About the RTPI

At the Royal Town Planning Institute (the RTPI), we champion the value of planning in building thriving places and communities. With over 27,000 members worldwide, we support planners at every stage of their career: raising professional standards, shaping planning policy, and proudly awarding chartered status, the highest professional accreditation in UK planning.

For over a century we have empowered planners to deliver positive impact: creating healthy, inclusive, economically and environmentally sustainable places. As the voice of the profession, we advocate, support, and lead with purpose, professionalism, and passion.

Consultation Response

We welcome the opportunity to respond to the draft Environment Strategy, prepared pursuant to Section 47 of the UK Withdrawal from the EU (Continuity) (Scotland) Act 2021. We recognise that this Strategy is important to help ensure continued alignment with EU law and policy, but we also see it as an opportunity to take stock of our actions and progress thus far and to ensure that, as a nation, we are moving collectively in the right direction to deliver our bold ambitions with respect to addressing the climate and nature crises and achieving net zero.

With the above in mind, we take this opportunity to draw your attention to the following matters which we believe should be taken into consideration in finalising the draft Strategy to ensure it aligns with and has full regard to our ambitions for a net zero and climate resilient Scotland. 

The need to embed biodiversity and nature enhancement

We broadly support the vision and outcomes set out in the draft Strategy. However, we believe that the ambition to “restore biodiversity and ecosystems” in the vision and the various outcomes does not go far enough to achieve the future safeguarding objectives of the vision statement – i.e. “to secure the wellbeing of our people and planet for generations to come”.

In order that we can truly tackle ecosystem degradation and biodiversity loss, we need to move beyond mere “restoration” towards the “enhancement” of biodiversity.

This shift away from “restoration” towards “enhancement” is reflected in Policy 3 of the National Planning Framework 4 (NPF4), the policy outcome of which is: “Biodiversity is enhanced and better connected including through strengthened nature networks and nature-based solutions”.  To achieve this, local development plans are required to “protect, conserve, restore and enhance biodiversity”, and development proposals are expected to “contribute to the enhancement of biodiversity”. Adopting a shift towards biodiversity enhancement in the Environment Strategy would result in closer alignment with the ambitions of NPF4 and would help to ensure there is a consistent direction of travel between them.

In addition to the above, we believe that a key problem with a “restoration” approach is that it requires the establishment of a clear restoration baseline. Although we have a 1990s baseline for CO2 emissions, we do not have a clearly agreed and adopted baseline for biodiversity restoration. Seeking to achieve an undefined baseline for biodiversity restoration could prove difficult given that it will likely look different to different individuals and generations with differing baseline expectations.

We therefore believe that it is biodiversity enhancement (and not simply restoration) that will enable us to truly tackle biodiversity loss and degraded ecosystems in Scotland. Unless this is embraced in the vision for the Environment Strategy, there is a risk that this ambition will be watered down, and we will end up accepting lesser (albeit somewhat improved) nature outcomes that do not go far enough to achieve our ambitions. 

Spatial Land Use Implications of the Strategy

The draft Strategy covers a lot of ground at a variety of scales – ranging from the local to the global. We are pleased to see important linkages between the environment and health recognised throughout the Strategy, and reference in places to NPF4.

However, the Strategy falls short of recognising the critical spatial land use, planning and management elements that connect (and are vital to achieve) many of the outcomes and delivery priorities set out in the Strategy document. For example, to address air pollution (section 3.3.1), water pollution (3.3.2), transitioning to a circular economy (3.4.1) and the behaviour changes of businesses, individuals and communities referenced throughout the Strategy (with respect to travel, consumer and trade choices, and how homes are heated etc.), we need to plan and design our places to make these outcomes possible. It is worth highlighting that the Scottish Government has recently consulted on Scotland’s Fourth Land Use Strategy, the consultation paper for which specifically highlights the natural capital that is generated when we appropriately plan and manage the use of land and our built and natural assets. It also recognises the interlinkages between many of the delivery priorities mentioned in this draft Strategy – including (for example) the links between food production practices and clean air and fresh water.

There is much evidence to show that spatial environments drive consumption and travel behaviours and cultures. For example, Public Health Scotland have prepared a number of Health Impact Assessment evidence guides that recognise the ways in which physical environments shape health – including heath and transport, health and greenspace, health and housing etc. In addition, the Health Foundation’s Evidence Hub, which provides data and insights on the drivers of health inequalities, includes an indicator showing the relationship between the concentration of fast food outlets and health. This demonstrates that where the spatial conditions provide fewer or limited healthier choices, the ability of communities to make vital behaviour changes to drive forward the outcomes of this strategy will be severely hampered. Unless communities have access to the infrastructure and services necessary to enable them to make healthier travel and consumer choices, it is unlikely that households will be in a position practically speaking to do so (such as relinquishing or reducing the use of private vehicles, for example).

NPF4 is referenced three times throughout the Strategy, specifically in relation to its policies around the protection and restoration of biodiversity (at Section 3.6.1 of the Strategy), minimising lifecycle greenhouse gas emissions (at Section 3.6.5), and blue-green infrastructure (at Section 3.5.1). However, we believe this constitutes viewing NPF4 through a very narrow lens when, in fact, it contains a vast number of policies which could drive forward many of the outcomes of this Strategy if properly implemented – including local living (NPF4 policy 15), sustainable transport (NPF4 policy 13), infrastructure first (NPF4 policy 18), to name just a few.

In particular, the draft Strategy focuses a lot of attention on heat decarbonisation and energy efficiency. NPF4 contains a number of relevant policies around energy (policy 11), quality homes (policy 16) and heat and cooling (policy 19) that are relevant to improving the efficiency of our buildings, but which also go unacknowledged in the draft Strategy. Policy 19 specifically requires LDPs to take into account Local Heat & Energy Efficiency Strategies, which aim to incorporate a place-based approach to energy efficiency and heat decarbonisation that could drive forward the ambitions of the Strategy, but which are also not referenced in the draft.

We also note that the draft Strategy focuses much of its attention on reducing emissions from transport, with a particular focus on the role of electric vehicles but also mentioning the importance of enhanced use of public transport and active travel. What is lacking in these sections of the Strategy is acknowledgement of the important connection between these outcomes and how places are designed to enable healthier and more sustainable travel choices through the creation of 20-minute neighbourhoods where people can live well locally.

We believe that there is opportunity within the draft Strategy to establish these important place-based links that are currently lacking. In this regard, we draw your attention to Table 1 of the draft Strategy, which includes the list of Outcomes and draft priorities for their delivery. We believe this Table could better recognise and capture the place element of many of these outcomes, including by adopting the following additions and changes:

•      Include a priority to implement the policies of NPF4. The draft priorities set out in Table 1 include a range of actions, including the implementation of a number of already published and adopted frameworks, plans and policies. However, there is no mention in this table to implementing NPF4 – the policies in which drive forward a number of the Strategy’s outcomes.  
• Change “creating nature-rich towns and cities” to “creating nature-rich places”. This draft priority currently assumes that it’s only in urban areas where nature-based solutions can improve people’s health and wellbeing. Nature-based solutions have a role to play right across Scotland’s communities, including in more rural and coastal areas. Amending this priority to refer to “places” rather than “towns and cities” will enable a broader discussion about the role of nature-based solutions throughout Scotland.
• Amend “Empower Scotland’s people to live well, sustainably” to “Enable Scotland’s people to live well locally and sustainably”. We believe this altered wording better recognises the joint responsibility of individuals, communities, and government to create the optimal conditions to enable people to make healthier and more sustainable choices. Local living is a key aspect of this, which we believe must be captured in this delivery priority. Likewise, within this priority:
  • Amend “Transport” to read “create the conditions necessary to enable a shift from car use towards active travel and public transport...”. We believe there needs to be recognition within the Strategy about the need to create the optimal conditions necessary to support a shift from car use. Rather than focusing on the outcome (i.e. a shift from car use), there should be greater focus on the actions that needs to take place to enable this shift. This will require an infrastructure-first approach, which should also be recognised in the Strategy.
  • Amend “Housing” to read “support decarbonised and energy efficient neighbourhoods and improve the nature-value of Scotland’s places”. “Housing” should extend beyond consideration of the energy efficiency of private spaces (i.e. homes and gardens) towards broader consideration of decarbonisation of whole neighbourhoods and communities. The way housing is designed and developed can influence not only the private spaces of residential occupants (i.e. their homes and gardens), but also the potential of the public domain (local streets, roads, pathways, greenspaces etc.) to contribute to decarbonised and more energy efficient places, through (for example) carefully chosen and located landscaping and the use of sustainable urban draining systems (SuDS).

The importance of Net Zero Placemaking 

As previously mentioned, the Strategy covers a lot of ground at a variety of scales – ranging from the local to the global, covering transport, energy efficiency, pollution and waste, food security and sustainability, housing, consumer behaviours, supply chains, tax measures, and financial systems (and more). This is encouraging as it recognises the broad and interconnected relationships that need to work together to achieve the broad vision for Scotland’s environment. However, despite their interconnectedness, the Strategy appears to treat each of these in isolation (taking a siloed approach) and largely fails to look beyond the individual parts towards the whole picture of creating a truly “One earth. One home. One shared future”. Consequently, despite the Strategy’s broad scope, there remain a number of missing elements which we believe are essential to delivering the Strategy’s outcomes and vision. 

For example, the draft Strategy does not go so far as to seek a broadened ambition beyond the decarbonisation of individual buildings towards an ambition of decarbonising Scotland’s places, which we believe represents a missed opportunity. This broadened scope would expand our understanding of how to introduce decarbonisation practices beyond individual building footprints, towards a place-based approach to decarbonisation, utilising the spaces between buildings to create (for example) opportunities for increased urban greening and local carbon sequestration, as well as creating the optimal conditions using spatial land use opportunities to facilitate improved air and water quality, biodiversity, and healthy living (as discussed in the previous section of this response). In this regard, we draw your attention to the Balance white paper produced by Anderson Bell Christie, which sets out the practical measures that they believe can be taken in the construction and planning sectors (amongst others) to drive forward sustainable construction practices to help us decarbonise our places (not just our buildings) and achieve net zero.

The use of energy efficient insulation and clean heating systems in individual buildings is only one part of a much bigger picture. Ignoring the importance of reducing the impacts of embodied carbon coupled with the benefits of place-based carbon sequestration opportunities is a missed opportunity that we feel requires greater attention in the Strategy.  

Links to the proposed Wellbeing and Sustainable Development (Scotland) Bill

In addition to the above, we also draw your attention to the Wellbeing and Sustainable Development (Scotland) Bill that is currently at Stage 1 of the enactment process. Given the future proofing and wellbeing objectives of the Strategy’s proposed vision, it is clear that implementation of this Environment Strategy will also work to support the objectives of this Bill and the functions of any Future Generations Commissioner appointed pursuant to Section 4. Although we do not believe there necessarily needs to be reference within this Environment Strategy to this Bill or the Future Generations Commissioner Role specifically, we do believe it will be important for this Strategy to be prepared with full regard to the interconnected objectives and purposes of this Strategy and those set out in the Bill to ensure a functional and collaborative relationship once they are both established in legislation, governance and policy. 

Monitoring the Strategy's implementation

We welcome the work that has been done to date to develop a Monitoring Framework and associated website. Enhancing our ability to effectively and transparently monitor our progress towards achieving our nature and net zero ambitions is critical to ensure the strategy, legislation, policies, guidance and practices we have put into place are working on the ground to deliver the outcomes we need.

For this to be effective, the indicators and data we use to track our progress must accurately reflect the outcomes we are seeking to achieve. We are concerned that the indicators included in the Monitoring Framework (whilst useful) are not an accurate reflection of the full suite of ambitions set out in the draft Strategy. For example, the indicator “Nature-based solutions to climate change” tracks woodland creation and peatland restoration only. Whilst these are important, this is not the only way to implement nature-based solutions to climate change and so will not provide us with the complete picture of our efforts and progress.

We appreciate that the Framework does state that additional indicators will be explored as the Monitoring Framework is further developed. We would welcome the continued development of these indicators to capture the true picture of our progress, including how this should link with a review of our practices to ensure they remain fit for purpose to achieve the Environment Strategy’s vision and outcomes.