Draft National Planning Framework 4 Consultation Response

Sustainable places. Our future net zero places will be more resilient to the impacts of climate change and support recovery of our natural environment. Do you agree that this approach will deliver our future net zero places which will be more resilient to the impacts of climate change and support recovery of our natural environment?

RTPI Scotland is concerned that the summary sections on Sustainable, Productive, Liveable and Distinctive Place when 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.

Liveable places. Our future places, homes and neighbourhoods will be better, healthier and more vibrant places to live. Do you agree that this approach will deliver our future places, homes and neighbourhoods which will be better, healthier and more vibrant places to live?

See above answer.

Productive places. Our future places will attract new investment, build business confidence, stimulate entrepreneurship and facilitate future ways of working – improving economic, social and environmental wellbeing. Do you agree that this approach will deliver our future places which will attract new investment, build business confidence, stimulate entrepreneurship and facilitate future ways of working – improving economic, social and environmental wellbeing?

See above answer.

Distinctive places. Our future places will be distinctive, safe and pleasant, easy to move around, welcoming, nature-positive and resource efficient. Do you agree that this approach will deliver our future places which will be distinctive, safe and pleasant, easy to move around, welcoming, nature-positive and resource efficient?

See above answer.

Distinctive places. Our future places will be distinctive, safe and pleasant, easy to move around, welcoming, nature-positive and resource efficient. Do you agree that the spatial strategy will deliver future places that overall are sustainable, liveable, productive and distinctive?

See above answer.

Spatial principles. Do you agree that these spatial principles will enable the right choices to be made about where development should be located?

Whilst RTPI Scotland very much 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. Also, the ‘balanced development’ principle (that we imagine is intended to be implicit throughout the Framework) has not been explicitly included anywhere else in the document despite the fact that it could form an important policy basis for development management decisions.

RTPI Scotland is also concerned that the spatial principles could complicate decision making, with the development management planner potentially having to consider applications against 6 spatial principles, 32 National Planning Policies (NPPs), any adopted Local Development Plans (LDPs) Regional Spatial Strategies (RSSs), Local Place Plans (LPPs) alongside any other material considerations.

If this section is retained, RTPI Scotland would welcome the inclusion of the Infrastructure First principle within it and the retention of the spatial principle from Scottish Planning Policy of ‘the right development in the right place’.

Spatial Strategy Action Areas. Do you agree that these spatial strategy action areas provide a strong basis to take forward regional priority actions?

RTPI Scotland welcome the intention to provide much needed vision and support for regional development in Scotland. 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, additional clarification through Scottish Government guidance would be useful. It is assumed these are the policy and spatial frameworks that will inform the emerging Regional Spatial Strategies. If this is the case then more clarity is needed on the role of RSSs and LDPs. This is especially important as the draft LDP regulations and guidance does not provide any clarity on the matter either.

RTPI Scotland are concerned that the Spatial Strategy Actions Areas overlap which may cause confusion. We are also concerned that they are not geographically aligned with other regional strategies produced by Scottish Government, for example the regions set out in draft Strategic Transport Project Review 2. 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. The text covering the action areas is 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.

North and west coastal innovation. Do you agree with this summary of challenges and opportunities for this action area?

No comment.

North and west coastal innovation. What are your views on these strategic actions for this action area?

No comment.

Northern revitalisation. Do you agree with this summary of challenges and opportunities for this action area?

No comment.

Northern revitalisation. What are your views on these strategic actions for this action area?

No comment.

North east transition. Do you agree with this summary of challenges and opportunities for this action area?

No comment.

North east transition. What are your views on these strategic actions for this action area?

No comment.

Central urban transformation. Do you agree with this summary of challenges and opportunities for this action area?

No comment.

Central urban transformation. What are your views on these strategic actions for this action area?

No comment.

Southern sustainability. Do you agree with this summary of challenges and opportunities for this action area?

No comment.

Southern sustainability. What are your views on these strategic actions for this action area? What are your views on these strategic actions for this action area?

No comment.

National Spatial Strategy. What are your overall views on this proposed national spatial strategy?

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 the 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 or clarification of this wording.

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 deliver these aspirations and ambitions 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 and deliver the NPF’s ambitions
each and every policy in the Framework provides clarity and certainty to give confidence to decisions makers to deliver the outcomes for the NPF4 set out in the Planning (Scotland) Act 2019
alignment is in place with other strategies and that all of 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 has 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 especially with regards to the making the most of the potential from mapping spatial data

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 as the Framework is to form part of the statutory development plan which means that it will need to be read alongside a complex array of other strategies and plans including, for example, LDPs and LPPs. Given this, RTPI Scotland would advocate for the drafting and publication of an easy read guide to sit alongside an updated ‘Guide to the Planning System in Scotland’. This could include a version aimed at children and young people.

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 that the NPF4 should demonstrate an innovative modern approach to a digital policy document, for example through the digital layering policy and place information.

Do you think that any of the classes of development described in the statements of need should be changed or additional classes added in order to deliver the national development described?

No comment.

Is the level of information in the statements of need enough for communities, applicants and planning authorities to clearly decide when a proposal should be handled as a national development?

RTPI Scotland is concerned over a lack of clarity in some of the National Development descriptions. For example, locational information is vague regarding Dundee and Edinburgh Waterfront and there need for clearer wording on policy requirements for consideration in the urban sustainable blue and green drainage solutions National Development.

Do you think there are other developments, not already considered in supporting documents, that should be considered for national development status?

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 lies in the implementation of the plan. 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.

Beyond sourcing funding for these projects, collaborative delivery will be crucial. This is especially true for Nationals Developments where other consenting regimes are the primary mechanism for delivery such as renewable energy developments over 50MW or the Digital Fibre Network. RTPI Scotland also believes that aligning the national developments with emerging Regional Spatial Strategies and the National Economic Transformation Strategy (NEST) will be key in ensuring their successful delivery. RTPI Scotland is extremely disappointed to see a very weak reference to the NPF4 in NSET and would like to stress that the success of this Framework will be reliant on strong reciprocal linkages across Scottish Government Policies and Frameworks.

To improve the read-across of document as a whole it may be worth exploring the value of linking this section to part 3 – for example by referencing National Development 10 in Policy 19 or National Development 2 and Policy 10.

This section is very lengthy which may affect 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.

Sustainable Places. We want our places to help us tackle the climate and nature crises and ensure Scotland adapts to thrive within the planet’s sustainable limits. Do you agree that addressing climate change and nature recovery should be the primary guiding principles for all our plans and planning decisions?

RTPI Scotland supports the intentions for planners to be leading on the twin climate and nature crisis. However, the success of planners in being able to achieve this very much lies in the usability of the document as a whole and whether it contributes to an effective consenting process.

There are a number of other additional and expanded policies on a range of matters set out in the Framework, which whilst in many cases are laudable, may have unintended consequence of complicating and obfuscating the primary aims of the planning system and the role of the decision maker in addressing the climate and nature crisis. For example, it is not clear if the nature crisis policy is to be given more weight than any another policy in the Universal Policy section such as Community Wealth Building. It is also not clear that policies within the Universal Policy section should receive more weight in the decision making process than that of other NPPs, beyond the one time use of the word ‘significant’ in the Global Climate Emergency policy. Considering in tandem the range of policy concerns and issues to be address in the 6 Spatial Principles set out in part 1 it is not clear that addressing the climate change and nature recovery are the primary guiding principles for plans and planning decisions. We believe they should be, and this should be clearly articulated in the framework. If Scottish Government wish to move to a system without a clear prioritisation mechanism, where every proposal may be subject to a complex combination of policy matters, it should not be assumed that the user of this document implicitly understands this and be set out clearly at the front of the document.

Whilst RTPI Scotland welcomes the incorporation of SPP in the Framework, and hope it provides certainty and consistency we have a number of concerns over the coherence of the document including:

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

Throughout part 3, RTPI Scotland is concerned over the regular use of the expression ‘should’ relating to the application of policies. Whilst RTPI Scotland recognises the policy drafting convention followed by Scottish Government there is still the concern that in many cases this could cause ambiguity over whether policies must be complied with. Potentially this could weaken some of the laudable aspirations of the Framework and make clear decision-making more difficult. Whilst we understand that the word ‘must’ is only to be used to set out a statutory obligation amending the wording to ‘expected to’ instead of ‘should’ might provide a clearer indication of what is being asked of the decision maker.

The policies must 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. To support the decision maker RTPI Scotland believe that the NPPs section could be strengthened through providing better context for the policies through supporting text. This will set out the parameters, aims and objectives and provide rational for NPPs.

RTPI Scotland recommends that the wording of a number of NPPs be tightened up and made more succinct. Abridging a number of policies might remove some uncertainty in the system through fewer ‘shoulds’ and potentially reduce the resourcing impact of the Framework on planning authorities. RTPI Scotland would also recommend the review of the need for development planning policies to be contained within the Framework or be set out in the development planning regulation and guidance instead therefore respecting the principle of subsidiarity and creating a more user friendly, concise document.

As the NPPs will, once adopted, be used to determine individual applications across the country for the next ten years, it essential that they are fit-for-purpose. The Institute is cognisant that whilst some of the NPPs as drafted are sound or only in need minor amendments, others will need more significant rewrites and will then need to be mapped back across the other NPPs to avoid conflicting and contradictory wording or processes. RTPI Scotland has concerns that this will not be able to be done thoroughly by June, as currently proposed by Scottish Government. It is important that any new policies are sound and robust and given this we recommend that Scottish Government review this timeframe, potentially extending the review period following consultation to allow for such changes to be carefully made. Importantly, and as part of the necessary stress testing of the NPPs, we recommend that Scottish Government continue the collaborative nature of the consultation period so far and explore the feasibility of setting up working groups with key stakeholders to support policy redrafting.

Policy 1: Plan-led approach to sustainable development. Do you agree with this policy approach?

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 that embeds the need to make decisions based on the wellbeing of future generations. This could build upon the future generations ambitions of the Welsh Government in the Well-being of Future Generations (Wales) Act 2015[2], bearing in mind the role of the Future Generations Commissioner is due to be established in Scotland within the parliamentary term.

Policy 2: Climate emergency. Do you agree that this policy will ensure the planning system takes account of the need to address the 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. Do you agree that this policy will ensure that the planning system takes account of the need to address the 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.

Policy 4: Human rights and equality. Do you agree that this policy effectively addresses the need for planning to respect, protect and fulfil human rights, seek to eliminate discrimination and promote equality?

RTPI Scotland strongly supports 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. However we have 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, the Public Sector Equality duty or Equalities Impact Assessments undertaken as a part of the LDP preparation process. Additional guidance is needed on the matter, or that this policy 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 this.

RTPI Scotland is unclear of the purpose of this area being included as a policy as community consultation and engagement is captured elsewhere by relevant legislation and good practice guidance. The Institute would suggest that it be more meaningfully captured as a Spatial Principle instead. To better support communities from a policy perspective, RTPI Scotland would recommend a strengthened weighting for development proposals which are community-led throughout the Framework.

Policy 5: Community wealth building Do you agree that planning policy should support community wealth building, and does this policy deliver this?

RTPI Scotland strongly supports 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. This policy therefore needs to be tested in its application on development proposals. Policy 5(a) may be improved by directing LDP Strategies or a Local Outcome Improvement Plan to have regard to any Community Wealth Building Strategy produced by the local authority.

RTPI Scotland recommends setting out Community Wealth Building as a spatial priority, or merge an abridged version of this policy to Policy 16 land and premises for business and employment to help the decision maker meaningfully apply it.

As suggested earlier, moving policy 4 & 5 to Spatial Principles in the Universal Policy section would more clearly demonstrate that the addressing climate change and nature recovery were the key guiding principles of the planning system, especially if this was established as priority.

Policy 6: Design, quality and place. Do you agree that this policy will enable the planning system to promote 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 advocates 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 would like to see 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. Do you agree that this policy sufficiently addresses the need to support local living?

RTPI Scotland is 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 believes the policy could be combined with policy 6 to strengthen both.

This policy could be strengthened with the connection to the Spatial Principle on compact growth. To avoid confusion or conflict regarding living locally in a rural location, additional information and caveating should be provided, for example as set out in para 453 of the draft LDP guidance.

Policy 8: Infrastructure First. Do you agree that this policy ensures that we make best use of existing infrastructure and take an infrastructure-first approach to planning?

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 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. However we believe that this alignment should work both ways with these strategies being guided by NPF4. RTPI Scotland also supports the specific reference to sustainable travel and investment hierarchies.

The Institute would wish to see specific reference to Regional Spatial Strategies included in this section given their role in identifying strategic development for areas of more than one planning authorities. 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.

RTPI Scotland is of the view that there needs to a clear and shared definition of infrastructure in Infrastructure First policy and the Infrastructure Investment Plan to also include, for example, green infrastructure.

Policy 9: Quality homes. Do you agree that this policy meets the aims of supporting the delivery of high quality, sustainable homes that meet the needs of people throughout their lives?

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 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.”

RTPI Scotland believes this policy could be better strengthened setting out clearly the links to Building Standards.

Policy 10: Sustainable transport. Do you agree that this policy will reduce the need to travel unsustainably, decarbonise our transport system and promote active travel choices?

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 that will 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 decarbonisation 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 as a matter of urgency.

Policy 11: heat and cooling. Do you agree that this policy will help us achieve zero emissions from heating and cooling our buildings and adapt to changing temperatures?

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. We believe a broader and ambitious approach could be established which takes a whole-systems approach to energy planning.

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.

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.

Again, RTPI Scotland believe this policy could be better strengthened by setting out clearly the links to Building Standards and requirements on heat and insulation efficiency, passive and natural solutions and design concepts.

Policy 12: Blue and green infrastructure, play and sport. Do you agree that this policy will help to make our places greener, healthier, and more resilient to climate change by supporting and enhancing blue and green infrastructure and providing good quality local opportunities for play and sport?

RTPI Scotland broadly 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. Whilst there are clear synergies between blue/green infrastructure and play and sport, it may be more appropriate to move play and sport to an expanded cultural policy labelled ‘leisure’ or into the health and well-being policy. The RTPI have set out advice on creating child friendly places in a recently published Practice Advice Note[5].

Policy 13: Sustainable flood risk and water management. Do you agree that this policy will help to ensure places are resilient to future flood risk and make efficient and sustainable use of water resources?

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. Given the Climate Change Committees recent appraisal of Scotland’s readiness for climate change highlighting poor performance in handling flood risk and water management[6], opportunities to strengthen this policy might need to be explored and appropriate resources allocated.

RTPI Scotland are aware that some of the wording in this policy might be overly blunt and cause problem for delivery offshore wind grid connections onshore.

Policies 14 and 15 – Health, wellbeing and safety. Do you agree that this policy will ensure places support health, wellbeing and safety, and strengthen the resilience of communities?

RTPI Scotland supports the new policy on lifelong health and wellbeing, aiming to create healthier places and requiring a Health Impact Assessment for proposals considered likely to generate significant health effects. RTPI Scotland would however like to raise the potential resource implications of the new Health Impact Assessment for planning authorities. More clarity and guidance will be need for planning authorities to carry out these assessments alongside a nationwide upskilling programme.

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. We also support the presumption against development that will significantly adversely affect air quality or generate unacceptable noise.

Policy 16 – land and premises for business and employment. Do you agree that this policy ensures places support new and expanded businesses and investment, stimulate entrepreneurship and promote alternative ways of working in order to achieve a green recovery and build a wellbeing economy?

RTPI Scotland supports the requirement for LDPs to identify employment land and support business development as well as alternative ways of working including 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. Do you agree that this policy will help to inspire people to visit scotland, and support sustainable tourism which benefits local people and is consistent with our net-zero and nature commitments?

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 like to see the 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. Do you agree that this policy supports our places to reflect and facilitate enjoyment of, and investment in, our collective 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 Do you agree that this policy will ensure our places support continued expansion of low carbon and net-zero energy technologies as a key contributor to net-zero emissions by 2045?

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’ (as currently done in SPP) and share concerns with other stakeholders that it is somewhat weakened by changes to other policies in the Framework.

Policy 20: Zero waste. Do you agree that this policy will help our places to be more resource efficient, and to be supported by services and facilities that help to achieve a circular economy?

The Institute broadly 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 with the length of this policy and that requirements for compliance with this policy needs more clarity, especially in regards to the proposed preparation of a decarbonisation strategy.

Policy 21: Aquaculture. Do you agree that this policy will support investment in aquaculture and minimise its potential impacts on the environment?

RTPI Scotland supports 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.

RTPI Scotland believes more detail can be brought to this policy whilst there is a need to clarify the responsibilities of different agencies.

Policy 22: Minerals. Do you agree that this policy will support the sustainable management of resources and minimise the impacts of extraction of minerals on communities and the environment?

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. More clarity on what a is considered ‘high standard’ of restoration and aftercare of schemes is desired. RTPI Scotland are aware that mineral planning is a specialist area and that many planning authorities will require planners with these skills.

Policy 23: Digital infrastructure. Do you agree that this policy ensures all of our places will be digitally connected?

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. Do you agree that these policies will ensure Scotland’s places will support low carbon urban living?

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. We also support the policies promoting 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 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.

RTPI Scotland welcome the Town Centre First Assessment Policy and we hope it helps put the health of town centres at the heart of decision-making processes.

RTPI Scotland believes this section could be further strengthened with reference to the Place Principle.

Policy 28: Historic assets and places Do you agree that this policy will protect and enhance our historic environment, and support the re-use of redundant or neglected historic buildings?

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, such as the approach taken for policy 3 and the Developing with Nature Guidance.

Policy 29: Urban edges and the green belt. Do you agree that this policy will increase the density of our settlements, restore nature and promote local living by limiting urban expansion and using the land around our towns and cities wisely?

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. Do you agree that this policy will help to proactively enable the reuse of vacant and derelict land and buildings?

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. RTPI Scotland believe that the policy could be further strengthened through clearer reference to the public sectors leading role in regeneration in a similar manner to ‘Future Wales: The National Plan 2040’. RTPI Scotland expect the Delivery Plan to set out how unviable or high risk sites can be brought forward.

Policy 31: Rural places. Do you agree that this policy will ensure that rural places can be vibrant and sustainable?

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 recently published thinkpiece[7]. RTPI Scotland would advocate for policy wording set out in the draft LDP guidance on this matter to be brought through into NPF4 to give it more primacy, especially para 456.

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. Do you agree that this policy will protect and restore 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. Do you agree that this policy protects carbon rich soils and supports the preservation and restoration of peatlands?

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: Do you agree that this policy will expand woodland cover and protect existing woodland?

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. RTPI Scotland are concerned about the skills and expertise available to planning authorities to assess carbon sequestrations, which is complex and specialist. In terms of an urban setting the policy could be stronger in encouraging new street trees to be designed into developments. RTPI Scotland are aware that 34 (b) might be overly blunt and cause acute problems for delivery of energy networks.

Policy 35: Coasts. Do you agree that this policy will help our coastal areas adapt to climate change and support the sustainable development of coastal communities?

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.

Do you agree with our proposed priorities for the delivery of the spatial strategy?

RTPI Scotland is disappointed that no draft Delivery Plan was published alongside the draft NPF4, to get an indication of how the NPF4’s ambitions and priorities will be implemented. A delivery plan needs to be taken forward collaboratively and urgently. RTPI Scotland believes that as a part of the delivery plan, a capital investment programme be published setting out funding and finance to support the delivery of the Framework.

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 regard. 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 were not fairly recognised in the Integrated Impact Assessment Partial Business & Regulatory Impact Assessment (Appendix B).

There is a need to take account of the context of diminishing resources and increased workloads in planning authorities with recent research from RTPI Scotland[8] 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[9] RTPI Scotland does not believe this will bring in the adequate resources for the planning service to undertake its statutory duties and deliver the Framework. 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. RTPI Scotland is happy to work with Scottish Government on this.

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 (IIP) with the spatial priorities guiding future public sector investment. We are however concerned that the current 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 Deals and Regional Growth Deals, and vice versa.

Development Plan Policy and Regional Spatial Strategies

RTPI Scotland is of the view that it would be helpful to have explanation as to how the various parts of LDPs will interact with the content of the NPF. There may arise 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 more clarity as to how Regional Spatial Strategies are to align with the Framework. A graphical representation would be useful here to support users in understanding the system, such as the one provided in Figure 2 of the draft LDP guidance.

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[10], a user and customer impact analysis[11] setting out the benefits for planning authorities, planning applicants and communities and a policy impact analysis[12] 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 SPP 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 that Scottish Government should establish a delivery oversight group, which includes representatives from younger generations, to report on progress being made and implications of changing contexts on annual basis.

RTPI Scotland is 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[13] 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.

Do you have any other comments on the delivery of the spatial strategy?

RTPI Scotland has 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 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

Annex A. Do you agree that the development measures identified will contribute to each of the outcomes identified in section 3A(3)(c) of the Town and Country Planning (Scotland) Act 1997?

No comment.

Annex B. Do you agree with the minimum all-tenure housing land requirement (mathlr) numbers identified above?

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.

Annex C. Do you agree with the definitions set out above? Are there any other terms it would be useful to include in the glossary?

RTPI Scotland would like to see a tightening up of undefined and unclear tests such as ‘nature positive’ and providing a number of additional definitions such as ‘nature networks’. A strong edit will need to be done of the Framework to ensure that terms are used in a consistent manor e.g. relating to renewable/green/blue hydrogen, Sustainable Urban Drainage Systems and 20 minute neighbourhoods.

Environmental Report. What are your views on the accuracy and scope of the environmental baseline set out in the environmental report?

No comment.

Environmental Report. What are your views on the predicted environmental effects of the draft NPF4 as set out in the environmental report? Please give details of any additional relevant sources.

No comment.

Environmental Report. What are your views on the potential health effects of the proposed national developments as set out in the environmental report?

No comment.

Environmental Report. What are your views on the assessment of alternatives as set out in the environmental report?

No comment.

Environmental Report. What are your views on the proposals for mitigation, enhancement and monitoring of the environmental effects set out in the environmental report?

No comment.

Society and Equalities Impact Assessment. What are your views on the evidence and information to inform the society and equalities impact assessment?

No comment.

Society and Equalities Impact Assessment. Do you have any comments on the findings of the equalities impact assessment?

No comment.

Society and Equalities Impact Assessment. Do you have any comments on the findings of the children’s rights and wellbeing impact assessment?

No comment.

Society and Equalities Impact Assessment. Do you have any comments on the fairer Scotland duty and the draft NPF4?

No comment.

Society and Equalities Impact Assessment. Do you have any comments on the consideration of human rights and the draft NPF4?

No comment.

Society and Equalities Impact Assessment. Do you have any comments on the islands impact assessment?

No comment.

Business and Regulatory Impact Assessment. Do you have any comments on the partial business and regulatory impact assessment?

RTPI Scotland are disappointed to see that clear cumulative resource burden of the Framework on planning authorities not recognised in the partial BRIA.

[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.rtpi.org.uk/practice/2021/july/children-and-town-planning-creating-places-to-grow/

[6] https://www.theccc.org.uk/publication/is-scotland-climate-ready-2022-report-to-scottish-parliament/

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

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

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

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

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

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