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RTPI Scotland's response to the Call for Ideas on Planning System Ambitions

RTPI Scotland's response to the Improvement Service's Call for Ideas on Planning System Ambitions.

The Call for Ideas was made by Craig McLaren, Scotland's new National Planning Improvement Champion, and the former Director of RTPI Scotland. The RTPI response has been formed in conjunction with inputs from RTPI Scotland's Policy Sub-Committee.

You can view the Call for Ideas here.

You can view the PDF version of the submitted response here.

Question 1: What are the outcomes we need the planning system to deliver to have impact?

For the planning system to deliver the outcomes that we need to have an impact, it is vital that we look beyond planning as a process. Planning is more than a reactionary system delivered on an application-by-application basis, and planners are more than just the administrative gatekeepers of this system and, consequently, of the built environment.

As set out in the RTPI’s Planifesto, planners across the public, private and third sectors are “catalysts of change and champions of sustainable development. We develop policy and plans that help residents and businesses to thrive, we bring the voice of local people into decisions about their area and we constantly strive to tackle the most pressing economic, social and environmental challenges.”

For the planning system to have meaningful impact, it must achieve the following outcomes:

Reinforce (not reinvent) Existing Outcomes

Why is this important?

The outcomes we need the planning system to deliver are already set out in existing legislation, policy, frameworks and guidance including:
• The Planning (Scotland) Act 2019
• The National Performance Framework and associated National Outcomes
• The National Planning Framework 4
• The UN Sustainable Development Goals
The Planning (Scotland) Act 2019 introduced a new purpose of planning “to manage the development and use of land in the long term public interest”. RTPI Scotland were strong advocates for this purpose to be embedded into the legislation, which places the “long-term public interest” as the principal outcome of the planning system.

This new purpose of planning does not sit in isolation. Section 3ZA(2) of the amended Town and Country Planning (Scotland) Act 1997 states that anything which “contributes to sustainable development or achieves the national outcomes…is considered as being in the long term public interest”.

The National Outcomes cover a broad range of ambitions spanning across the social, economic, environmental, and cultural spectrums. The planning system has the potential to contribute towards all of the National Outcomes both directly and indirectly as a result of its role in shaping places. This is recognised within Scotland’s Fourth National Planning Framework, which describes the planning system as a delivery mechanism for both Scotland’s National Outcomes as well as the UN SDGs. The spatial principles, cross-cutting outcomes, and National Planning Policies are the ways in which NPF4 seeks to support delivery of the National Outcomes and UN SDGs and, consequently, to achieve the purpose of planning set out in the Act.

Consequently, we do not need to reinvent the wheel. For the planning system to deliver positive impact, we need to ensure that it reinforces the outcomes already set out.

To achieve this, it is vital that planners have access to the necessary guidance, tools, and skills they require to deliver balanced decisions with confidence and conviction.

The Perception of Planning – shifting the rhetoric from planning as a barrier to a solution

Planning is so often perceived as a barrier to development and to progress, rather than as part of the solution to tackling the economic, social and environmental challenges that society currently faces.

For planning to have the required impact, we need a shift in the rhetoric around planning and planners.

The RTPI has recently launched the “It Takes Planner &” campaign, to raise awareness of the pivotal role planners play in creating liveable and healthy communities, and to tackle misinformation about the planning system and the profession. For this campaign to have wide reaching impact, and to achieve the necessary shift in the perception of planning, it will take a whole-of-the-profession approach, and beyond. There is a role for the National Planning Improvement Champion to play, working with local authorities, to not only assist them in monitoring and improving their performance, but to also ensure that the monitoring process and associated outcomes are transparent, public-facing, collaborative, and responsive to local communities and businesses.

Quality of Place Outcomes

There has been a tendency in the past to consider “outcomes” through a narrow lens of the physical and tangible, which can be easily counted and used to demonstrate (through numerical evidence) success, or otherwise. Whilst physical and numerical outcomes, such as housing numbers, completed infrastructure projects etc. are important, existence does not automatically mean quality. Without quality, we will not achieve the outcomes set out in the National Performance Framework, UN SDGs, NPF4, or the purpose of planning in the Town and Country Planning (Scotland) Act, which are vital to the health and wellbeing of Scotland’s communities.

It is important, therefore, that we assess the planning system’s effectiveness on the quality of the outcomes delivered.

Stakeholder & Community Experience Outcomes

In addition to physical outcomes in the form of housing, infrastructure, services etc. we also need to ensure positive outcomes with respect to user and stakeholder interaction with the planning system.

This includes outcomes related to:
• Access to information and advice about the planning system and associated services.
• The ease by which communities can engage in the plan-making process.
• Clear and consistent communication and discourse between local planning authorities and communities, developers and other key stakeholders.

In the above regard, we note that NPF4 includes the cross-cutting outcome of ‘a fair and inclusive planning system’, which acknowledges that opportunities exist to engage in development planning and decision-making, but that “experience shows that some people can find it more challenging to engage with planning”, and that any engagement undertaken “should be early, collaborative, meaningful and proportionate”.

Outcomes for the Planning Profession

We also need to ensure that the planning system impacts positively on the individuals and organisations responsible for keeping it up and running – i.e. the planning profession itself.

The Big Conversation study recently undertaken by RTPI Cymru sought to understand the wellbeing of planners in Wales. The study found that increased pressures on the profession have led to a concerning impact on planners’ wellbeing, with 61% of respondents reporting being overstretched
at least several times a week and 21% reporting feeling overstretched all of the time. Reasons for this included:
• Increased workloads
• Reduced capacity due to challenges around the recruitment and retention of staff
• Uncompetitive salaries
• Lack of training and professional and specialised development opportunities within local planning authorities.
• Public misinformation leading to complaints and criticisms that can often become vitriolic and personal.

Whilst the majority of respondents considered that they did have the support of their employer, only a third of Development Management Planners and Enforcement Officers who responded to The Big Conversation survey believed they had the right support.

Similar results were reported in the Big Conversation study undertaken by RTPI NI.

Planners (and the organisation in which they work) need to have the right support, tools, and training to enable them to do their job efficiently, effectively, and with confidence and conviction. This is vital to ensuring the continued strength of, and attracting new and talented individuals to, the planning profession.

Outcomes Beyond the Planning System

In addition to the above, it is also important to acknowledge that the planning system does not (and must not) operate in isolation. There are a wide range of factors, external to the planning system, that impact upon its ability to deliver positive impacts. One example of this is our transition to net zero. This is a strong policy outcome of NPF4, but it’s delivery also relies heavily upon energy companies, the national grid, and transport operators (to name just a few).

The planning system must operate in collaboration and in unison with these external partners in order to achieve maximum impact.

Question 2: What makes a high-performing planning authority?

Planning authorities’ performance is often assessed by the speed they carry out their functions. However, speed does not automatically mean high performance. It is vital, therefore, that we do not conflate the two. Whilst speed can be an outcome of a high performing planning system, it can equally be a symptom of poor performance if it does not achieve the high quality and intangible outcomes referred to in our response to the previous question.

Instead, RTPI Scotland believes that for planning authorities to be high performing, they must be able to demonstrate the following:

Strong Leadership

Strong leadership is key to a high performing planning authority. RTPI Scotland were strong advocates for the introduction of Chief Planning Officers into every local planning authority. Our 2021 CPO Thinkpiece sets out the roles and responsibilities we believe CPOs need to have to achieve the required impact on the planning system, its position at the corporate table of local authorities, enhanced planning authority performance, and cross-departmental and cross-sectoral interaction and integration to achieve a joined-up, collaborative and participative approach to services and delivery.

These roles and responsibilities include:
• Planning adviser – to provide advice to the local authority as a whole on the spatial and place-based implications of decisions and investments in the short-, medium-, and long-terms.
• Placemaking champion – to champion and operationalise the Place Principle, 20-minute Neighbourhoods, The Town Centre Frist Principle etc. at the corporate level of local authorities.
• Head of the profession – to act as the lead planning professional in the organisation and manager of planning services.
• Point of contact – for the public, Scottish Government and its key agencies, councillors, and scrutiny organisations such as Audit Scotland and the Scottish Public Services Ombudsman

Community Partnership Approach to Planning

Communities are critical stakeholders in the delivery of the Local Development Plan. An LDP that has community buy-in will be less likely to attract community objections to applications that facilitate its delivery. How planning authorities engage with communities and other key stakeholders throughout and following the plan-making process is therefore important to ensure its successful delivery.

For the community to be productive delivery partners of the LDP, they must also be productive partners in its creation facilitated by local planning authority engagement practices. Not all engagement practices are equal. Therefore, high performance is not simply about the act of engaging, but about the quality of those engagements which must be deliberative and inclusive with a focus on mutual learning and collaboration to build consensus and trust.

Best Practice Employer

For planning authorities to be high performing, they must act as best practice employers to the staff who are responsible for efficiently, effectively and collaboratively delivering the planning service in a joined up and participatory way.

As previously mentioned, The Big Conversation study recently undertaken by RTPI Cymru and RTPI NI found that increased pressures on the profession have led to a concerning impact on planners’ wellbeing.

Although the studies undertaken reveal that many challenges faced by planners are due to a range of external pressures beyond the direct control of planning authorities, for planning authorities to be high performing it is critical that employee wellbeing be a top priority. This can begin through employer processes, such as regular staff “health checks” and support mechanisms to enable planning authorities to have a continual and up-to-date picture of employee wellbeing, overall morale, and the impact of work-related pressures. By understanding the state of staff wellbeing, planning authorities as employers can begin to develop agile coping and resilience strategies and mechanisms (such as intelligent workload management support systems) that can adapt to the needs of their employees.

As part of this, it is also important that planning authorities embed a proactive and productive learning and knowledge sharing environment. This will result in the creation of a nurturing space where positive outcomes can be celebrated and professional development needs met. Embedding constructive working approaches is also important, enabling teams to identify areas for improvement and evaluate different approaches and ways of working.

Access to Knowledge, Skills and Training

Planning authorities have a broad role that far exceeds the narrow structural scope of their defined duties within the planning system – i.e. Development Management, Development Planning, and Planning Enforcement. Planners are uniquely placed to balance a range of competing objectives within the built environment, as well as to bring together and to reconcile local community, developer, business, and other stakeholder aspirations to achieve the defined purpose of planning set out in the Act. The skills required to undertake this role efficiently and effectively range from communication, analytical and team working skills, to a broad range of technical knowledge on such topics as urban design, floodwater management, carbon and climate impacts, biodiversity restoration and habitat protection (to name just a few).

For planning authorities to be considered high performing, they must look beyond the number of applications assessed, the number of planning enforcement cases dealt with, or the speed at which they can carry out their duties. They must also ensure that planning officers have access to the knowledge, skills and training required to deliver their functions in a way that achieves quality, holistic, and place-based outcomes.

Resourcing Strategy

The above cannot be accomplished without the necessary resources in place to support the planning system and profession.

Research undertaken in 2022 by RTPI Scotland into resourcing of the planning service revealed that:

• Gross expenditure to planning authorities has diminished in real terms by 38% since 2010
• There have been 25% staffing cuts in planning departments since 2010
• Planning application fees only cover 66% of their processing costs
• There are 91 new and unfunded duties in the Planning (Scotland) Act which could cost between £12.1m and £59.1m over 10 years.
• Only around 8% of staff in planning authorities are under 30, with an estimated demand of around 700 planners over the next 15 years.
The 2023 update to this resourcing research (due to be published in December 2023) reveals that:
• Planning expenditure has continued to decline, being the only local authority service to see a reduction in funding on a national level between 2021-2022.
• The national planning department workforce is at its lowest level in five years, and on a gradual trend of decline, having fallen 23% between 2013 and 2022.
• Approximately 150 students graduated from Scotland’s accredited planning schools in 2022. Research undertaken by Partners in Planning (2021) indicates that between 2012/13 and 2016/17, around 68% of graduates in Scotland went into UK work. Assuming this remains an accurate reflection, 70%-75% of this proportion would be required to work in Scotland to meet the projected planning workforce demand over the next 10-15 years.

For local planning authorities to achieve high levels of performance it is imperative that they have a proper resourcing strategy in place to understand their requirements in terms of staff, training, and digital tools and how this sits within the corporate business plan of the authority as-a-whole and available departmental budgets. As well as budgetary considerations, the resourcing strategy should also consider the skills, tools, and knowledge currently available to make the best use of what local authorities already have at their disposal, and the potential for cross-departmental and cross-sectoral joint and collaborative working practices to be implemented.

Question 3: How can we measure this?

Outcome and performance monitoring is key to understanding the effectiveness of local planning authority processes and ways of working in delivering planning system outcomes. But, before we can address the question of “how” we can measure, we first need to address the question of “what” we need to measure.

RTPI Scotland believes that monitoring needs to take a whole-system approach that looks beyond simple numerical metrics of (for example) housing units delivered, towards the wider cumulative place-based and systemic outcomes of planning and the quality of these outcomes in delivering wider social, environmental, and economic benefits.

Cumulative impacts of planning

This is vital to achieve the quality of place outcome noted in our response to question 1.

Not only should we be measuring the number of applications assessed and houses built, we should also be measuring what local authorities have (through the planning system) been able to protect, preserve and enhance (e.g. areas of habitat and biodiversity restoration, protection of historic buildings, reduced emissions, improved air quality, public realm improvement projects and walkable neighbourhoods etc.) and the longer-term impacts on, for example, biodiversity and climate adaptation and resilience.

Economic impacts of planning - direct and indirect

Planning fees represents only a fraction of the income generated through the planning system. Through the planning system we can help to create the places where people want to live, work, relax and invest. This has wide-ranging economic (as well as social and environmental) implications, both direct and indirect, which are not necessarily captured by current monitoring practices.

These include (but are not limited to):
• The added value generated through developer contributions.
• Community benefit funds created through wind farm development projects.
• The additional council tax and business rates that are generated from completed developments that required planning approval.

For a clear picture of the planning system’s value in generating economic growth for local authorities and their communities, monitoring practices must begin to capture the income generated as a direct and indirect consequence of the planning system.

Stakeholder and community experiences

To achieve the related stakeholder and community experience outcome under Question 1, it is critical for planning authorities to include this as part of their performance review and monitoring processes.

This should not just be diluted down to the number of complaints received, but also enable positive experiences and constructive criticisms to be documented from developers and other key stakeholders.

It should also include the critical assessment of engagement practices that have been undertaken to ensure they are effective in delivering the cross-cutting outcome of ‘a fair and inclusive planning system’ in NPF4.

This should include:
• Who has been engaged
• The frequency of those engagements (understanding that quantity does not automatically mean quality)
• The purpose of the engagement exercise and the ability of the data obtained through the engagement exercise to inform other areas beyond its immediate purpose
• The format of engagement (i.e. surveys, workshops etc.)

Planner wellbeing

Related to our point under Question 2, for a planning authority to be high performing they need to also act as best practice employers and monitor the wellbeing and stress levels of their staff to ensure the right support mechanisms are in place.

 

Moving onto the question of “how”, we would like to make the following remarks:


• The Future of Planning Performance Frameworks (PPFs)


The PPF is a useful tool that has enabled local planning authorities to self-reflect on their performance and progress over the preceding year. We believe there is scope to reimagine this tool so that it can provide a useful method to measure the performance of local planning authorities in a more consistent way addressing the points raised above.

In addition, we believe there is scope to evaluate the wider visibility of PPFs, including their usefulness and meaningfulness to the public. This relates to the point identified under Question 2 about a partnership approach to planning. There is potential for the PPF to be used to enhance public communication about the value of planning. For example, from the data collected in the PPF planning authorities could create a ‘year in numbers’ infographic that could be included in email footers, on bus stops etc. to encourage wider engagement in, and understanding of, the planning system.

Notwithstanding the above, it is important that this tool does not become an exercise in ranking local planning authorities one against the other which could set them back in making meaningful progress.


• The Important Role of Data and Digital Tools


Digital tools have an important role to play in how we measure and assess impact, outcomes and performance. Critical to this will be ensuring that the collection and collation of data is consistent across Scotland and between local authorities so that it can provide a whole-nation picture of our progress. Also critical is ensuring that the digital tools we have available do not sit in silos and that they can effectively interact and work in an integrated manner to help us achieve our planning system outcomes and ambitions.

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