RTPI Scotland's Response to NPF4 Position Statement

OVERVIEW

The “Programme for Government” recognises the important role that the National Planning Framework, along with local development plans and local place plans, can have in redesigning communities to best respond to the current Covid-19 pandemic. Emerging regional spatial strategies also have a great deal to contribute to the future of long-term planning in Scotland.

National Planning Framework 4 will set out a new plan for Scotland in 2050. The strategy will have to make some big decisions about the future development of Scotland and the Scottish Government’s ambitious targets for addressing climate change demand a fresh approach and significant investment in infrastructure, as well as a new understanding of how zero carbon living might work.

The Scottish Government has issued a Position Statement which outlines its current thinking on the issues that will need to be addressed when preparing Scotland’s fourth National Planning Framework (NPF4).

The document contains a particular focus on net zero emissions, resilient communities, a wellbeing economy and better, greener places.

It is clear and self-evident that the preparation of National Planning Framework 4 is a significant task that cannot be achieved by government alone. The approach to date has been open and collaborative from the start, and there has been significant inputs from a wide range of individuals and organisations.

RTPI SCOTLAND SUMMARY RESPONSE

RTPI Scotland are in no doubt that the National Planning Framework, with new collaborative thinking and new ideas has the potential to help transform Scotland’s environment, places, communities and economy. The Position Paper provides us with a strong and very promising foundation for this and shows how planning can support a sustainable and equitable green economic recovery that delivers the new normal we need post the Covid-19 pandemic.

RTPI Scotland is pleased that the Position Statement picks up on all the points raised by our 10 Big Ideas Paper and there is a clear synergy and relationship to the wider RTPI publication Plan the World We Need. In particular we welcome the inclusion of our keys asks of prioritising planning for the net zero carbon target by 2045, putting people’s health and wellbeing at the heart of the planning system and prioritising active and sustainable travel.

It outlines a range of key headline opportunities which RTPI Scotland supports including:

• Building 20-minute neighbourhoods.
• Introducing a stronger preference for reusing existing buildings before new development proceeds.
• Shifting future development away from greenfield land including by actively enabling the redevelopment of vacant and derelict land.
• Strengthening support for development in town centres and restricting out-of-town retail and leisure to help us transition away from car-dependent developments towards those that enable walking, cycling, wheeling and public transport accessibility.
• Stimulating new models of low carbon living in our rural areas as well as our towns and cities, by facilitating further investment in digital infrastructure, building in more space for people to work remotely and creating community hubs.
• Expecting low and zero carbon design and energy efficiency, for example by actively encouraging much wider use of sustainable and recycled materials in new developments.
• Significantly strengthening policies to secure low carbon heating solutions.
• Supporting renewable energy developments, including the re-powering and extension of existing wind farms, new and replacement grid infrastructure, carbon capture and storage and hydrogen networks.
• Harnessing the potential for rural development to act as a lever to facilitate woodland creation and expansion.
• Expanding green infrastructure, biodiversity and natural spaces to make our places greener, healthier and more resilient to the impacts of climate change.
• Restricting peat extraction and development on peatland and facilitating restoration through permitted development rights.
• Removing the need for planning permission for active travel and electric vehicle charging points to ensure that we can roll-out new infrastructure widely and quickly.

Our high level comments on the Position paper are focussed around 4 key areas:

Priorities

• We support the broad and all - embracing approach being adopted to consider a spatial planning strategy for Scotland which is innovative, creative and comprehensive. However, RTPI Scotland would welcome that clear consideration in the NPF4 is given to the priorities necessary to support post-covid recovery that achieves net-zero carbon targets and tackles inequalities
• The NPF should set out what success should look like. Key to this will be the role of planning in promoting the long term public interest and embedding a place based approach.
• National developments should not necessarily need to be ‘big’ and should promote zero carbon and health and well-being.

Positioning

• RTPI Scotland would like to highlight the clear opportunity arising from the NPF4 to positon itself as key corporate document that influences Scottish Government decision making and has buy in from all Cabinet Secretaries in supporting their post Covid-19 recovery ambitions and as a vision piece on planning for the ‘new normal’.
• With the status as part of the development plan RTPI Scotland wishes to see an NPF4 that has considered in terms of its purpose and format both as policy document and a National Plan from a multi-stakeholder perspective.
• We would like to see policies in the NPF policies provide real certainty through making sure that they are clear, robust, and strongly worded to provide clarity for development management decisions.
• There is a need to ensure that the NPF clearly defines the roles of, and coordination required between, different organisations and other national strategies. We are pleased to note the many references to aligning strategic thinking across all the proposals which will be a real challenge to deliver and places a heavy reliance on successful Regional Spatial Strategies which are still evolving.

Delivery

• We welcome and support proposals to better link the NPF with other spatial strategies and the Infrastructure Investment Programme. We feel strongly that NPF4 should be accompanied by and integrated with a 10-year capital investment programme to enable the vision to be delivered on the ground with clear, trackable milestones and outcomes.
• It is a very aspirational update statement but RTPI Scotland would stress that success will be determined by the implementation of the plan, not its preparation. To do so RTPI Scotland wishes to see clear emphasis on deliverability and action plans. There is a need for the NPF to be supported by resources to deliver its ambitions through a linked capital investment programme.
• To deliver change on the ground the planning system will to have adequate resourcing and skills. RTPI Scotland considers the Position Statement to be truly ambitious and aspirational in its approach but its ultimate success will depend on a reality check and clear articulation of responsibilities, collective cooperation, funding, timing, resources and training requirements.
• There is a need for a clear articulation on how the NPF4 can embed, operationalise and champion the Place Principle and the infrastructure first principle across Scotland including with any National Developments identified
• Throughout the life of the NPF it should be supported by a transparent and robust evidence base and indicators for monitoring purpose, which are continuously kept up to date. The digital planning strategy should prioritise the collection and analysis of spatial data to support this. Scottish Government should publish an annual report on progress made through the emerging Improvement Coordinator role
• RTPI Scotland would welcome a scoping exercise to evaluate whether establishing a number of programmes alongside the NPF will help fill the gap between policy and projects (such as National Developments) and help join up national strategies and resources.

Engagement

• RTPI Scotland praise the inclusive approach so far adopted by the Scottish Government in working towards NPF4 and we look forward to further engaging. RTPI Scotland has engaged extensively with the consultation process to date and looks forward to continue playing an active part in the next stages in the process. Moving forward RTPI Scotland would encourage a clearer indication of the engagement process through the drafting stage of the NPF4. RTPI Scotland would advocate for the establishment of steering group to have oversight of the entire plan, ensuring that there is continuity across sections and a coherent plan is produced.
• RTPI Scotland will be keen to discuss how it could work with Scottish Government in taking forward the consultation which will be undertaken on the draft NPF4. Engagement on the NPF provides an opportunity to better explain the role of the planning system, to highlight it’s importance and to de-mistify and de-myth planning among newly elected MSPs, the public and policy makers.

Although the Government has published a Position Statement rather than a Consultation exercise it has set out to “sense check” the Position Statement. Below is RTPI Scotland’s responses to the 7 questions set-out for stakeholders.

1. Do you agree with our current thinking on planning for net-zero emissions?

YES.

RTPI Scotland is pleased to see that in the new spatial strategy priority is to be given to addressing climate change challenges and we support the inclusion of a plan for net-zero emissions.

The overall success of NPF4 will rely on its relationships to and its sense of fit with other overarching strategies and policies from world, national, regional and local levels. The planning system can be a facilitator of the Place Principle and place based approaches in order to achieve net zero carbon targets.

We also support the 5 main themes set out for further development.

• Prioritisation emissions reduction
• Integration of land use and transport
• Facilitation of design solutions and innovation
• Promotion of nature-based solutions
• Delivery of infrastructure to reduce emissions

RTPI Scotland would however welcome stronger recognition of the role that proactive planning and place-leadership can take in maximising the opportunities of a green industrial revolution, growing economies linked to “green” sectors and replacing jobs lost in fossil fuel-based industries.

2. Do you agree with our current thinking on planning for resilient communities?

YES. This is a particularly strong section within the proposed NPF4 reflecting the wide views expressed in support of involvement, participation and collaboration in achieving quality places and communities.

8 key action areas are identified for inclusion in the new spatial strategy as follows:

• Application of the concept of 20 - minute neighbourhoods
• Strengthening community resilience
• Promoting inclusion and eliminating discrimination
• Improving health and wellbeing
• Actively planning for and supporting the delivery of good quality homes
• Promoting an infrastructure first approach to community development
• Enhancing and expanding green infrastructure
• Achieving more sustainable travel

RTPI Scotland advocates the further roll out and investment in blue and green infrastructure across Scotland which is cross - cutting other themes such as climate change, flooding, quality places and spaces etc.

We are pleased to see a planned shift away from maintain a 5-year land supply to a new approach which is looking at the longer-term prospects around deliverability and viability. We also support the crucial role to be played by Housing land Audits and welcome the move to make them clearer and more consistent. RTPI Scotland would be happy to be further involved in this work area to assist the Scottish Government.

3. Do you agree with our current thinking on planning for a wellbeing economy?

YES. The new spatial strategy envisages Scotland will be healthier, fairer and more prosperous and future development will contribute to a green, sustainable and inclusive economic recovery and RTPI Scotland welcomes and endorses this approach.

The role of emerging regional scale spatial and economic strategies will need to align with city and regional growth deals and the work of Regional Economic Partnerships and Regional Land Use Partnerships.

Important components of this will include community wealth building initiatives (East and South Ayrshire) and sustainable tourism across Scotland.

To engineer a shift from economic growth to a well-being economy is truly transformational but it will demand a level of intervention in development and investment processes and their redistribution to sustainable locations and geographic centres where the need is greatest. How this can possibly be coordinated at a spatial, national level is the biggest challenge the Scottish Government will face in this process of realignment.

The bringing together of future investment and infrastructure projects is also an objective which we strongly support but the detail behind this will require unprecedented cooperation and joint working arrangements to be introduced and managed.

The role of positive planning policies and strategies in the sustainable tourism sector are identified as vital components to be further developed and we look forward to seeing how this can be achieved in a post-pandemic recovery scenario and contributing to that process.

Stimulation of the culture and creative industries across Scotland is another vital element in the future thinking and we see it as a means of stimulating regeneration in deprived areas and other “non-natural” locations to also assist in the sustainability, well-being and empowering local communities.

Securing strategic transport and digital connectivity are crucial elements in the spatial strategy.

4. Do you agree with our current thinking on planning for better, greener places?

YES. The initiatives set out in this section are supported including Town Centre Action Plans, Land Use Strategy, Place Principle and stronger policies on design and place making. This is an area where, despite many previous attempts and some notable exceptions, design of new developments, particularly in housing, can be disappointing and average. This is a crucial area which should be able to be make good design a mandatory planning requirement and eliminate tokenism and mediocrity.

We strongly support the priority re-use of vacant and derelict land particularly where it is located in deprived communities. A presumption in favour of brownfield development should be mandatory and greenfield development should be the short and medium-term exception.

The future proofing of natural and historic assets and the re-use of historic buildings should always be core policies in local development plans.

There is an urgent need to re-engineer our town centres post pandemic as the damage caused to the retail sector in particular has changed the economic landscape and basic functions of town centres and city centres for good. This will require new approaches, legislation and a flexibility of mindsets to “localise” and diversify our town centres and the land uses within them. This reinvention must be holistic in nature and be part of an overall regional spatial strategy which also reflects the changing roles of out of centre retail parks and similar developments who are also having to look for a new identity and purpose.

5. Do you have further suggestions on how we can deliver our strategy?

YES. RTPI Scotland considers the proposals set out in the Position Statement to be laudable and supportable. In terms of the themes of the key outcomes there is an opportunity to provide more clarity and readability. Many of the issues considered underneath each outcome do not sit within them neatly and often heavily interact and intersect with other issues and other outcomes. To support this RTPI Scotland would advocate for a clearer and simplified approach towards the outcomes using the three pillars of sustainable development of people, planet and economy.

RTPI Scotland see delivery as one of several real challenges to the implementation of the strategy. A Delivery Programme will be essential, as proposed, but it needs to have resources and costs at its heart and it needs to clearly set out the linkages and relationships between all the participating partners, of which there are many.

It is acknowledged in the Position Statement that there has to be a collective approach to delivery across the different scales of planning, national, regional and local and this synchronisation and coordination will be fundamental and critical to successful implementation.

The further development of an infrastructure first approach has to embedded into these processes as recommended by the Infrastructure Commission for Scotland. RTPI Scotland wishes to see the establishment of an independent, specialist body to coordinate and provide strategic, upfront and long-term infrastructure advice to Scottish Government and to identify resources required for delivery. To assist this, RTPI Scotland would welcome a clearer definition of what infrastructure first means

The planning tools cited, developer contributions, land assembly, compulsory purchase and Masterplan Consent Areas are all seen as an integral part of this refocussed approach and RTPI Scotland is willing to contribute further to their further development and enhancement.

6. Do you have any comments on the Integrated Impact Assessment Update Report, published alongside this position statement?

No comment

7. Do you have any other comments on the content of the Position Statement?

YES – please see summary response for other comments.