Fourth National Planning Framework - position statement: consultation analysis
Independent analysis of the responses to our consultation paper on Scotland’s Fourth National Planning Framework Position Statement which ran from 26 November 2020 to 19 February 2021.
This summary sets out key themes arising from a consultation on the Position Statement on the Fourth National Planning Framework (NPF4) that was published in late November 2020. The Position Statement set out current thinking on the issues that will need to be addressed when preparing NPF4, making clear that the approach to producing NPF4 will continue to be a collaborative one, that no decisions have yet been made, and that the Scottish Government will continue to work with a wide range of stakeholders to develop the proposals over the coming months.
In total, 251 respondents made a submission. The majority of respondents (201) were organisations, with 50 individual members of the public also making a submission. The submissions received were very diverse, ranging from relatively brief statements through to very extensive responses commenting on all the key outcomes and many of the potential policy changes outlined in the Position Statement. Where consent has been given to publish the response, it can be accessed at National Planning Framework: Position Statement: Published responses.
A Plan for Scotland in 2050
The Position Statement explains that NPF4 will include national planning policies, providing a clear and coherent plan for future development and will have the status of development plan, informing day-to-day planning decisions. It will embed the UN Sustainable Development Goals and Scotland's national outcomes and will have the Place Principle as a key driver. The long-term strategy will be driven by the overarching goal of addressing climate change and is expected to focus on achieving four key outcomes: Net-Zero Emissions; Resilient Communities; A Wellbeing Economy; and Better, Greener Places.
There was broad support for:
- The general direction of NPF4 and the ambition for climate change to be the overarching priority.
- Embedding UN Sustainable Development Goals and Scotland's national outcomes.
- The four key outcomes set out in the Position Statement.
- Focus on the Place Principle.
Respondents also made a number of general points highlighting the importance of:
- Consistency of approach and of alignment of NPF4 with other plans, strategies and policies including the Climate Change Plan update, the Infrastructure Investment Plan, the National Islands Plan, the National Transport Strategy 2 (NTS2), the Land Use Strategy and Regional Spatial Strategies, and with city/growth deals.
- Collaborative working across policy delivery areas, including across planning and other sectors and statutory bodies.
There were general calls for use of stronger or more robust language setting out clear requirements rather than simply encouraging change. The need for resources was also an issue highlighted across a number of responses with financing, upskilling and enforcement of planning controls all identified as necessary for delivery.
Some respondents expected to see more on the response to COVID-19 in the Position Statement, for example with respect to new working patterns that may become established and on priorities for supporting the post-COVID recovery. It was argued that there must be a green recovery with the principle of net zero embedded at its core.
Respondents also highlighted what they would like to see as central approaches to NPF4 including that:
- The focus should be on its purpose as a land use planning document constituted as part of the statutory Development Plan.
- Climate change and biodiversity crises should have equal recognition. Although it was acknowledged that the Position Statement recognises climate and nature crises to be 'intrinsically linked' it was suggested there is little mention of the nature crisis or action to address it elsewhere in the document.
- A place-based approach should embed public health and wellbeing at the centre of climate change decision-making.
- Planning for waste management and the circular economy should form a key pillar of NPF4.
- Consideration should be given to opportunities that would be offered by a 'biodiversity net gain' policy approach' including mirroring 'natural capital' planning approaches adopted elsewhere in the UK.
There were also calls for greater involvement for communities in planning decisions and for the planning system to address a perception that, at present, developers can steer the process for their own benefits.
A Plan for Net-Zero Emissions
Prioritise emissions reduction: There was broad support for the focus on tackling issues relating to climate change and agreement that achieving net zero emissions should be the over-arching priority of the spatial strategy. It was observed that the short timescales mean it will be important that Scottish Planning Policy (SPP) can be implemented as quickly and easily as possible by Planning Authorities.
There was also support for the emphasis on renewables and for the focus on strategic levels of planning. It was agreed that an urgent and radical shift in policies will be needed, although a stronger commitment to the climate change priority was also thought to be necessary.
Integrating land use and transport: There was support for integrating land use and transport and a particular welcome for embedding the NTS2 sustainable travel hierarchy in NPF4. Respondents highlighted the high levels of carbon emissions from transport as a sector and, within this, the proportion generated by private cars. There was also support for directing development to locations that reduce the need to travel and are well served by sustainable transport options. Some respondents pointed to the need to understand limitations of the sustainable travel hierarchy in rural areas.
Facilitate design solutions and innovation: While there was strong support for retrofitting existing buildings to improve their energy efficiency, the scale of the challenge was also highlighted. There were calls for new development to be carbon neutral, energy efficient or built to Passivhaus principles and 'future-proofed' as far as possible. Facilitating development of networks for renewable and zero emission heating was supported and the importance of alignment of NPF4 with the forthcoming Heat in Buildings Strategy was highlighted.
Promote nature-based solutions: There was support for promoting nature-based solutions in respect of climate mitigation and also with respect to benefits to biodiversity, adaptation to flood risk and improved air quality. The role of nature-based solutions in cities was highlighted and it was suggested NPF4 should acknowledge that blue/green infrastructure solutions are also a form of nature-based solutions. Referring to use of vacant and derelict land in the context of nature-based solutions was proposed, and the role of greenbelt land in mitigation of climate change was highlighted.
Deliver infrastructure to reduce emissions: Respondents expressed support for the Infrastructure Investment Plan, including the priority given to enhancing existing assets over new build, and for updating the spatial framework for onshore wind. A number of respondents noted and welcomed the statement that it is expected "that NPF4 will confirm that the Global Climate Emergency should be a material consideration in considering applications for appropriately located renewable energy developments."
A Plan for Resilient Communities
Apply the concept of 20 minute neighbourhoods: This approach was described as an exciting and challenging opportunity to make local places the focus of people's lives. Many of the comments noted the connections between the 20 minute neighbourhood approach and other themes set out within the Position Statement, including in relation to reducing carbon emissions, infrastructure first and the use of vacant and derelict land. A number of comments addressed the challenges around delivering 20 minute neighbourhoods in a rural context. The difference between creating a new 20 minute neighbourhood and achieving 20 minute neighbourhoods within existing communities and developments was also highlighted.
Strengthen community resilience: There was support for the focus on the climate emergency and its impact on community resilience. Future-proofing the built environment was described as crucial to responding to the threat of climate change. The connection was also made between addressing surface water flooding and drainage and other themes covered in the Position Statement, for example in relation to blue/green infrastructure solutions and tackling vacant and derelict land.
Promote inclusion and equality and eliminate discrimination: There was support for efforts to strengthen public trust and involvement in the planning process, but also some concerns about whether or how this can be delivered. It was suggested that there is a lack of narrative about how the community involvement goals will be achieved. Local Place Plans were described as a welcome, community-driven approach to support place-based solutions.
Improve our health and wellbeing: There was support for putting the needs of people and their health and wellbeing at the heart of the planning system, and for the focus on the six Public Health Priorities. A number of respondents commented on the extent to which the COVID-19 pandemic has both shone a light on the importance of locality as a foundation of resilient communities and introduced additional pressures on the health and wellbeing of those communities.
Actively plan and support the delivery of good quality homes: Comments included broad support for NPF4 setting out a long term view of the homes required to meet Scotland's future needs. The references and connections to Housing to 2040 were also noted and welcomed.
There were two broad but interconnected themes running though many responses. One of these reflected the focus on the SPP and Housing consultation, and the specific policy proposals set out within the Position Statement in relation to housing land supply and Housing Land Audits. There was also a considerable focus on the ambition set out in the Position Statement that homes should be "accessible, affordable, well designed and energy-efficient with the right homes in the right places to support both urban and rural communities".
Promote an infrastructure-first approach to community development: There was support for taking an infrastructure-first approach, although it was also suggested that the approach needs to be more clearly defined. A number of the comments addressed the infrastructure-related implications of 20 minute neighbourhoods, both in terms of the range of services required and the implications for travel, and particularly active-travel related infrastructure. It was also suggested that detailed consideration of infrastructure and service provision should be central considerations for future land use decisions and development plans.
Enhance and expand natural infrastructure: A number of respondents noted the importance of natural (blue and green) infrastructure and its contribution to resilient communities. The recognition that the management and maintenance of natural infrastructure is essential was welcomed and there was support for nurturing and expanding natural networks, with greenspace described as critical social and physical infrastructure that provides essential services to people and the environment. As at other themes, some respondents noted how the COVID-19 pandemic has highlighted the health and wellbeing benefits of having access to good quality greenspace, but also on spatial inequalities across the country.
Achieve more sustainable travel: The focus on achieving more sustainable travel was welcomed, including refocusing policies to draw out how land use planning can build in sustainable travel choices. However, it was also noted that the principle of integrating land use and transport planning and reducing the need to travel have been embedded in transport and planning policy for a number of years. It was suggested that there needs to be a strengthening of the intent and definition around the principles set out. There were also a number of references to the importance of NPF4 aligning with NTS2 and the key role of NTS2 in providing the right infrastructure in the right place at the right time if the infrastructure-first approach is to be delivered.
A Plan for a Wellbeing Economy
Support a sustainable and green economic recovery: Many respondents expressed their support for this focus, and the role of NPF4 in supporting the transition to a net-zero, circular economy. There was also support for specific elements of the approach to a sustainable and green recovery as set out by the Position Statement, including a spatial strategy targeting investment in areas and sectors where jobs and investment are needed most, and which can help to deliver wider economic and environmental targets. Some respondents suggested more linkages with the 'plan for net-zero emissions'.
Reduce inequality and improve health and wellbeing: There was support for NPF4 having a role to play, including through helping deliver jobs in the right sectors and right places. There was a view that NPF4 provides an opportunity to address negative health and wellbeing impacts in some places, and to create more places which support good health and wellbeing. Respondents also saw a role for NPF4 in ensuring the move to a wellbeing economy is delivered in a fair way, with a framework for economic development aligned with public health principles and committed to tackling health inequalities.
Provide certainty and flexibility to encourage investment: It was seen as important that NPF4 strikes the right balance between the certainty of a plan-led system, and the flexibility required to respond to social and economic change. Respondents also referred to a number of specific sectors seen as having potential to contribute to government objectives, and where there was a perceived need for NPF4 to do more to encourage investment. These included renewable energy, ports, transport infrastructure, aquaculture, and recycling and waste management.
Grow our food and drink sector: Some respondents expressed their support for the priority assigned to growing Scotland's food and drink sector. This included a focus on the economic significance of the sector, particularly for rural and island communities. Some respondents raised concerns about proposed support for the aquaculture sector. However, others suggested that the aquaculture sector has been changing rapidly in recent years and wished to ensure that NPF4 is based on an accurate picture of the sector and its current environmental impact. The extent to which sustainable growth in the aquaculture industry is important in tackling the challenges facing rural and island communities was also highlighted.
Support sustainable tourism development: There was support for the focus on enabling sustainable tourism development and for the commitment to building on investment through the Rural Tourism Infrastructure Fund. The economic significance of tourism at national and regional levels was noted, with references to a particular need to support recovery following the COVID-19 pandemic. Respondents also expressed specific support for the need to strike a balance between providing the infrastructure required to support tourism, while protecting the interests of local communities and minimising environmental impacts.
Stimulate culture and the creative industries: There was support for a stronger focus on culture and the creative industries. This included a particular focus on the potential contribution of these industries to health and wellbeing and as a significant economic sector, with potential to support regeneration of deprived areas. Some respondents also expressed a view that a wellbeing economy requires a stronger role for communities, for example through community businesses and social enterprises.
Transition to a circular economy: Reference to the circular economy was welcomed, including in relation to wider climate change policy priorities and to support economic recovery. There was also support for recognition of a role for the existing built environment and of opportunities for existing and new economic sectors to respond to the transition to a zero carbon Scotland. The effect of the COVID-19 pandemic in hampering progress on elements of the circular economy (for example through reintroduction of single use plastics) was noted and it was argued NPF4 should seek to protect and build on progress made prior to the pandemic.
Promote sustainable resource management: In relation to peatland, there was support for the reference to preservation and restoration, and in particular the proposed restriction of further development on peatland to ensure its role in carbon sequestration. However, respondents also highlighted potential tensions between preservation of peatland and other aspects of NPF4, including concerns around a 'blanket ban' on development on peatland. There were calls for NPF4 to set out a clear policy framework for how planning authorities should weigh the relative benefits of peatland preservation against renewable energy or other developments that can offer net carbon benefits.
Secure strategic transport connectivity: There was support for interventions to manage demand for car use, with respondents seeing potential links between managing demand for car use and other NPF4 priorities such as achieving net-zero emission targets and promoting inclusion and equality. However, it was suggested that significant work and investment will be required to achieve the required shift away from car use, particularly outwith urban centres. There was also support for improved transport connectivity to reduce emissions associated with freight.
Improve digital connectivity: Respondents expressed their general support for the inclusion of improved digital connectivity as a priority for NPF4, including noting its importance in enabling more home-working and reducing travel. The increase in home-working during the COVID-19 pandemic was suggested to have reinforced the importance of access to digital connectivity for all, not only in terms of home-working but also communication and access to services. However, it was also suggested that the COVID-19 pandemic has highlighted the inequality of access to high quality digital connectivity in Scotland.
A Plan for Better, Greener Places
The Place Principle and spatial planning: A number of respondents expressed support for the application of the Place Principle, which was described as a step-change in how planning can look holistically at areas at various spatial scales. In terms of delivering effective placemaking, comments and suggestions included that NPF4 should seek to align spatial planning with assessments of the capacity of places to accommodate new growth and ensure that neighbourhood and place planning are not focussed solely on the provision of new assets which will require funding. However, it was also suggested that a place-based approach should not become too focused on existing assets as a context. It should also identify truly new outcomes and seek to catalyse long term change that addresses social challenges.
Achieve higher quality design: Comments included that improving the quality of design of new development should be a fundamental outcome for the planning process. However, it was also suggested that design should not be seen as 'separate', as it is fundamental to achieving positive outcomes in many other policy areas. In terms of how NPF4 could further support high quality design, suggestions included that a stronger policy direction on the design of places - and incorporating nature based solutions - should be a priority.
Re-imagine city and town centres: There was support for a new approach to town and city centres, recognising the need for these places to be revitalised to create attractive and vibrant places, and the contribution that they can make to wider climate change and economic objectives. Respondents expressed specific support for the "town centre first" policy and links were made to the concept of 20 minute neighbourhoods. Some respondents reflected on the degree of change required of town and city centres, including reference to changing shopping habits and the growth in home-working. A need for funding and investment to achieve the required change was suggested, as was a focus on stabilising the decline of town centres before looking at significant changes in character or use.
Re-use vacant and derelict land and empty buildings: A number of respondents offered their support for NPF4 having a focus on reuse, including recognising the opportunities for re-development. This included specific support for a "brownfield first" approach prioritising re-use of brownfield sites over greenfield development, for the review of green belt policy and for potential expansion of land assembly and compulsory purchase. Respondents also noted the importance of these proposals in terms of reducing development pressure on valuable green spaces, supporting delivery of climate change and other environmental objectives and revitalising town and city centres. Some wished to see NPF4 set out stronger measures to limit greenfield development, although others argued against prioritisation of brownfield over greenfield development, suggesting that releasing greenfield land for development as part of a planned national strategy could help to contribute to economic and environmental targets.
Actively promote working and living in rural Scotland and the islands: There was particular support for the focus on rural repopulation and for links to land use and other policies and strategies including the National Islands Plan, the Land Use Strategy and Rural Planning to 2050. Some respondents wished to see NPF4 set out more detail on policies for rural development, and that this should recognise that rural and island communities are very varied in terms of the scale and type of development that may be sustainable. The need to ensure that development is supported by sustainable infrastructure, including transport and digital connectivity was also highlighted.
Protect and restore Scotland's natural environment: There was support for strengthening the approach to protecting and restoring the natural environment and for the focus on biodiversity which, it was argued, should be central to decision making throughout the planning process. In addition to protecting existing habitats, it was suggested NPF4 should incorporate policies that make nature recovery a consideration in every planning decision. It was also argued that SPP should support the new Scottish Biodiversity Strategy.
The safeguarding and promotion of forestry, environmentally significant locations and green or blue corridors was welcomed, although it was also suggested consideration should be given to incorporating the concept of 'natural capital', including as a funding tool and economic lever to meet objectives of nature conservation and growth. However, concern was expressed that any application of natural capital approaches must make clear what is expected of everyone involved in the development process.
Protect and enhance our historic buildings and places: There was support for the intention to protect and enhance historic buildings and places, although also an observation that the historic environment is not just buildings and places as Scotland's landscapes – including wild land areas - are largely a product of human activity over time. It was also suggested that the Position Statement should acknowledge that the historic environment is a finite resource which cannot be replaced and should place increased emphasis on facilitating the acquisition and re-use of neglected historic buildings to secure their long-term future.
Adapt our coastline to the impacts of climate change: The potential impact of coastal erosion was highlighted, and it was reported that the Dynamic Coast project is providing case studies that include developing adaptation plans for vulnerable stretches of coast. It was also suggested there could be an opportunity for NPF4 to embed marine and coastal planning in the planning system more strongly and to articulate how and where nature-based solutions could apply, in light of funding for flood risk management and coastal change adaptation announced in the Programme for Government of September 2020. Adapting communities to flood risk and coastal change was noted to have significant resource implications.
General comments included that delivery mechanisms to implement NPF4 will need to be robust and innovative and be supported by collaborative partnership working. It was suggested that it will be important that Planning, and specifically Chief Planning Officers, are represented at the highest local authority level to help enable delivery of NPF4.
There were also calls for the delivery programme to be co-produced with local authorities and Key Agencies and for a more cross sectoral approach to both development and delivery of the strategy. It was suggested that wider aspirations, such as the Place Principle, 20 minute neighbourhoods and a wellbeing economy, may be better achieved by looking beyond Planning alone. Support for local authorities in the form of a national delivery agency was also proposed.
Suggestions with respect to funding included that delivery must have resources and costs at its heart and that, ideally, a fully funded delivery strategy should be delivered in tandem with NPF4. A structure for signposting to, and co-ordinating with investment strategies that are led by other interested parties (including public and private bodies) would be helpful; this could advise where investment should be directed, from which sources and for what purposes.
The need for defined timescales and priorities for delivery were also suggested. To allow for better understanding of timeframes for progressing the work, information on the timing of suggested policy changes outlined in the Position Statement was requested. It was also argued that monitoring the impact and outcomes of planning policy should be an integral part of the system. The need for transparency was also highlighted, including publishing performance data and progress reports.
Among other comments on the Position Statement there was a request that, in light of the delays to NPF4, interim policy guidance on renewable energy developments should be issued. It was suggested there should be immediate guidance on the planning balance being tilted in favour of the climate emergency, which should be a material consideration in all planning decisions or should be given significant weighting or "special regard".
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