RTPI Scotland's Response to 'Local Living and 20-Minute Neighbourhoods: Draft Planning Guidance' Consultation

Question 1: How helpful is Part 1 of the guidance to further the understanding of local living and 20-minute neighbourhoods in a Scottish Context?

Very Helpful

RTPI Scotland is largely supportive of the approach taken in preparing Part 1 of this guidance document. RTPI Scotland’s briefing paper on implementing 20-minute neighbourhoods[1] highlighted the importance of ensuring that the fundamental tenets of 20-minute neighbourhoods are embedded into policy, including planning policy, transport policy, open space policies etc. as well as into development management procedures, including the pre-application process, planning obligations and performance assessments. The principles of local living and 20-minute neighbourhoods have a critical role to play in Scotland’s delivery of NPF4, the Climate Change Plan, the National Performance Framework, and the UN SDGs, and we are pleased to see the strong links made in this section to these broader national and global targets and objectives. We are also pleased to see recognition in this section of the far-reaching implications of local living and 20-minute neighbourhoods in relation to enhancing health and wellbeing, tackling the climate and nature emergencies, and creating vibrant local economies, as well as the important links to other national policy initiatives, such as Housing 2040, the Town Centre Action Plan, and Scotland’s retail and transport strategies. RTPI Scotland have previously advocated for a clear and holistic definition, vision and approach to be embedded in policy for implementing 20-minute neighbourhoods. To achieve these ambitions a holistic approach must be taken across all policies, guidance and procedures.

This type of holistic approach will rely on the successful cross-sectoral application of the Place Principle. We are encouraged that the Principle features in the guidance as key to the successful delivery of 20-minute neighbourhoods; together with existing tools as the Place Standard and Place Based Framework. The Place Principle supports collaborative place-based action, and the Place Standard is a commonly used tool to help people think about the quality of their place and where action might be required. The prominence of the Place Principle and Place Standard in this guidance reflects the Scottish Government’s consistent approach to delivering place-based outcomes, which the Institute fully supports.

Notwithstanding the above, we wish to stress that if the Place Principle is to have overarching effectiveness across all sectors and communities in Scotland, it must be properly operationalised to ensure that it effectively influences policy, practice and investment on the ground. RTPI Scotland believe that there is a need for a stronger framework for embedding the Place Principle into all policy-, plan- and decision-making practices. Furthermore, in order to ensure the ongoing effectiveness of policy and guidance (such as this local living guidance) in implementing the Place Principle, measures should be introduced to ensure that public authorities publicly report on how they have embedded the Principle in their approaches and how they have applied it in their decision-making, including any reasoning.

Part 1 of the guidance recognises that achieving local living and 20-minute neighbourhood principles requires more than an assessment of the physical context of place, but also the social and economic contexts. Whilst we agree with this, we believe there should also be greater attention paid to the diverse community context of Scotland’s places. Afterall, not all communities are the same and not all individuals in a community are the same. Much research has been undertaken about the implications of spatial planning policy and design practices on individuals of different age groups, genders, racial identities and disabilities (to name a few). For example, RTPI research on women[2], children[3], and individuals living with dementia[4] reveals the many barriers that individuals can face because public spaces were not designed with their needs in mind. The implementation of local living and 20-minute neighbourhood principles represents an opportunity to tackle the deep-seated spatial inequalities that are currently present in our built environments. It is vital, therefore, that this guidance document acknowledges these inequalities and the role of local living and 20-minute neighbourhood principles in tackling them head on. Although reference is made to tackling “inequalities” throughout the document and Annex A of the guidance draws some attention to this issue in the additional information related to ‘influence and sense of control’, RTPI Scotland does not believe that sufficient attention has been paid to what is meant by “inequalities” or to the specific role of local living and 20-minute neighbourhood principles in tackling spatial inequalities. This needs to be addressed and made clear up front in this guidance.

We are pleased to see an acknowledgement in this guidance of the different needs of rural and urban communities in implementing local living principles. RTPI Scotland’s think piece on “The National Planning Framework 4 and Rural Planning”[5] highlights a number of challenges facing rural communities in the 2020s, including population decline, sustainable transport, affordable housing and other key infrastructure etc. The implementation of local living and 20-minute neighbourhood principles represents an opportunity to address some of these challenges through a spatial planning lens. The RTPI’s recent research on Rural Planning in the 2020s found that cross-boundary partnership working which brings together local authorities, communities and other stakeholders can have transformative implications. Similarly, research undertaken by RTPI Cymru entitled “Living Locally in Rural Wales” found that “creativity, partnership working, funding, flexibility and understanding of the issues and impacts, along with a holistic approach will all be important factors in working towards more local living” in rural areas.[6]  A recent report commissioned by Hitrans and Sustrans entitled ‘Living Well Locally’[7] concludes that “20 Minute Neighbourhoods could be as good a fit for rural Scotland as for urban Scotland” provided some adjustments are made to our thinking around:

• Travel – broadening sustainable travel beyond walking and cycling to include any sustainable transport option, such as public transport, community transport and electric vehicles (recognising that cars will continue to be a required form of transport in rural Scotland).
• Flexible targets – understanding that an acceptable travel distance to achieve local living will vary in different places and the focus should not be on a specific number (i.e. 15, 20, or 30 minutes).
• Language – replacing the word “neighbourhoods” with “communities” to ensure the language appropriately captures rural as well as urban areas.

 

Question 2: Please refer to the Local Living Framework Diagram on page 19 of the guidance. How helpful is the framework diagram in encouraging flexible, place-based approaches to support local living?

 

Very Helpful

RTPI Scotland welcomes the consistent approach taken by the Scottish Government by integrating the Place Standard Tool in the Local Living Framework Diagram of this guidance. Since its launch in December 2015, The Place Standard Tool has been used by a range of community groups, practitioners, and organisations across Scotland and internationally in a variety of different ways and at varying scales to carry out assessments of place and to inform spatial planning and decision-making. Integrating the Place Standard into the guidance will help to further enhance the Tool’s credibility and standing. It will also help to better position the Place Standard as an outcomes-based delivery tool.

Notwithstanding the above, individuals and communities in Scotland will likely interact with, interpret and seek to implement the Framework in different ways. Careful consideration will need to be given to the implementation of this Framework, to ensure that its application adequately addresses the spatial inequalities faced by a variety of individuals daily (and particularly those individuals who may not actively engage in local authority consultation and engagement exercises).

In the above regard, we note that the Scottish Government has released a consultation on “Effective Community Engagement in Local Development Planning Guidance”, which is due to close on 13 September. This Community Engagement Guidance should be referenced as an important tool in the delivery of the local living principles set out in this guidance. These guidance documents are very much interrelated and, as such, it is vital that they work together to successfully deliver the ambitions of NPF4. This interrelationship should be highlighted within the guidance documents themselves to ensure a holistic approach is taken with respect to their implementation. Although specifically targeted at community engagement with respect to the LDP process, the Effective Community Engagement guidance could also be useful in ensuring the equitable delivery of the local living and 20-minute neighbourhood principles in general and, consequently, should be referenced within this guidance document as an important delivery tool.

 

Question 3: Looking at part 2 of the draft guidance: how helpful are the ‘categories’ and ‘key considerations for local living’ that are captured within this part of the document?

 

Somewhat Helpful

Although useful as a guide, it should be made clear in this guidance that the categories and key considerations set out in Part 2 are not an exhaustive list. Communities are all different, with different challenges, and there needs to be scope within this guidance to capture these unique differences. Although Part 2 of the guidance does state the importance of flexibility and that this should not be a tick-box exercise, there is the risk that listing ‘key considerations’ in this structured fashion could inadvertently encourage this type of tick-box form of assessment. This risk could potentially be mitigated by including a statement in Part 2 that each local authority/community/group/individual etc. should, as a first step of implementing the guidance, critically review the key considerations listed in the document to determine if additional considerations should be added that are relevant to the local area in question.

In addition to the above, we believe that the following alterations should be made to the key considerations if they are to form part of the final guidance document:

• Beyond the ‘Feeling Safe’ theme, the words ‘safe’ and ‘safety’ are noted as key considerations only twice in this part of the guidance – under the themes of ‘Moving Around’ and ‘Traffic and Parking’. RTPI Scotland believes that safety should, in fact, be a key consideration under every theme, but particularly the themes of ‘Public Transport’, ‘Streets and Spaces’, ‘Natural Space’, ‘Play & Recreation’, ‘Facilities & Services’, ‘Housing & Community’, and ‘Social Interaction’. RTPI research on Women and Planning revealed that feelings of insecurity and a lack of safety are significant barriers to many women and girls when it comes to utilising a variety of public spaces, services and facilities, including (but not limited to) public transport, public parks, and recreational facilities. Research[8] has shown that it is not only women that experience barriers related to feeling unsafe in public spaces, and that implementing planning and design changes that look through a gendered lens can have wide-reaching health and wellbeing benefits across the whole of society. By incorporating ‘safety’ as a key consideration across all themes, this would then provide a vital connection between these themes and the ‘Feeling Safe’ theme, which should not be considered in isolation.

It is also important to remember when assessing the ‘safety’ or our public spaces, that perceptions of safety are not fixed. They can vary depending on the time of day, time of year, how active a space is at any given time, and the way the space is maintained over time (or not maintained). It is therefore important that the fluid nature of ‘safety’ be given due consideration in the ‘Feeling Safe’ theme of this guidance by including as key considerations, for example, the different feelings of safety that can be experienced during daylight hours and after dark (in addition to the different weather conditions already mentioned in this theme). ‘Maintenance’ should also be included as a key consideration in this theme after reference to ‘care’. The word ‘care’ suggests an informal collective approach by the community to looking after a space in their day-to-day use of that space. ‘Maintenance’ or ‘management’, on the other hand, suggests formal measures of upkeep and repair, which we would argue are equally important.

• We are pleased to see some recognition in this part of the guidance to the importance of the quality of certain services and facilities (rather than just their quantity and physical proximity). However, similar to our above point regarding ‘safety’, we argue that ‘quality’ should be extended as a key consideration across all themes. Currently, ‘quality’ is only referenced as a key consideration in relation to the themes of ‘Streets & Spaces’, ‘Play & Recreation’, ‘Facilities & Services’, and ‘Work & Economy’. Whilst we agree that ‘quality’ should be a key consideration in respect of these themes, we equally consider that ‘quality’ should be a key consideration with respect to the categories of:
  • Movement – particularly the quality of public transport services and pedestrian and cycle infrastructure, which could impact their usability. This relates to both their physical condition and their design – i.e. the physical condition of the surface and the widths of footpaths and cycle lanes, whether cycle routes are on-road or off-road etc.
  • Resources – Quality should also be a key consideration with respect to the ‘Housing & Community’ and ‘Social Interaction’ themes. The quality and condition of housing, community assets, communal facilities and social spaces are key to ensuring they contribute positively towards local living and 20-minute neighbourhoods. We should not assess these spaces on their mere existence, but on their active contribution towards health and wellbeing.
  • Civic – Quality of spaces has a key role to play in people’s identify and belonging and their feeling of safety within a space.
• As mentioned above, the implementation of local living and 20-minute neighbourhoods represents an important opportunity to tackle the deep-seated inequalities present in our built environments. We note that ‘inclusive’, ‘inclusivity’, and ‘tackling inequalities’ are referenced as key considerations under only 3 of the 14 themes (namely, ‘Moving Around’, ‘Streets & Spaces’, and ‘Social Interaction’). Although there is mention in the ‘Movement’ introductory paragraph about the importance of taking into account the transport needs of diverse groups, this does not go into sufficient detail about what the needs of these diverse groups are, and the negative consequences they face of having their needs overlooked. Consequently, we do not believe that this issue has been given sufficient weight in the guidance document and could result in the inequitable delivery of local living and 20-minute neighbourhoods. To remedy this, there needs to be greater clarity in the guidance as to what is meant by ‘inequalties’, as well as the important role that local living and 20-minute neighbourhoods play in tackling these. This could be better addressed in Part 2 of the guidance by:
  • Including in the introduction to the ‘Spaces’ category an acknowledgement of the different experiences of different groups of people relating to gender, age, race, ethnicity, disability etc. in using and moving around Scotland’s public realm, and the vital role that local living principles play in creating inclusive spaces.
  • Under the ‘Play & Recreation’ theme, the key consideration around the ‘variety & quality of play & recreation provision’ should not be restricted to consideration across age groups alone but should also include consideration across different genders and abilities.
  • Under the ‘Identity & Belonging’ theme, ‘inclusive design’ should be added as a further key consideration. The identity of an individual within a community and their sense of belonging to a place relies heavily on their ease of access to, movement through, and feelings of safety, security and ease within the space. It is important that inclusive design practices are adopted to ensure the equitable delivery of local living and 20-minute neighbourhoods.
• To achieve 20-minute neighbourhoods, it is not enough to simply assess the physical characteristics of a place in terms of housing, services, facilities and travel options. RTPI Scotland’s research on implementing 20-minute neighbourhoods[9] also recognises the importance of achieving higher densities to support 20-minute neighbourhoods – with an average density of 65 dwellings per hectare identified as an estimated requirement. Compact settlement patterns help to reduce the distances between homes and jobs and make more efficient use of existing transport infrastructure. Research has shown that larger settlements with high densities can provide a critical mass of population to support local services, improve economic productivity, reduce transport emissions, improve public health, and encourage greater social interaction. A stronger policy line in terms of density will be necessary to add more weight in the planning balance to the consideration of compact settlement form as opposed to existing local impact or landscape impact. Policy support needs to be continued for intensification of settlements especially through promotion of use of brownfield land. Other policy measures such as reduction in minimum parking standards will enhance opportunities to achieve gentle density and better quality placemaking. We believe there is opportunity within this guidance to recognise the importance of density in achieving local living and 20-minute neighbourhoods. This could be achieved by including ‘density’ as a key consideration under the ‘Housing & Community’ theme.
• We note that in the ‘Traffic Parking’ theme, consideration is given to delivery, uplift and loading. However, no mention is made of trades access and parking that may be required to carry out maintenance and repair works on both public and private land. We believe this should also be a consideration under this theme as well as delivery, uplift and loading.

Question 4: How helpful is the proposed ‘structured approach’ for use?

 

Very Helpful

RTPI Scotland supports the iterative process proposed as part of this structured approach. This type of cyclical process recognises that Scotland’s places are living, breathing, vibrant, diverse and continuously subject to change. Town planning has a crucial role to play in the design and development of high-quality spaces that prioritise health, happiness and the wellbeing of individuals and communities. The collaborative nature of town planning ensures a wide variety of stakeholders and actors are involved in creating and improving places over time. Understanding and planning for the shifting context of place in a collaborative and holistic manner which aligns with investment opportunities will be essential to the successful delivery of local living and 20-minute neighbourhood principles.

Notwithstanding the above, RTPI Scotland have concerns that current constraints on resourcing and funding could continue to act as a barrier to the successful delivery of local living and 20-minute neighbourhoods. Whilst we acknowledge that this guidance does not create additional policy requirements or duties on local authorities, there is an expectation that the successful implementation of this guidance will rely on its integration into LDP and LPP processes. RTPI Scotland have long held the view that the ability of local authority planners to deliver on the new format LDPs and to support communities in preparing LPPs will be hindered by their limited resources and budgets, which have decreased in real terms by 42% since 2009[10]. RTPI Scotland’s recent research[11] reveals that:

• Nearly a third of planning department staff have been cut 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.

RTPI Scotland’s response to the draft LDP guidance[12] expressed concerns that for planners to prepare the new style LDPs, significant upskilling will be required, which may require a nationwide training programme. We also raised concerns about the resource intensive nature of maintaining the LDP evidence base. We note that the local living guidance equally establishes a process for undertaking an ongoing review and evidence gathering process, which no doubt will feed into the evidence gathering and monitoring stages of the LDP process. Whilst RTPI Scotland supports this type of ongoing monitoring and review approach, we wish to highlight the resource intensive nature of this.

Likewise, the resource implications for communities wishing to produce LPPs, for planning authorities to support their development, and for plan implementation is a substantial concern for RTPI Scotland. We have previously[13] called upon the Scottish Government to provide dedicated resources to support LPPs in the form of a national grant scheme for communities (as has been established in England to support Neighbourhood Plans). In terms of funding allocation, we note the uneven uptake of neighbourhood planning in England where research has revealed a much lower uptake in urban and deprived communities with only 5% of completed plans in urban areas and just 6.7% of neighbourhood planning areas in the most deprived parts of the country. Therefore, any national grant scheme should target funding to communities sitting within the bottom 20% on the Scottish index of Multiple Deprivation, or similar measurement in rural areas, or areas with significant potential for growth.

Although we are supportive of the structured approach presented in the guidance, without additional support to local planning authorities and communities in the preparation of their LDPs and LPPs, the successful implementation of this guidance could be severely hampered. Given this, RTPI Scotland reiterates calls on Scottish Government, as made to the previous draft NPF4, for a comprehensive resource and skills strategy to be published as part of the Delivery Programme of NPF4.

 

Question 5: Does Part 3 of the guidance clearly communicate the importance of both qualitative and quantitative data in establishing a baseline for a place?

 

Very Useful

Digital

The collection, storage and ongoing maintenance of both quantitative and qualitative data are crucial to the development and policy planning processes and implementation of the local living and 20-minute neighbourhood principles set out in this guidance document. In particular, LDP evidence gathering and reporting processes provide a clear opportunity to support the formation of policy which can facilitate the delivery of local living.

RTPI Scotland’s Policy Briefing Paper on implementing 20-minute neighbourhoods[14] recognises the important role of the Scottish Government’s Digital Planning Strategy and transformation programme to unlocking the value of planning data, delivering an end-to-end digital planning service experience, creating the conditions for digital to flourish, using digital tools to drive collaboration and engagement, and embedding a culture of digital innovation that can drive forward the delivery of local living and 20-minute neighbourhood principles.

 

The Place Principle

RTPI Scotland is pleased that the Place Principle features in this guidance as a driving force for the delivery of 20-minute neighbourhoods; together with existing tools such as the Place Standard and Place Based Framework for collecting the qualitative data necessary to capture the lived experiences and community expectations of a place. This reflects the Scottish Government’s consistent approach to delivering place-based outcomes, which the Institute fully support. The Place Principle supports collaborative place-based action and the Place Standard is a commonly-used tool to help people think about the quality of their place and where action might be required.

However, to ensure the ongoing effectiveness of the Place Principle, the data gathering process needs to include relevant, transparent and robust indicators for public authorities to monitor and report on how they have embedded the Principle in their approaches and decision-making, including any reasoning.  It is imperative that the Place Principle is operationalised and an effective monitoring process established to ensure that it can effectively influence policy, practice, investment and (ultimately) the delivery of local living and 20-minute neighbourhoods on the ground.

 

Density

We note the guidance recognises that travel times, distances and expectations will vary depending on the density of the area in question. As previously mentioned, RTPI Scotland believes that a stronger policy line in terms of density will be necessary to add more weight in the planning balance to the consideration of compact settlement form as opposed to existing local impact or landscape impact, particularly in existing settlements and urban areas. Policy support needs to be continued for intensification of settlements especially through promotion of use of brownfield land. Other policy measures such as reduction in minimum parking standards will enhance opportunities to achieve gentle density and better quality placemaking. We believe there is opportunity within this guidance to recognise the importance of density in achieving local living and 20-minute neighbourhoods, but only if an assessment of density is included at the data gathering stage of the process.

 

Demographic Characteristics

We also note that the section on quantitative data gathering focuses almost entirely on the physical characteristics of place. Whilst we agree that understanding the physical characteristics of a place (such as what services, facilities and amenities are present) is important, RTPI Scotland considers that it is equally important to understand the demographic characteristics of a place in terms of who is living, working and spending their leisure time in these places. This is important to understand who will benefit from the implementation of this guidance, which is vital if 20-minute neighbourhoods are to successfully tackle spatial inequalities. Although the guidance does state that comparisons can be made with other datasets (including the Scottish Index of Multiple Deprivation and the Census), there needs to be greater recognition of the importance of understanding the demographic (as well as the physical) place characteristics to ensure the implementation of local living and 20-minute neighbourhood principles tackles spatial inequalities and caters to the diverse needs of Scotland’s places and people. Understanding the demographic characteristics of a place can also assist in ensuring that efforts are made to engage with all members of the community through the qualitative data collation exercise and include more targeted approaches to engage with individuals who may not otherwise actively engage.

 

Engagement

RTPI Scotland supports the review of previous engagement exercises as a valuable starting point for qualitative information. Depending on when these previous engagement exercises were undertaken, this review process could give an indication of communities’ changing attitudes over time, recurring themes of importance to communities, as well as avoidance of consultation fatigue by ensuring that any additional engagement exercises employed are not unnecessarily repetitive. Also, when compared with demographic data, it may be possible to ascertain if any individuals have been inadequately represented in the past to warrant the adoption of a more targeted engagement approach.

 

Question 6: How helpful is the ‘collaborate, plan, design’ section of Part 3 in supporting collaborative practices?

 

Very Helpful

RTPI Scotland supports the emphasis on collaborative working through the Place Principle, community engagement, flexibility, adaptability, and public service reform outlined in this section of the guidance. The delivery of local living and 20-minute neighbourhoods requires collaboration between a variety of stakeholders and actors, including local authorities, communities, transport providers and planners, health and education providers, local businesses, developers, built environment professionals, and other organisations and industry experts. It is important to ensure when delivering the objectives of local living, that a coordinated approach is taken within and between these different groups and organisations from the outset to ensure a holistic and inclusive approach to the delivery of local living principles from the data gathering stage through to the implementation and ongoing review stages of the process.

The successful delivery of local living and 20-minute neighbourhood principles can only be achieved through the effective cross-sectoral implementation of the Place Principle. This will, in turn, require the introduction of formal processes to operationalise and monitor its work so that it positively influences policy, practice and investment on the ground and to ensure the necessary alignment with the local living and 20-minute neighbourhood principles set out in this guidance is achieved. Only through effective reporting and monitoring of the Place Principle will it be possible to understand if, where, and how the Principle has been applied and, we would argue, is essential if the Place Principle is to effectively drive forwards the delivery of local living and 20-minute neighbourhoods, as is asserted to in this guidance.

We are pleased to see recognition in this section of the importance of local level leadership in the delivery of local living and 20-minute neighbourhoods. Since the onset of the Planning (Scotland) Bill, RTPI Scotland have been strong advocates for the introduction of statutory Chief Planning Officers (‘CPO’). We welcomed the provision of this new local authority position in the Act, and we consider that this role is vital to bring about the type of collaborative and holistic oversight to the delivery of local living and 20-minute neighbourhoods that is needed if this guidance is to be implemented successfully across Scotland.

RTPI Scotland believes that a key part of the CPO role will be as a local place champion, to ensure that planning is at the forefront of local authority planning and investment plans, positioning planning as an enabler and influencer on the corporate priorities of place making, economic development and infrastructure delivery. These are all critical components of local living and 20-minute neighbourhoods. CPOs will help ensure that local authorities take planning, place, and local living objectives into account when making strategic decisions about investment, asset management, resources and integrated service delivery, in alignment with the Place Principle. We eagerly anticipate the publication of the Chief Planning Officer Guidance. The CPO guidance should cement within it the CPO’s position of leadership in delivering local living and 20-minute neighbourhoods, and this leadership role of the CPO should be supported and strengthened in this local living guidance.

 

Question 7: How helpful is the ‘implement and review’ section of Part 3 in assisting the delivery of collaborative approaches to support local living?

 

Somewhat Helpful

RTPI Scotland is pleased to see the alignment of the local living commitment across a number of cross government policies, strategies and investments referenced in this guidance document. We are also pleased to see the adoption of a collective approach to delivering local living and 20-minute neighbourhoods, and the importance of cross-sectoral and -organisational knowledge, skills, collaboration and support reflected in the guidance (i.e. understanding that local authorities do not, cannot and should not shoulder the entirety of responsibility).

The structured approach to local living and 20-minute neighbourhoods relies heavily on the adoption of new style LDPs and LPPs. The guidance document specifically states that “planning authorities are ideally placed to gather the quantitative and qualitative data that is essential to plan and deliver local living as part of the Evidence Report stage of LDP preparation. LDP policies, proposals and allocations, informed by the principles of good place making, can help to focus investment in buildings and places that deliver sustainable and healthy communities”. RTPI Scotland agrees with the critical role of LDPs in delivering local living and 20-minute neighbourhoods. However, we are also acutely aware that for many local authorities, new style LDPs prepared in accordance with this guidance, are several years away from adoption. Consequently, local authorities will, in the interim, be required to make decisions on planning applications based on the list of considerations set out in Policy 15 of NPF4 (which now forms part of the statutory development plan). This guidance document acknowledges that the relevance and assessment against Policy 15 “will vary between applications and contexts” and that LDPs will provide “a further steer on expectations for applications”. While local authorities are awaiting this “further steer”, more clarity should be provided to local authorities on how their DM officers should apply these guidelines when assessing planning applications.

The successful delivery of local living and 20-minute neighbourhoods is not something that will be completed in the short or medium term. It is a long-term and ongoing process that will require continuous review and monitoring to ensure that the steps taken towards achieving the local living objectives of NPF4 are durable and can stand the test of time in terms of serving the needs of Scotland’s diverse communities now and into the future. RTPI Scotland believes, therefore, that the review and monitoring stage is essential to the successful implementation of local living and 20-minute neighbourhoods, in line with the Place Principle. However, the review and monitoring process has been allocated only a single paragraph in this section of the guidance document. The approach taken to monitoring and measuring planning performance is a key barrier to the implementation of the Place Principle and, consequently, to the delivery of local living and 20-minute neighbourhoods. RTPI Scotland has, for several years, advocated for the recasting of planning performance measurements to be more focussed on outcomes. To do this, we need to measure the outcomes of planning beyond simple metrics like speed of processing applications and number of housing units delivered. Rather, we need to assess planning in terms of placemaking aspirations and social, economic, and environmental value, to track and improve the impact of planning. This involves shifting measurement beyond narrow development outputs to consideration of wider place outcomes and impacts. The way in which local authorities currently measure their planning performance does not take account of many of these wider place outcomes and more needs to be done to link planning to these wider place-making objectives – particularly the local living and 20-minute neighbourhood objectives of NPF4.

RTPI commissioned research on Measuring Planning Outcomes[15] considers how local authorities can better measure the outcomes of planning. The research led to the development of a toolkit to be used by local authorities to improve their outcome measurement in planning departments. The benefits of the toolkit and the ‘results’ arising from its use include:

• Tracking performance/progress over time.
• Integration across policy sectors and themes.
• Understanding what has worked, what has not worked and identifying possible causes and what needs improving or abandoned in the future.
• Informing Development Management and decision-making
• Raising aspiration towards delivering better planning outcomes against strategies/plans/policy goals.
• Visibility/transparency of outcomes and impacts at local levels.
• Aggregation and benchmarking of performance at regional and national scales.
• Raising shared factual/scientific awareness between different parties and stakeholders.
• Educational dimension in terms of knowledge transfer, skills and awareness/use of data.

This toolkit has been piloted in Scotland. The pilots have provided a range of lessons for the future implementation of the toolkit and it illustrates how the toolkit should be used to feedback into policy and plan-making processes by introducing new targets, identifying where additional indicators and data are needed, or where actions are required around policy implementation. This approach to measuring planning performance would greatly enhance the ‘implement and review’ stage of delivering local living and 20-minute neighbourhoods in line with this guidance document.

 

Question 8: Looking at Part 4 of the draft guidance: do the case studies provide a useful and appropriate range of examples of good practice?

 

Yes

We are pleased to see a good range of examples of good practice in this section of the guidance document, spanning across Scotland’s rural and urban areas. We are also pleased to see the Place Standard feature in these case studies as an important engagement and delivery tool, together with other tools used by local authorities (including GIS mapping).

We note, however, that the case studies presented in this section are light on detail regarding how review and monitoring have been/are proposed to be undertaken to ensure the long-term durability of the projects. As mentioned in our response to Question 7 above, effective ongoing review and monitoring is essential to the successful implementation of local living and 20-minute neighbourhoods, in line with the Place Principle. We understand that these case studies are still in their early stages and may not yet have reached the stage of undertaking a detailed review and monitoring process. To ensure this guidance remains up to date and relevant into the future, we recommend it also be subject to a review and monitoring process to ensure its long-term effectiveness. This review process should include a review of the case studies contained in this section of the guidance, to provide an update on their progress and to provide further information about the review and monitoring processes adopted for each case study, and their success.

We also note that the East Ayrshire Case Study includes a paragraph on the lessons learned from the process. This is very useful in providing a level of critical assessment and knowledge sharing that provides valuable insight into the potential pitfalls (as well as the successes) of local living implementation. We believe all case studies in this section of the guidance would benefit from a ‘lessons learned’ component.

We would also like to flag that many of the diagrams featured in the case study section of the guidance are at a low resolution making them illegible. It would be beneficial if these diagrams could be included in the guidance at a higher resolution so they can be read clearly.

 

Question 9: Looking at the impact assessment update report: do you have any views about the initial conclusions of the impact assessment update report that accompany and inform this guidance?

 

Yes

We note that this impact assessment is an update report of the assessment originally carried out for NPF4. Consequently, this update report largely concludes that the guidance will have no impact given that it places no additional requirements on planning authorities. This conclusion is also taken with respect to the update to the Business and Regulatory Impact Assessment (BRIA).

RTPI Scotland would like to take this opportunity to highlight our disagreement with the conclusions of the final NPF4 BRIA regarding resourcing impact on planning authorities. The conclusion of the BRIA mainly drew on focus to potential savings for planning authorities in the LDP preparation with the adoption of National Planning Policies. It stated that where additional policy requirements are more significant, additional guidance and skills development will be undertaken, but made no mention of the necessary provision of additional resource.

RTPI Scotland does not consider that the NPF4 BRIA took full consideration of the real-world costs of the revised NPF4 on planning authorities. Planning authorities will be affected by almost every policy change of NPF4. However, a full evaluation of the potential costing for them has not been consistently undertaken. This can be seen, for example, in policies where additional resource burdens on planning authorities to consider new evidence or assessments has been highlighted (e.g. Policy 30), whilst remaining silent on other new or expanded policies (e.g. Policy 23). Notwithstanding this, the BRIA has identified 14 policy areas that may have a resourcing and skills impact on planning authorities, a number which we believe to be an underestimate.

In relation to the implementation of the local living and 20-minute neighbourhood guidance, although we acknowledge that this guidance does not create additional policy requirements or duties on local authorities, there is an expectation that the successful implementation of this guidance will rely on its integration into LDP and LPP processes. RTPI Scotland have long-held the view that the ability of local authority planners to deliver on the new format LDPs and to support communities in preparing LPPs will be hindered by their limited resources and budgets, which have decreased in real terms by 42% since 2009[16]. Given this, RTPI Scotland reiterates calls on Scottish Government, as made to the previous draft NPF4, for a comprehensive resource and skills strategy to be published as part of the Delivery Programme of NPF4.

 

Question 10: Please provide any further comments on the draft guidance document in the box below

 

RTPI Scotland is pleased to see publication of this draft guidance for implementing local living and 20-minute neighbourhoods. RTPI Scotland strongly supported the integration of local living into the policy framework of NPF4 and recognise it as a key opportunity to embed place-based plan- and decision-making practices centrally within Scotland’s planning system. Local living and the 20-minute neighbourhood are concepts of urban development that have ascended rapidly in the minds of policymakers, politicians and the general public across the world. It is a model of urban development that creates neighbourhoods where daily services can be accessed within a reasonable walk, wheel, or cycle. If delivered effectively, such neighbourhoods can help to regenerate urban centres, enhance social cohesion, improve health outcomes, and support the move towards carbon net-zero targets through the reduction of unsustainable travel. The latter aim is achieved principally by expanding communities’ travel options and enhancing freedom of choice beyond that of the private motor vehicle. This relies not only on the existence and accessibility of a variety of travel infrastructure, but also on community access to a variety of other services and facilities (including housing, retail, employment, education, health care, communications infrastructure etc.). Consequently, this freedom of choice will rely heavily on the successful implementation of the Infrastructure First Policy (Policy 18) of NPF4 to ensure that the necessary infrastructure requirements to support local living are identified, integrated into the LDP, and are able to be delivered on the ground. Although this guidance does refer to the importance of infrastructure, there are only two specific references to the infrastructure first approach (within the Stewarton, East Ayrshire Case Study in Part 4). We believe this guidance should highlight the importance of the infrastructure first policy in delivering 20-minute neighbourhoods from the outset and throughout the document, to reinforce the links between these two NPF4 policies.

In addition, if local living and 20-minute neighbourhoods are to be delivered successfully, it will be important for an effective ongoing review and monitoring process to be adopted in the long-term. RTPI Scotland believes that adopting an approach akin to the toolkit set out in the RTPI’s Measuring Planning Outcomes research, would greatly enhance the ‘implement and review’ stage of delivering local living and 20-minute neighbourhoods in line with this guidance document. This would be further supported through the operationalisation of the Place Principle, the effective application of which is vital to achieving the cross-sectoral collaboration that is critical to the successful delivery of the local living and infrastructure first policies of NPF4.

 

[1] RTPI | Implementing 20 Minute Neighbourhoods in Planning Policy and Practice

[2] wip-ii-final.pdf (rtpi.org.uk)

[3] children-and-town-planning-july-2021.pdf (rtpi.org.uk)

[4] dementiatownplanningpracticeadvice2020.pdf (rtpi.org.uk)

[5] rural-planning-and-npf4-final.pdf (rtpi.org.uk)

[6] Plan The World We Need (rtpi.org.uk)

[7] 20MNs_highlands_islands_2022.pdf (nickwrightplanning.co.uk)

[8] For example: Queering Public Space - Arup

[9] https://www.rtpi.org.uk/media/8111/20-minute-neighbourhood-briefing-report-final.pdf

[10] https://www.rtpi.org.uk/research/2022/december/resourcing-the-planning-service-key-trends-and-findings-2022/

[11] https://www.rtpi.org.uk/research/2022/december/resourcing-the-planning-service-key-trends-and-findings-2022/

[12] https://www.rtpi.org.uk/consultations-rtpi/2022/march/rtpi-scotlands-response-to-draft-local-development-plan-regulations/

[13] https://www.rtpi.org.uk/consultations-rtpi/2021/june/rtpi-scotlands-response-to-local-place-plan-consultation/

[14] https://www.rtpi.org.uk/media/8111/20-minute-neighbourhood-briefing-report-final.pdf

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

[16] https://www.rtpi.org.uk/research/2022/december/resourcing-the-planning-service-key-trends-and-findings-2022/