Local Government, Housing and Planning Committee's draft NPF4 call for evidence

Please provide your views on the consultation and development of NPF4 and how this has contributed to the draft.

RTPI Scotland welcomes the opportunity to submit written evidence to the Local Government, Housing and Planning Committee (LGHPC) regarding the draft National Planning Framework 4 (NPF4) hereon in ‘the Framework’. The Royal Town Planning Institute (RTPI) is the champion of planning and the planning profession. Our mission is to advance the science and art of town planning, working for the long-term common good and well-being of current and future generations. We campaign to promote healthy, socially inclusive, economically and environmentally sustainable places. We have around 2,100 members in Scotland and a worldwide membership of over 27,000. RTPI Scotland’s members represent both the public, private and third sector interests and are extensively involved in all areas of planning matters across Scotland. Our membership will be the key means by which the NPF4 will be implemented.

RTPI Scotland has worked with Scottish Government throughout the Framework’s engagement process, which we commend for being both inclusive and wide ranging.  RTPI Scotland will be providing continued support to Scottish Government with further engagement activities to feed into this critical stage of the Framework’s scrutiny. We expect outputs from this stage of engagement to receive careful and meaningful consideration which will inform the drafting of the finalised NPF4 when laid before Parliament.

RTPI Scotland would like to stress that the written evidence presented here to the LGHPC represents our first stage response to the Framework, setting out preliminary thoughts and drawing on key high-level themes. We expect our thinking to develop further as our engagement work progresses. During this time we will also be considering the implications of interconnected regulations and guidance consultations running concurrently with this consultation such as those on the draft local development planning guidance and regulation.

We would warmly welcome the opportunity to provide further input through oral evidence for the respective scrutinising committees and would be happy to provide regular updates and briefings where necessary.

Please provide your views on the structure of the National Planning Framework 4 document.

RTPI Scotland broadly welcomes the direction of travel promoted through draft Framework. We are pleased to see its commitments to tackling the climate crisis and Global Climate Emergency, to minimise emissions and to enhance biodiversity. We welcome the importance being attached to place based approaches, especially by embedding the 20-minute neighbourhood approach and having stronger presumption against out-of-town retail. The intended timing of publication of the Framework provides a clear opportunity to firmly embed and recognise the fundamental role planning will have in supporting post-COVID recovery[1].

However, if the Framework is to ensure that these aspirations and ambitions are achieved RTPI Scotland believes that there are a number of fundamental steps that need to be taken. There is a need to ensure that:

• there is a capital investment programme working alongside the Framework to provide the resources to deliver the development and infrastructure required
• there is adequate investment in planning services to ensure there are planners in place to manage the service
• each and every policy in the Framework provides clarity and certainty to give confidence to decisions makers and help deliver the outcomes for the NPF4 set out in the Planning (Scotland) Act 2019
• alignment is in place with other strategies and that these are up to date
• there is clarity in definitions of key concepts such as 20 minute neighbourhoods, community wealth building etc, especially given semi-legal nature of planning
• the Framework includes short-, medium-, and long-term milestones and establish a delivery oversight group, which should include representatives from younger generations, to report on progress being made and implications of changing contexts on annual basis
• there is a focus on identifying and measuring the outcomes of the Framework
• the ambitions and policies set out in the framework embed the need to make decisions based on the wellbeing of future generations
• a clear link is made to the Scottish Government’s Digital Planning Strategy with demonstration of how data can be embedded as a foundation of the new Scottish planning system

RTPI Scotland understands the logic behind the structure of the document however we are concerned about the accessibility of the Framework in its current form for many stakeholders, especially members of the general public. This is particularly important to consider as the Framework is to form part of the statuary development plan so will need to be read alongside a complex array of other strategies and plans including, for example, Local Development Plans (LDPs) and Local Place Plans (LPPs). Therefore, to improve engagement with the Framework for those who do not work in the planning profession, RTPI Scotland would advocate for the drafting and publication of an easy read guide to be read alongside an updated ‘Guide to the Planning System in Scotland’. This could include a version aimed at children and young persons.

To improve the readability and accessibility of the Framework, RTPI Scotland believes that the National Development and Action Areas sections could be restructured and simplified with more detailed information moved into appendices. A hyperlinked contents page would also be greatly welcomed for easier use of the Framework. More broadly we believe Scottish Government’s Digital Planning Strategy should use the opportunity provided through the publication of the NPF4 to demonstrate an innovative modern approach to a digital policy document, for example through the through digital layering policy and place information.

Please provide your views on the incorporation of the Scottish Planning Policy and coherence of the NPF4 document overall as a roadmap.

Whilst RTPI Scotland welcomes the incorporation of Scottish Planning Policy in the Framework, we have a number of concerns over the coherence of the document which will be addressed throughout our response but principally include:

• Status and read-across of section part 1
• Applicability of policies when determining planning applications
• Conflicting and contradicting policy wording
• Alignment with broader government strategies and plans
• Accordance with the obligations set out in the Planning (Scotland) Act 2019

Part 1 – A National Spatial Strategy for Scotland 2045

What is your view on the Sustainable Places section?

RTPI Scotland understands that this section sets out the overarching spatial strategy for Scotland and is very supportive of the inclusion of the introduction and use of national spatial strategy map. The how-to section of the Framework for part 1 states that “The strategy will also be relevant to wider policies and strategies relating to land use.”  RTPI Scotland believes the entire Framework should be relevant to wider policies and strategies relating to land use and therefore would advocate for the removal of such wording.

RTPI Scotland is concerned that the summary sections on Sustainable, Productive, Liveable and Distinctive Place read in combination with the spatial principles section and part 3 may cause confusion for stakeholders engaging with the Framework. The summary sections themselves whilst repeating much of the information contained in part 3 do not summarise all the important content of corresponding part 3 sections. For example, Distinctive places in the introduction does not include mention of polices changes to urban edges and the green belt. Therefore, if a stakeholder were to read it without engaging with the relevant section in part 3, critical policy detail and information might not be conveyed. A more clear and concise approach might be taken if the Places summary sections were to be removed and with national policy summaries and detail all held within part 3.

What is your view on the Liveable Places section?

See above answer

What is your view on the Productive Places section?

See above answer

What is your view on the Distinctive Places section?

See above answer

What is your view on the 'Spatial principles for Scotland 2045' section?

Whilst RTPI Scotland supports the aspirations of the spatial principles section we are concerned that not enough clarity has been provided as to the status of the section, especially how it may be considered in the development management and development planning process or of how it can be read across the other sections of the Framework. For example, spatial principle a) on compact growth does not significantly feature in part 3 and is not mentioned at all under policy 30 on Vacant and derelict land and empty buildings. Other spatial principles such as the ‘balanced development’ principle, although we imagine is implicit throughout the Framework, has not been explicitly included anywhere else in the document and could form an important policy basis for development management decisions. RTPI Scotland welcomes the inclusion of the Infrastructure First principle within the Framework and would support its inclusion in this section.

Do you have any other comments on the National Spatial Strategy outlined in NPF4?

Whilst our understanding from the how-to guide is that the preparation of Regional Spatial Strategies is to be informed by part 1 of the Framework, some additional clarification in the form of guidance would be useful on the matter.

What is your view on the 'Action areas for Scotland 2045' section?

RTPI Scotland welcome the ‘Action areas for Scotland 2045’ section to provide much needed vision and support for regional development in Scotland. We assume these are the policy and spatial frameworks informing the emerging Regional Spatial Strategies. Whilst most action areas include mention of their respective city region growth deal, more emphasis on these key investment vehicles would be welcome. RTPI Scotland will be keen to see how the action areas are considered in the delivery plan and monitoring programme.

Do you have any other comments on the Action areas for Scotland 2045 outlined in NPF4?

These action areas are considerable in length and RTPI Scotland would welcome any attempts to make the sections more concise, with use of appendices for further information if necessary.

Please provide your views on each of the National Developments in the text boxes provided below.

• Central Scotland Green Network
• National Walking, Cycling and Wheeling Network
• Urban Mass/Rapid Transit Networks (Aberdeen, Edinburgh, Glasgow)
• Urban, Sustainable Blue and Green drainage solutions
• Circular Economy Material Management Facilities
• Digital Fibre Network
• Island Hub for Net Zero
• Industrial Green Transition Zones
• Pumped Hydro Storage
• Hunterston Strategic Asset
• Chapelcross Power Station Redevelopment
• Strategic Renewable Electricity Generation and Transmission Infrastructure
• High Speed Rail
• Clyde Mission
• Aberdeen Harbour
• Dundee Waterfront
• Edinburgh Waterfront
• Stranraer Gateway

Please provide any other comments on the National Developments section of the NPF4?

RTPI Scotland has no comments on specific National Developments however we welcome the clear emphasis on ‘green growth’ and believe that, if delivered, these projects could be transformative for Scotland, supporting a new green economy. 

As we said in our response to the NPF4 Position Statement we believe the success of the NPF4 will very much lie in the implementation of the plan and key to this will be the delivery of the national developments. Considering a number of these have been carried over from the previous NPF3 there may be questions over the deliverability of the proposed developments. RTPI Scotland is concerned that, for example, none of the national developments have been contained in the 21-22 Programme for Government, and the Infrastructure Investment Plan Scotland 2021-22 to 2025-26 only provides clear investment plans for Circular Economy Material Management Facilities, Digital Fibre Networks and the Dundee Waterfront. We are firmly of the view that there is a need for the Framework to be supported by a capital investment programme so as to ensure that it ambitions can be realised on the ground. This has been done elsewhere with a case in point being the Irish National Planning Framework which was published in 2018.

RTPI Scotland also believe that aligning the national developments with emerging Regional Spatial Strategies and the National Economic Transformation Strategy will be key in ensuring their successful delivery.

This section is very lengthy which may reduce the readability of the document as a whole. Therefore, as discussed previously regarding action areas, this section may benefit from being abridged with more detailed information moved to appendices. We note the National Developments were annexed in the NPF3.

RTPI Scotland are also concerned over a lack of clarity in the descriptions of some of the national developments, especially in terms of clearly setting out the status of applications coming forward in or near national developments. This applies to potentially vague locational information regarding Dundee and Edinburgh Waterfront and the need for clearer wording on policy requirements for consideration in the urban sustainable blue and green drainage solutions national development.

Please provide your views on each of the National Planning Policies in the text boxes provided below.

Policy 1: Plan-led approach to sustainable development

RTPI Scotland supports inclusion in this section of the purpose of planning which is to manage the use and development of land in the long-term public interest, contribute to Scotland’s national outcomes and the UN Sustainable Development Goals. However, we note that there may be some confusion for this policy as it is included in the Universal Policy section but applies only to LDPs.

Within the Universal Policy section, we would further welcome a policy which embeds the need to make decisions based on the wellbeing of future generations. This could build upon the future generations ambitions set out by the Welsh Government set out in the Well-being of Future Generations (Wales) Act 2015[2].

Throughout part 3, RTPI Scotland are concerned over the regular use of the expression ‘should’ relating to the application of policies. In many cases this could cause ambiguity over whether policies must be complied with, potential weakening some of the laudable aspirations of the Framework and making clear decision-making more difficult.  The policies most provide the utmost clarity for those submitting planning applications, and, for those who will be using the framework to inform decisions they need to make on development proposals.

Policy 2: Climate emergency

RTPI Scotland broadly supports the new requirement to give significant weight to the Global Climate Emergency in plans and decisions. However, we believe that the policy could be strengthened through incorporating circular economy principles such as considering embodied carbon and more emphasis on the need to enhance resilience to the impacts of climate change in the built environment. In order to support planners in implementing this policy RTPI Scotland advocates for the publication of guidance and an assessment template to explain how the assessment of carbon emissions should be approached and presented. As a new duty RTPI Scotland would also like to raise awareness of the potential additional resource implications alongside the need to upskill planners in terms of their climate literacy, through a nationwide training programme. RTPI Scotland would welcome the opportunity to support Scottish Government and other key stakeholders in this regard.

Policy 3: Nature crisis

RTPI Scotland broadly supports the new policy responding to the nature emergency requiring plans and proposals to contribute to the enhancement of biodiversity. However, RTPI Scotland wishes to see a clearer explanation as to what the ‘Nature Crisis’ is, a clearer definition of what constitutes nature positive development and a clear read across to the interconnected policy 32, which has a different set of overlapping criteria. The success of the policy will rely heavily on the content of the associated NatureScot ‘Developing with Nature’ guidance on securing positive effects for biodiversity from local development. RTPI Scotland will be fully responding to the on-going consultation for the aforementioned guidance in due course.

Policy 4: Human rights and equality

RTPI Scotland strongly support the intentions of the policy to reinforce the important role of planning in respecting, protecting and fulfilling human rights, seeking to eliminate discrimination and promoting equality. RTPI Scotland has concerns that it is unclear how applications will comply with this priority especially when considering existing legal duties such as the Human Rights Act 1998 and the Public Sector Equality duty. Additional guidance is needed on the matter, or that this be moved to one of the spatial priorities instead.

This policy also emphasises the need for planners to undertake effective community engagement. RTPI Scotland would like to highlight the opportunities to support planners to achieve this through publication of draft guidance on effective community engagement, the detail of the draft regulations and guidance on development planning and securing much needed funding for Local Place Plans. 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.

Policy 5: Community wealth building

RTPI Scotland strongly support the core principles of community wealth building including that of progressive procurement, fair employment and just labour markets, shared ownership of the local economies, socially just use of land and property and improving flows of investment within local economies. However, we have some reservations about the wording of Policy 5 and, in particular 5(b), which requires national and major developments to contribute to community wealth building objectives. RTPI Scotland does not believe that these objectives have been clearly set out in the Framework or elsewhere in Scottish Government policy and guidance. Furthermore whilst the principles of community wealth building are commendable in their intentions, they might be difficult to apply in the decision making process at the planning application stage. RTPI Scotland wishes to see that this policy is tested in its applications with development proposals. Policy 5(a) may be improved by obliging LDPs to have regard to any Community Wealth Building Strategy produced by the planning authority.

Policy 6: Design, quality and place

RTPI Scotland notes the updated policy on design, quality and place which requires that plans and proposals to reflect the six qualities of successful places. Although RTPI Scotland support the more detailed policy approach to design, we are concerned over the unprecise wording in this section, with references to ‘sense of joy’ unlikely to support applicants or development management planners in developing or assessing proposals. In order to achieve more clarity on what makes successful places, RTPI Scotland would advocate for the reframing of quality of design and place in line with themes set out in Place and Wellbeing Outcomes[3]. To also better support placemaking aspirations, RTPI Scotland advocates for a design policy section which better encapsulates placemaking consideration beyond planning applications. This could be achieved through merging policy 6 and 7 to ensure consideration of living locally and the 20-minute neighbourhood are fully embedded into the design considerations of all stakeholders from the beginning.  RTPI Scotland note that this policy section references Creating Places (2013) and Designing Streets (2010) national policy statements.  Both of these documents will need to be updated to reflect a changed policy and societal context, especially with regard to key ambitions around net zero carbon, a post-Covid green economy, place based approaches, health and wellbeing and community wealth building.

Policy 7: Local living

RTPI Scotland are fully supportive of the inclusion of local living section and integration of the 20-minute neighbourhood concept in the Framework. In particular we are pleased to see many recommendations in our recent publication on the matter reflected in the policy[4]. As mentioned in the previous question RTPI Scotland believe the policy could be combined with policy 6 to strengthen both.

Policy 8: Infrastructure First

RTPI Scotland strongly supports this new policy which requires LDPs and delivery programmes to be based on an infrastructure-first approach, identifying infrastructure requirements including delivery responsibilities, mechanisms and related developer contributions. However it should be recognised that this will have a significant resource burden on planning authorities, infrastructure providers and statutory consultees given the need to develop a robust evidence base in the preparation of LDPs on matters such as infrastructure capacity, condition, needs and deliverability for the new ‘gatecheck’.

To support making this stage of the LDP preparation process more efficient, RTPI Scotland sees an important role for the Scottish Government’s Digital Planning Strategy[5] that includes the development of a shared data resource for infrastructure, planning and place data to support infrastructure providers to provide necessary information available in time for the early stages of the LDP preparation process.  

RTPI Scotland also supports the policy steer for LDPs to align with other relevant infrastructure plans and policies, including the Scottish Government’s Infrastructure Investment Hierarchy, the Infrastructure Investment Plan, the National Transport Strategy 2 and the Strategic Transport Project Review though we believe that this alignment should work both ways RTPI Scotland also supports the specific reference to sustainable travel and investment hierarchies.

The Institute would wish to see included in this section specific reference to Regional Spatial Strategies which are to identify strategic development for areas of more than one planning authorities which will have a significant impact on future development and infrastructure requirements. RTPI Scotland is aware that guidance on how the infrastructure first approach is to be considered in LDP preparation process is contained in the recently published draft local development planning regulations and guidance. We intend to address this matter separately in our response to the corresponding consultation however further to this, we believe this policy would greatly benefit for having guidance published alongside it to help guide stakeholders through the delivery process, including clarification on how this section relates to Section 75 agreements and the emerging infrastructure levy.

RTPI Scotland has argued for a number of years that Scottish Government must take a more active role by prioritising its Capital Borrowing Powers to fund infrastructure and establishing a body or number of special purpose vehicles to work with local partners to coordinate and provide infrastructure, deliver development and assemble land across Scotland. 

Policy 9: Quality homes

RTPI Scotland welcomes changes to the quality homes policy section, and the Minimum All-Tenure Housing Land Requirement (MATHLR) approach to housing numbers which is set out in Annex B. We believe this is a reasonable and appropriate approach and hope that it can provide clarity on housing land supply figures and incorporate ambitions on quality placemaking.

RTPI Scotland supports the added emphasis on the need to provide affordable housing options through a range of tenures and types. We also welcome the new obligation for applicants to provide a statement of community benefit for large scale housing proposals.

However, RTPI Scotland is concerned however that policies 9(c) & 9(f) on the need to ensure housing needs of older and disabled people are vague and will be difficult for development management planners to interpret when scrutinising residential proposals. This may then conflict with one of the outcomes for the NPF4 set out by the Planning (Scotland) Act 2019 that the Framework meets “the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people.”

Policy 10: Sustainable transport

RTPI Scotland supports the requirement for developments that generate a significant increase in the number of person trips to improve accessibility and safety for all modes of travel. We also welcome   the presumption against developments which increase reliance on the private car and references to 20-minute neighbourhoods in this section. However, RTPI Scotland wishes to see policy 10(h) strengthened with the inclusion of ‘or’ between bullet points to emphasis that developments should comply with all the set-out criterion. RTPI Scotland believes the section could be strengthened with specific reference made to Scottish Government’s commitment to a 20% reduction in car kilometres by 2030.

Policy 10(b) obliges LDPs to be informed by an appropriate and effective transport appraisal undertaken in line with Development Planning Transport Appraisal Guidance (DPMTAG). RTPI Scotland would like to highlight that the DPMTAG guidance is considerably out-of-date, having been published in 2011 with references made within it to the NPF2. Therefore, to reflect a changed policy context focused on decarbonisations and to improve how the transport appraisal process can contribute to the preparation of the next generation of LDPs, RTPI Scotland wishes to see the DPMTAG reviewed and updated in due course.

Policy 11: Heat and cooling

RTPI Scotland supports the updated and expanded policy on heat and cooling which requires alignment with the area’s Local Heat and Energy Efficiency Strategy, that proposals should be designed to connect with existing or future heat networks and where there is no effective solution available, an alternative low or zero emissions heating system be provided.

RTPI Scotland also supports the encouragement of passive or natural solutions to cooling. However, the Institute wishes to highlight the resource intensive nature of such requirements and the current lack of resources, skills and knowledge within the public sector on energy related planning matters, especially in terms of assessing district heating feasibility proposals, resulting in costly use of external consultancies. Central to achieving low and zero carbon heat project delivery will be a holistic approach driven by effective partnership working, skills and information sharing, meaningful community engagement and a thorough understanding of spatial opportunities and constraints across sectors. Therefore RTPI Scotland supports the role of Heat Networks Partnerships (HNPs) for co-ordinating support across the built environment professions and will form an important delivery vehicle for this policy.

Policy 12: Blue and green infrastructure, play and sport

RTPI Scotland supports the updated policy on blue and green infrastructure, play and sport with new policies to protect children’s outdoor play provision and design-in new opportunities for play in the built environment alongside maintenance of blue-green infrastructure to be addressed in planning applications.

Policy 13: Sustainable flood risk and water management

RTPI Scotland supports the updated policy on flooding and water management including consideration of Future Functional Floodplain, flood risk mitigation mandated in new infrastructure, the discouragement of impermeable surfaces and the incorporation of blue-green infrastructure for drainage and surface water where practicable. 

Policies 14: Health and Wellbeing

RTPI Scotland supports the new policy on lifelong health and wellbeing, aiming to create healthier places and requiring a Health Impact Assessment of any proposals considered likely to generate significant health effects.

We also support the presumption against development that will significantly adversely affect air quality or generate unacceptable noise. RTPI Scotland would however like to raise the potential resource implications of the new Health Impact Assessment for planning authorities.

Policies 15: Safety

RTPI Scotland supports the updated policy on safety which sets out requirements to take into account potential impacts of new development on major-accident hazard sites.

Policy 16: Land and premises for business and employment

RTPI Scotland supports the requirement for LDPs to identify employment land and support business development as well as alternative ways of working and micro-businesses. Planning can be a key mechanism of directing economic stimulus measures towards local, strategic and national place-based solutions, which have public support and deliver multiple benefits. In order to unlock the transformative power of aligning economic and land use planning RTPI Scotland would like to highlight the critical need to align the National Strategy for Economic Transformation (NSET) with the Framework. RTPI Scotland therefore believe that this section could be strengthened with explicit mention of the NSET.

Policy 17: Sustainable tourism

The Institute supports the new policy on sustainable tourism which encourages growth of the sector in a way which manages impacts on local communities and the introduction of a new policy to manage short-term holiday letting. RTPI Scotland would however support inclusion of clearer policy advice around short-term letting such as setting the number of days which a property could be let for without there being a material change of use. We would like to highlight concerns over the resourcing requirements of the short-term holiday letting policy, especially in terms of potential enforcement action required which could be extremely high for some local authorities. 

Policy 18: Culture and creativity

RTPI Scotland supports the new policy on culture and creativity which recognises the importance of the sector and requires proposals to make provision for public art, encourages creative and cultural uses, protects existing venues, and reflects the agent of change principle.

Policy 19: Green energy

RTPI Scotland broadly supports the updated policy on green energy which provides general support for renewable energy developments in many circumstances. We have some concern that this policy may require improved clarity over wording such as better defining what impacts are considered ‘unacceptable’ and share concerns that it is somewhat weakened by changes to other policies in the Framework.

Policy 20: Zero waste

The Institute welcomes the updated and expanded policy on zero waste which requires LDPs to identify locations for new infrastructure and support development in line with the waste hierarchy. We hope this will help deliver the associated national development policy in this regard. 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. 

Policy 21: Aquaculture

RTPI Scotland support the updated policy on sustainable aquaculture which supports industry needs whilst taking into account wider marine planning issues. However, we have concerns over the resource implications for planning authorities. Aquaculture applications command a very low fee income for planning departments and require an extensive amount of technical planning work, for example, this policy requires planners to assess impacts including operational effects, siting and design of cages and land-based facilities. In the recent review of planning fees and performance, no mention was made about increases to any fees for aquaculture, something that RTPI Scotland believes needs revisited.

Policy 22: Minerals

RTPI Scotland supports the updated policy on minerals that requires LDPs to identify a 10 year land bank at all times, safeguards resources and set out criteria for assessing proposals for extraction. RTPI Scotland especially supports stronger wording in this policy that extraction of fossil fuels is not supported other than in exceptional circumstances that are consistent with national policy.

Policy 23: Digital infrastructure

RTPI Scotland supports the updated policy on digital infrastructure requiring proposals to incorporate appropriate, universal and future-proofed digital infrastructure. The policy also supports new services and technology in areas with no or low connectivity are supported. RTPI Scotland hopes this policy, alongside the investment framework set out the Infrastructure Investment Plan will support the delivery of the Digital Fibre Network.

Policies 24 to 27: Distinctive places

We support the intentions of the updated policy 24, instructing planning authorities to allocate a proportion of housing land requirement in town centres. However, as these sites can be difficult and slow to develop, appropriate support will be needed to ensure that enough housing is delivered in these areas.

RTPI Scotland supports policy 25 which sets out that out-of-town development including new retail is not supported. RTPI Scotland also supports the policies support for development which diversifies and strengthens city, town and local centres whilst seeking to avoid the clustering of certain developments that can have negative impacts on communities. However we strongly believe that  that the policy should be strengthened to contain a clear presumption against drive-through retail, aligning with the principles of policy 11. To support the implementation of this policy, RTPI Scotland wish to see current town centre and retailing methodologies, published in 2007, updated to reflect a changed policy context. This could be achieved for example through removing the current catchment area definition set out by car travel to support the new neighbourhood shopping and living locally policy.

Policy 28: Historic assets and places

RTPI Scotland broadly support the updated policy on historic assets and places however is concerned that the more restrictive approach to development could potentially undermine intentions set out elsewhere for example in policy 19. RTPI Scotland are also aware that the Managing Change Guidance Notes could benefit from being updated and consolidated.

Policy 29: Urban edges and the green belt

RTPI Scotland are broadly supportive of the updated policy on urban edges and the green belt but would like to highlight the important contribution of Local Development Plans in providing a tailored approach to ensure that green belt designation and policy is fit-for-purpose in localities.  RTPI Scotland note in policy 5c that the identified area of search methodology proposed is outdated.

Policy 30: Vacant and derelict land

RTPI Scotland supports this updated and expanded policy on vacant and derelict land and empty buildings that encourages re-use of land and buildings and discourages greenfield development unless there are no suitable brownfield alternatives.

Policy 31: Rural places

Whilst reasoned in its approach, RTPI Scotland feels to some extent that this policy is unambitious. RTPI Scotland has provided many workable policy ideas for rural Scotland in a recent thinkpiece[6].  More broadly RTPI Scotland is concerned that the Framework has not been effectively ‘rural proofed’ with new and updated policies needing tested in the rural context.

Policy 32: Natural places

RTPI Scotland are concerned that this policy may conflict with policy 19, creating a more restrictive environment for the development of onshore wind farms through more stringent policy tests. Achieving net zero carbon targets rely upon an expansion of the onshore wind and for this to happen quickly.  Given this planning authorities will benefit from a strong and clear policy line on this to support their decision making.

Policy 33: Peat and carbon rich soils

RTPI Scotland supports the updated policy on peat and carbon rich soils. Their effective protection will also require that planners have access to reliable spatial data relating to each category.  

Policy 34: Trees, woodland and forestry

RTPI Scotland supports the intentions of this updated policy requiring LDPs to link with Forestry and Woodland Strategies, and to not supporting loss of valuable hedgerows, trees and woodland. Whilst the policy provides support for sustainably managed woodland, overall RTPI Scotland are concerned that the Framework does not make a clear enough case on the social benefits of forest management at landscape scale for rural communities, instead focusing more on the link between forestry and carbon sequestration. In terms of an urban setting the policy could be stronger in encouraging new street trees to be designed into developments.

Policy 35: Coasts

RTPI Scotland broadly supports the updated policy on coasts requiring plans to consider adaptation to future climate impacts, supporting development in areas of developed shoreline provided coastal protection measures are not required, and minimising development in undeveloped coastal areas unless it supports the blue economy, net zero, the economy or communities. However, RTPI Scotland would support greater clarity on how policy 35e be applied and remain consistent with the wording in the rest of the policy.

Please provide your views on each of the key delivery mechanisms in the text boxes provided below.

Aligning Resources

RTPI Scotland supports the collaborative approach discussed in this section as central to delivering the spatial strategy including the use of the Place Principle in this regards. However, we are extremely concerned that the Framework includes a number of new assessments, new and expanded policies and many additional duties. This will place a significant cumulative resource burden on planning authorities. It is disappointing that the costs of these have yet to be fully estimated by Scottish Government given that it has not undertaken a full Business and Regulatory Impact Assessment and that these issues were not fairly recognised in the Integrated Impact Assessment Partial Business & Regulatory Impact Assessment (Appendix B).

In their scrutiny of the Framework the LGHPC needs to take cognisance of the context of diminishing resources and increased workloads in planning authorities with recent research from RTPI Scotland[7] showing 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
• 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

Whilst there is a welcomed mention of the need to invest in the planning service in a subsequent section increased resourcing is only identified through an increase in planning fees. As set out in recently published research[8] RTPI Scotland does not believe this will bring in the appropriate amount of resource necessary for the planning system to undertake its statutory duties and deliver the Framework as set out. To address the additional resourcing and skills requirements from the Framework RTPI Scotland wishes to see a comprehensive resource and skills strategy published 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 do so. Due to the potentially significant resourcing implications of the Framework, RTPI Scotland would welcome the inclusion of the Finance and Public Administration Committee as apart of the joint committee scrutiny process.

Infrastructure First

RTPI Scotland is pleased to hear that once the NPF4 is adopted it will inform the next iteration of Scotland’s Infrastructure Investment Plan with the spatial priorities guiding future public sector investment. We are however concerned that the current in IIP is not due for renewal for another year which given timeframes may make it challenging to deliver many elements of the Framework. We reiterate the need for the ambitions of the Framework to be supported by an aligned capital investment programme. RTPI Scotland believe this approach could be strengthened through that publication of an annual National Infrastructure Assessment. If integrated with the Framework’s delivery and monitoring programme this could improve our on-going understanding of national infrastructure requirements and actions necessary to support delivery.

See response to the Policy 8 section for a fuller discussion on the infrastructure first principle.

Delivery of National Developments

RTPI Scotland supports intentions to work collectively with key partners and align public and private sector investment to support delivery. We are concerned however that only a handful of the national developments reference the STPR, city and regional growth deals and very few are mentioned in the Infrastructure Investment Plan or the Programme for Government. This calls into question the reliability of the delivery strategy in the ‘aligning resources’ section which sets out the intent to primarily utilise these plans and programmes for delivery. Therefore, RTPI Scotland queries whether the national developments, like LDPs moving forward in the new system, need be informed by an infrastructure first approach and be supported by the accompanying delivery programme setting out who will be responsible for delivering what infrastructure and how it will be funded. Key to this is alignment with the city and regional deals, and vice versa.

Development Plan Policy and Regional Spatial Strategies

RTPI Scotland would consider that it would be helpful to have some explanation as to how the various parts of LDPs will interact with the content of the NPF. As previously mentioned, we understand that some of this may have been addressed in the recently published draft local development planning regulations and guidance, which we intend to address separately in our response to the corresponding consultation. However, there may remain a potential tension as to whether planning authorities will want to adopt the policies in full or adapt them for the local circumstances. Clarity will need provided as to the extent to which planning authorities will be able to adapt the policies. RTPI Scotland also wishes to see better clarity as to how Regional Spatial Strategies are to align with the Framework.

RTPI Scotland note that there is no mention of the Scottish Government Digital Planning Strategy in this section and would like to see clear consideration of how it can support the implementation of the Framework through its inclusion in the delivery programme. 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[9], a user and customer impact analysis[10] setting out the benefits for planning authorities, planning applicants and communities and a policy impact analysis[11] setting out the range of policy ambitions that rely upon a digital planning service.

Monitoring

RTPI Scotland believe that any monitoring programme set out will have to look very different from that carried out for the NPF3. This would include an approach to monitoring the part 3 policy which could take a similar approach to work commissioned by Scottish government into the adoption of Scottish Planning Policy in LDPs. We support the approach which monitors development of national and local levels but also wish to see monitoring at the regional level too. We believe that the Framework should include short-, medium-, and long-term milestones and establish a delivery oversight group, which should include representatives from younger generations, to report on progress being made and implications of changing contexts on annual basis.

RTPI Scotland are pleased to see our work in monitoring outcomes referenced in this section. We would like to see any measurements of success move beyond simple metrics like speed of processing applications and number of housing units delivered and assessing planning in terms of placemaking aspirations and social, economic and environmental value, in order to track and improve the impact of planning.  Our research[12] aims to help provide practical ways to gauge how planning delivers on the explicit aspirations of planners and elected representatives, in terms of placemaking and social, economic and environmental value. The research report is accompanied by a suite of documents to deliver on the research aims. There is a Handbook that offers practical guidance, documents on the pilots carried out in Ireland and excel sheets providing the practical framework for implementing this new process of measurement. There is an important role for the new National Planning Improvement Coordinator in developing and implementing this.

Please provide your views on Annex A.

No comment.

Please provide your views on Annex B.

RTPI Scotland understands that stakeholders are broadly happy with the approach, however we share some concern over the high resource requirements for planning authorities to refine nationally derived targets to be more accurate for their locale, potentially inhibiting some from doing so. To improve consistency across authorities and reduce the resource burden we believe that this area of data collection and analysis be addressed by the Scottish Government’s digital planning taskforce as a matter of priority. We hope that a clear and consistent approach to housing numbers can move conversations on to securing agreement on the methods of assessing the deliverability of sites, mechanisms to review HLS and most importantly on how we can deliver quality development.

Do you have anything else to add in relation to the draft of the National Planning Framework (NPF4)?

RTPI Scotland have highlighted in our response concerns over the applicability of a number of policies contained within the Framework. Whilst an impact assessment has been undertaken, this has focused on higher level matters in order to meet its statutory requirements. Therefore, RTPI Scotland calls upon the LGHPC, the respective parliamentary committees scrutinising this joint call for evidence and the Scottish Government to use this key consultation stage to thoroughly scrutinise and stress-test the new and expanded policies. Much of this will require a sharp and detailed focus on policy wording, the necessary guidance, skills and resources needed for planners to undertake the new duties alongside a clear overview of how the various parts of the Framework will interact with one another. Furthermore, the complementarity of the Framework with a wide range of other government strategies and the Planning (Scotland) Act 2019 is a critical consideration. The Framework’s success will very much rely on the quality of the associated guidance and in our response RTPI have identified a range of methodologies, plans and guidance that will need updated to support planners to deliver the intended outcomes of the Framework including:

• Scotland’s National Marine Plan (2015)
• Designing Streets (2010)
• Creating Places (2013)
• Development Planning and Management Transport Appraisal Guidance (2011)
• Town Centre and Retailing Methodologies (2007)
• HES Managing Change Guidance Notes

 

[1] RTPI (2021) Urban planning after COVID-19 - Supporting a global sustainable recovery. Oct. Available here: https://bit.ly/3zHzvWq

[2] https://www.futuregenerations.wales/about-us/future-generations-act/

[3] https://www.improvementservice.org.uk/products-and-services/consultancy-and-support/planning-for-place-programme/place-and-wellbeing-outcomes

[4] https://www.rtpi.org.uk/research/2021/march/20-minute-neighbourhoods/

[5] https://www.gov.scot/publications/transforming-places-together-scotlands-digital-strategy-planning/#:~:text=This strategy defines a long-term strategic direction for,needed and the benefits this transformation will bring.

[6] https://www.rtpi.org.uk/policy/2021/september/the-national-planning-framework-4-and-rural-planning/

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

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

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

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

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

[12] https://www.rtpi.org.uk/research/2020/november/measuring-what-matters-planning-outcomes-research/