inclusive economic growth.
  • Increasing the influence and improving integration of the SEA, while also streamlining the assessment approach so it is more integrated, responsive and up to date would help ensure positive contributions to sustainable development are better identified.
  • The current sustainability criteria within SPP paragraph 54 are too imprecisely drafted to be used as criteria for assessing planning applications, although this is frequently what happens. They allow development where, for example, there is an option of public transport or walking/cycling but where, in reality, that is very unlikely to form a significant proportion of journeys.
  • Current SPP needs to be clarified as building in the green belt can be justified as supporting sustainable economic growth under current policy.
  • Given the number and breath of principles included under Sustainability in current SPP, and the fact that some development proposals will not meet all of these, if these are to remain, NPF4 should clarify what weighting should be applied to each principle at the development management stage.

There was also a call for NPF4 to include a specific policy setting out the need for the highest standards of sustainable design and construction. This should outline general principles to improve the environmental performance of developments and should also require all developments to produce a sustainability statement to demonstrate how such issues have been considered. The Mayor of London's Plan was cited as containing a good practice example of a sustainable design and construction policy,[38] and the supporting Sustainable Design and Construction Supplementary Guidance[39] as being well-regarded for promoting excellence in sustainable design standards.

Issues relating to the environmental performance of buildings are covered further at the Climate change theme.

Community engagement and empowerment

A number of respondents addressed the importance of community engagement, including that NPF4 should encourage and increase the opportunities for communities to be involved in and influence planning-related decisions. It was suggested that this approach could strengthen the relationship between the community and the local authority by developing partnerships and sharing power and decision-making.

In terms of who should be involved, comments included that it will be important to ensure that engagement is inclusive for all members of the public, including those who traditionally may be least likely to engage, but who are most likely to benefit from approaches to support quality of life, health and wellbeing. It was reported that many people living in poverty will not be able to take part in digital consultation and engagement, so thought needs to be given as to how to engage them.

For rural authorities, it was noted that digital infrastructure may be lacking in some rural locations and it will be important to ensure that some people are not disenfranchised as a result. It was also reported that certain age groups are not well-versed in using online platforms.

Other comments included that:

  • Community groups should be at the heart of community engagement.
  • Young people and children must be involved, and the debate should be inclusive and intergenerational. It was suggested that planning authorities must engage with children and young people on relevant planning matters, such as those that concern the design and development of public and private places likely to be used by children and young people for play, recreation, leisure, assembly and study. Further, it was suggested that it should be the responsibility of the planning authority to make appropriate links with schools, youth councils, support groups (such as young carers), local representatives of the Scottish Youth Parliament and other childhood professionals.

In terms of the areas of the planning system where community engagement was seen as key, suggestions included:

  • Developing LDPs, with ample opportunities to input into their development and revision.
  • Developing LPPs.
  • Setting targets for new homes and determining planning applications.
  • Consultation on national infrastructure.

A specific area of activity highlighted was the emergency-focused community resilience groups that exist in parts of Scotland, and it was suggested that engagement between groups such as these and local authorities needs to be placed on a more formal basis. It was suggested that giving such community groups guaranteed access to appropriate local authority fora, as required under the Community Empowerment (Scotland) Act 2015, especially in terms of planning and flood risk management, would be empowering and help ensure more effective and efficient deployment of local authority and community assets during and after emergencies. It was recommended that the important role community groups have to play in the planning process be recognised formally within NPF4.

Co-creation and partnership working between individuals, communities and businesses in developing green networks was also highlighted, with involvement of all stakeholders in developing and delivering solutions reported to enable local priorities and solutions to be tied to wider outcomes and to support increased understanding and buy-in.

In terms of the type of approach that should be promoted or required, it was suggested that early engagement with organisations working with communities, for example via the Scottish Community Development Centre, could support the embedding of the National Standards for Community Engagement in NPF4. Other comments included that:

  • It will be important to identify ways of streamlining access and understanding the wider range of expertise that exists to facilitate access. This includes public bodies, local authorities, and third-sector organisations.
  • There could be opportunities to share best-practise and collaboration between communities when creating community-led LPP.

Suggestions regarding the type of approach which could or should be taken included:

  • Taking an asset-based community development, co-production approach. It was proposed that the LPP process (covered further under the Placemaking theme) should provide a statutory framework for this to happen.
  • Embracing and normalising mini-publics, participatory budgeting and digital innovations such as online forums.
  • Citizen Assembly engagement, including on planning decisions.

It was suggested, however, that required approaches should not be too prescribed or specific, as different communities will engage in different ways and flexibility on how engagement is achieved should be given to the local authority.

It was also noted that community engagement work has resource and capacity issues for planning authorities and that communities with a high-level of engagement are often those who are individually well-resourced in terms of finance and time. Finding ways to engage those that have limited resources was suggested as a priority for NPF4.

Finally, it was suggested that relevant third sector organisations could play an impartial role in helping deliver the aims of NPF4, including through explaining planning processes, bringing different communities and stakeholders together, mediation, facilitating local communities to engage with their places, and promoting the involvement of young people and other seldom-heard groups.



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