RTPI Scotland's response to Net Zero, Energy and Transport Committee inquiry

Council planning, decision-making and capacity in relation to net zero

1. How effective are councils at strategic planning, budgeting, and making procurement decisions that align with net zero goals? If there are barriers, what are they?

As addressed throughout this response, RTPI Scotland believes planning is a fundamental lever of local government to help meet net zero targets. However, in the past ten years planning departments have seen continual disinvestment, being one of the hardest cut local government services. Recent research from RTPI Scotland^[1] has shown that:

• Nearly a third of planning department staff have been cut since 2009
• Planning authorities’ budgets have diminished in real terms by 42% since 2009
• In 2020 local authorities only spent 0.38% of their total net revenue budgets on planning
• 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
• Over the next 10 to 15 years there will be a demand for an additional 680 to 730 entrants into the sector

In order for the councils to achieve a locally driven, placed-based response to climate change there is a severe need for planning authorities to be financed effectively. RTPI Scotland understand that planning fees are due to be increased as a means of bringing much needed resource into the planning service.  Whilst we welcome any additional resource, as set out in recently published research^[2] the Institute does not believe this fee increase will bring in the appropriate amount of resource necessary for the planning system to undertake its statutory duties and we are concerned that any potential increase in income from planning fees received by local authorities may not necessarily be reinvested into the planning system.

2. What role can the local government planning system and local development plans do to help us reach net zero? Could the planning system do more?

Planning, planners and the planning system can support our drive towards net zero targets in a multitude of ways through:

• Identifying, developing and approving suitable renewable energy developments at a strategic and local level whilst integrating and empowering key stakeholders such as local communities to deliver low carbon, resilient and affordable energy networks.
• Designing and locating new development to maximise accessibility by public, active and shared modes of transport. Patterns of housing and commercial development must support urban regeneration and renewal, and provide levels of patronage which support the recovery of public and shared transport providers, rather than diverting public funds towards the expansion of the road network to accommodate car use.
• Reduce the need for travel by promoting local living through the 20-minute neighbourhood concept.
• Integrating temporary measures to enable walking and cycling into wider strategies for place, locking in long-term shifts in travel behaviour. This will require multidisciplinary place-based teams which can integrate active travel measures with plans for high street regeneration, green infrastructure, new car-free residential and commercial developments, electric vehicle charging points and last-mile deliveries.
• Engaging with communities and businesses to ensure that changes meet a range of mobility needs. This should include groups which promote diversity and equality in walking and cycling, including in more rural areas.
• Collaborating on temporary measures to support sustainable mobility in car-dependent locations. Provide evidence on locations where ongoing subsidy will be required to maintain levels of public transport coverage and frequency, or initiatives to provide access to active and shared mobility options, such as like electric bikes.
• Embedding ‘climate justice’ in plan-making. Strong climate mitigation and adaptation policies are required to achieve net zero carbon and increase resilience to environmental risks. These policies must be designed to support the most vulnerable in society, integrated with the measures outlined above.
• Improving the quality of existing homes and neighbourhoods. The focus of planning on new build supply must be complemented with efforts to improve existing housing stock. Much-needed investment in energy efficiency retrofit should be linked to masterplans which regenerate deprived areas, protecting the rights of existing residents, and improving access to jobs, services, amenities and infrastructure.
• Deliver high quality and affordable housing in the right locations. Significant growth should be mixed use and targeted on brownfield sites which support wider regeneration efforts. Housing should come from a more diverse range of providers, including SME’s, housing associations, local authorities and the custom and self-build sector, with clear design standards for space, light and thermal efficiency.
• Improving access to green spaces. Parks, public gardens and other open spaces should be integrated into strategic plans for critical green and blue infrastructure. These should improve quality, scale and accessibility of green spaces, especially in areas of deprivation, while delivering multifunctional benefits such as flood mitigation, cooling, air quality, active travel, biodiversity gains, habitat creation and space for urban agriculture.

Achieving the net zero carbon targets – and recovering from the current situation regarding Covid-19 - shows the need to change how we work and the need to plan, prepare and provide a routemap for a different Scotland.  There is a need to agree that we need a new normal and how we achieve this. We need to embed resilience into how our cities, towns, villages and neighbourhoods function and develop over time. This needs to embrace risk in a more positive and constructive way. To make this change RTPI Scotland is of the view that there is a need to undertake the following shifts:

• from short term thinking to long-, medium- and short- term thinking
• from having many overlapping and disjointed strategies to complementarity
• from an opportunistic, reactive approach to development to a planned, proactive approach
• from economic priorities to holistic priorities covering environmental, social and economic issues
• from a competitive investment approach to one of managed investment
• from a deal-making approach to one based on providing a place vision first
• from short-term, project focussed investment to a planned long term holistic vision

RTPI Scotland are pleased to see that the crucial role of planning in supporting the shift to a net zero society has been fully recognised in the recently published draft NPF4, with amongst many new and expanded policies, a new requirement in the draft NPF4 to give significant weight to the Global Climate Emergency in plans and decisions. RTPI Scotland are also aware of the current consultation for draft regulations and guidance relating to the preparation of Local Development Plans. We will be responding to this consultation in full in due course and expect there to be a strong links made between development planning and achieving net zero ambitions.

3. What innovation, skills and capacity are needed in the local government workforce when it comes to making net zero achievable? Does that capacity exist or are there gaps?

RTPI Scotland would like to reiterate the clear capacity and resourcing issues currently being experienced in planning departments as set out in response to Q1. Moreover, in our response to the Local Government, Housing and Planning Committee’s call for evidence[3] regarding the draft NPF4 we highlighted a number of training requirements to support planners dealing with new assessments and duties, including the provision of detailed guidance where necessary. This includes the need to improve planner’s climate literacy on matters such as new duties such as scrutinising carbon lifecycle assessments. This could be achieved through providing training and publication of guidance and an assessment template to explain how the assessment of carbon emissions should be approached and presented.

To address our concerns regarding additional resourcing and skills requirements resulting from the draft NPF4 we have called upon Scottish Government to publish a comprehensive resource and skills strategy as a part of the delivery programme. The intention of such a strategy would be to apply a cohesive and holistic approach to resourcing delivery, including through ensuring a secure pipeline of planners necessary to process applications and produce Local Development Plans but also make sure they have the skills and knowledge needed to support the new system.

In terms of innovation to support planning departments RTPI Scotland wish to highlight the opportunities emerging from the Scottish Government Digital Planning Strategy. RTPI Scotland has undertaken research on behalf of Scottish Government on this matter. The Benefits of Investing in a Digital Planning Service research series sets out the economic and societal benefits arising from digital transformation; efficiencies that accrue within the planning system from investment in new technology and validation of the estimated cost and time savings; and the costs (financial and other) of not taking forward digital approaches across the planning service.  It includes an economic impact analysis^[4], a user and customer impact analysis^[5] setting out the benefits for planning authorities, planning applicants and communities and a policy impact analysis^[6] setting out the range of policy ambitions that rely upon a digital planning service, including addressing net zero carbon ambitions.

Partnering to achieve net zero goals

4. How well do councils leverage in support and finance from the private sector for net zero delivery? Are City Region Deals being used effectively for this? What mechanisms or forums are there for sharing opportunities and good practice?

Typically, larger local authorities, with greater access to resources are more easily able to unlock investment and deliver low carbon projects through the work of dedicated teams within their organisational structures. However, many authorities do not currently have sufficient internal capacity and skills in net zero related sectors.

RTPI Scotland believes there is significant opportunity to better co-ordinate transport and infrastructure planning and investment at a regional level to support net zero ambtitions. Beyond unlocking economic growth, with the correct implementation, City Deals and Regional Economic Partnerships should also generate a wide array of social and environmental benefits for the country. If City Region Deals are to provide this transformational change for our communities they need to be part of a strategy that integrates approaches to economic, social and environmental issues, including addressing net zero carbon ambitions. To do so they need to recognise how a range of investments across the region can complement one another and bring mutual benefit and look beyond the immediate to ensure that investments bring sustainable and lasting benefits in the longer term.  They cannot be a list of individual projects and initiatives sitting in isolation. To unlock this transformational change, integration and alignment with other national and regional strategies will be essential. These include:

• Emerging Regional Spatial Strategies
• Regional Economic Partnerships
• National Planning Framework 4 (NPF4)
• National Transport Strategy
• National Economic Strategy
• National Energy Strategy
• National Marine Plan
• Land Use Strategy
• Historic Environment Strategy
• Fairer Scotland Action Plan
• National Waste Management Plan
• Regional Transport Partnerships

Currently the measure of the success of investments from City Region Deals is based upon their contribution to GVA.  We believe that a more holistic approach is required if the City Region Deals are to deliver transformational change and this must mean that environmental and social benefits are also aimed for.

5. How well do councils partner with the voluntary sector and social enterprises to work towards net zero goals? Are there instances of good practice you can point to or areas where opportunities are being missed?

No comment.

6. How do councils involve local communities in decision-making on major net zero projects and how do they support community-led initiatives?

Planners hold a fundamental role in engaging communities on the future development of their areas. This is especially important in preparing Local Development Plans where communities can look at and discuss the types of developments deemed to be acceptable, where they should be, and the infrastructure needed to support them.

However, the Institute would like to stress that successfully undertaking proactive, collaborative and meaningful community engagement is a highly resource intensive statutory function and therefore careful consideration is needed as to how planning authorities can be effectively resourced to do so. RTPI Scotland believe there is a clear opportunity for enhancing public engagement through emerging Local Place Plans (LPPs). LPPs will help planners to communicate strategic overarching considerations and allow communities to plan priorities for net zero interventions, conveying detailed local understanding. Planners can in turn bring the vital links to other departments, agendas and organisations that help to navigate the system and turn community aspirations into reality. For LPPs to succeed there needs to be funding set aside to support communities to develop them. There is currently no designated funding in place to support them to do this, although their success may well depend on this. It has been estimated that each LPP could cost between £10,000 - £30,000 each^[7].

Role of the Scottish Government and its agencies

7. What is the Scottish Government doing to help the local government sector deliver on net zero goals? What, if anything, could it do more of to help the sector?

As discussed in Q1 and Q2 RTPI Scotland believes that Scottish Government needs to ensure planning departments are effectively resourced to undertake their statutory functions. Beyond this a clear and strong policy framework alongside detailed guidance is needed to improve the confidence of decision makers in submitting and determining applications that fully consider net zero aspirations.

One opportunity to ensure better cross-departmental working is presented through the Place Principle. The Scottish Government and COSLA have agreed to adopt the Place Principle to help overcome organisational and sectoral boundaries. This includes improving coordination between stakeholders, enhancing collaboration and communication across local authorities departments, key agencies, NGOs and private sector. The principle requests that all those responsible for providing services and looking after assets in a place need to work and plan together, and with local communities, to improve the lives of people, support inclusive growth and create more successful places. The Place Principle supports collaborative place-based action and the Place Standard is a commonly-used tool to help people think about the quality of their place and where action might be required. If the Place Principle is to be effective there is a need to ‘give it teeth’ and operationalise its work so it influences policy, practice and investment on the ground. RTPI Scotland believes that the planning system can be a facilitator of the Place Principle and place-based approaches. RTPI Scotland wish to see a clear articulation from Scottish Government on how the Place Principle can be embedded in policy, operationalised and championed. As a part of this there needs to be a stronger recognition of the role that proactive planning and place-leadership can have through the enhanced corporate influence of planning. There is an opportunity to achieve this through the Chief Planning Officer role, provisions for which are set out in the Planning (Scotland) Act 2019.

There is a need for a stronger policy framework and the introduction of measures to ensure that public authorities publicly report on how they have embedded the Place Principle in their approaches and how they have applied it in their decision making, including any reasoning.  Appropriate enforcement may be required if necessary and public funding opportunities could be offered with a stipulation that there is adherence to the Place Principle.

What is the role of enterprise agencies or other public bodies as enablers of joint working on net zero goals by local government and its cross-sectoral partners?

Statutory consultees are important stakeholders in the planning process. It is vital that they have the appropriate resource to enable them to contribute their expertise to development proposals in timely and robust manner. Therefore the need to

Local government work on net zero in particular areas

8. How are councils working with cross-sectoral partners to decarbonise heat in buildings and to ensure they have greater energy efficiency?

RTPI Scotland supports the role of Heat Networks Partnerships (HNPs) for co-ordinating support across the built environment professions. A place based approach to decarbonisation can encourage cross departmental collaboration across specialisms, develop in-house resources of local authorities and harness the power of data sharing. Planners work with sustainability and climate officers as well as transport planners and highway teams, in-house energy and ecologists, tree officers, flood officers, and housing officers among others. This can be a useful starting point for creating shared visions and ensuring better coordination of delivery, probing, learning and honing in on potential solutions in a way that gives due attention to the relevant perspectives. However, there are clear challenges both for planners in managing these processes, and for infrastructure providers in engaging with planning frameworks. To be effective therefore HNPs and place based decarbonisation strategies need to place planners and climate and sustainability officers central to these efforts, ensuring they have appropriate resources

RTPI Scotland would like to reiterate, as discussed elsewhere in this response, that few local authorities feel they have the resources, in terms of skills, knowledge and expertise; especially when it comes to assessing district heating feasibility proposals.  This may lead to outsourcing work to external consultancies, which can result in higher resourcing pressures when delivering Local Heat and Energy Efficiency Strategies (LHEES). Another barrier may also be the lack of information to support local authorities with LHEES, especially in terms of clarity of the roles in which councils and services providers should play.

9. How are councils working with cross-sectoral partners to decarbonise transport (including encouraging active travel) and to improve air quality?

Despite a strong policy steer and a clear transport hierarchy prioritising active travel, uptake of active travel has stagnated in recent years in Scotland[8] with car traffic has increasing. Transport is also the largest single contributor to Scotland’s carbon emissions with private cars accounting for 39% of overall transport emissions in 2018[9]. Car-centric design can have implications on ease of access to employment, services and facilities, which are not always located a convenient walking, cycling or public transport distance from residential neighbourhoods. In addition, with priority given to vehicle movement and access, less attention has been paid to the place function of streets and human movement through them. This has resulted in, for example, narrow footpaths, inadequate street lighting and fragmented cycle lanes.

However RTPI Scotland believes with the recent publication and new direction of the Strategic Transport Project Review 2 and the push for ‘living locally’ through the extensive reference to the 20 minute neighbourhood within the draft NPF4 a new opportunity has arisen to push for decarbonisation of transport and improvement of air quality.

From a development planning perspective Transport Appraisals are an important tool to assess the impact of LDP strategies on transport networks and identifying locations where transport interventions are necessary. Transport Appraisals are undertaken in line with the Development Planning and Management Transport Appraisal Guidance (DPMTAG)[10]. The DPMTAG has a clear steer within it for promoting active travel modes, including through the production of Active Travel Plans. However the implementation of national policy and guidance is not resulting in shift in travel modes on the ground. RTPI Scotland would recommend an evidence based review of the DPMTAG in advance of the producing updated guidance. A move towards a tighter consideration of 20 minute neighbourhoods in Transport Appraisals may support local transport interventions to encourage active travel for local journeys.

The need to move active travel considerations from policy through guidance to delivery is a key concern in supporting decarbonising transport and improving air quality. A refreshed ‘Designing streets’ provides another opportunity to do so. Designing Streets intends to steer street design towards place-making and away from a system focused upon the dominance of motor vehicles. However the consideration of active travel infrastructure is now outdated with the inclusion of wording such as “Only where traffic volumes and speeds are high should the need for a cycle lane be considered.” A refreshed ‘Designing Streets’ needs to better emphasise the importance of active travel when considering street design including the consideration of strategic active travel networks and core paths. An updating Designing Streets should incorporate updated guidance on active travel including a refreshed Cycling by Design and a new National Walking design standards. Local street design guidance can be subsequently produced to reflect local character.

As discussed above in recent years in Scotland there has been a significant increase in traffic volumes. This increase in traffic has not been experienced equally across roads in urban areas with studies in England showing the greatest increase in volumes on since 1994 has been almost entirely on minor roads resulting in a greater noise, air pollution and road danger on residential streets. A response to this in recent years has been the deployment of low-traffic neighbourhoods (LTNs)[11]. LTNs operate whereby private motorised vehicles can still access all homes and businesses, but they cannot cross through the neighbourhood. Following a Transport Appraisal whereby problems of high congestion are identified in residential areas, there may be a role for LDPs in identifying traffic calming measures needed in areas such as LTNs and set out a policy response accordingly in alignment with any local walking and cycling strategies. In a rural context the need to drive for the foreseeable future cannot be overlooked, however on arrival to the nearest settlement, encouraging ‘park and walk’ culture through interventions could have many benefits.

10. How are councils working with cross-sectoral partners to promote recycling and a “circular economy”?

RTPI Scotland wishes to highlight the increasing role that the planning system will have in regards to circular economy with an updated and expanded policy on zero waste in the draft NPF4. The policy requires LDPs to identify locations for new infrastructure and support development in line with the waste hierarchy. However, we have concerns that requirements for compliance with this policy needs more clarity, especially in regards to the proposed preparation of a decarbonisation strategy. 

11. How are councils working with cross-sectoral partners to use the natural environment (its “green infrastructure”) to achieve net zero targets?

The planning system is a fundamental mechanism to ensure delivery of blue/green infrastructure, approaches to flood management and mitigation are joined up and that biodiversity is enhanced through creating, expanding and protecting areas of high ecological value.  RTPI Scotland wish to highlight the developing with nature guidance and draft regulations on Open Space Strategies, both of which will have important implications for cross-sectoral working in this area.

 

[1] https://www.rtpi.org.uk/research/2021/june/resourcing-the-planning-service-key-trends-and-findings-2021/

[2] https://www.rtpi.org.uk/research/2021/november/funding-the-planning-service-2021/#_ftn3

[3] https://www.rtpi.org.uk/policy/2022/january/local-government-housing-and-planning-committees-draft-npf4-call-for-evidence/

[4] https://www.rtpi.org.uk/research/2020/november/transforming-planning-places-and-scotland-economic-impact-analysis/

[5] https://www.rtpi.org.uk/research/2020/november/transforming-planning-places-and-scotland-user-and-customer-impact-analysis/

[6] https://www.rtpi.org.uk/research/2020/november/transforming-planning-places-and-scotland-policy-impact-analysis/

[7] RTPI Scotland (2019) Financial Implications of Implementing the Planning (Scotland) Act 2019. August. Available here: https://bit.ly/3uRbtFT

[8] https://nationalperformance.gov.scot/chart/journeys-active-travel

[9] Transport Scotland (2020) Scottish Transport Statistics No. 39 2020 edition. Available here: https://bit.ly/2On8LqM   

[10] Transport Scotland (2009) Development Planning and Management Transport Appraisal Guidance. Available here: https://bit.ly/3biJPd7

[11] Scottish Parliament Information Centre (2020) SPICe briefing - Low traffic neighbourhoods. October. Available here: https://bit.ly/3c8fygo