RTPI Scotland's Response to the 'Review of National Outcomes: Call for Evidence'

Question 1: Are there any changes to the current set of 11 National Outcomes that you would propose? If so, in summary, what would these be?

The current set of national outcomes cover a broad range of ambitions spanning across the social, economic, environmental and cultural spectrums. The planning system has the potential to contribute towards each of the current National Outcomes both directly and indirectly as a result of its role in shaping places. This has been firmly established in the Planning (Scotland) Act 2019, the National Planning Framework 4 (NPF4) and the recently published Local Development Planning (LDP) guidance. The RTPI has around 2,100 members in Scotland and a worldwide membership of over 27,000. RTPI Scotland’s members represent both the public, private and third sector interests and are extensively involved in all areas of planning matters across Scotland and represent a key means by which the current National Outcomes are achieved.

Whilst we consider the current national outcomes to be highly relevant to planning and to the important work our members undertake daily, it is imperative that they also embed Scotland’s bold ambitions to address the climate and nature emergencies and to deliver the country’s net zero targets. NPF4 places the global climate and nature crises at its core, recognising the critical role of planning in making decisions about development that will impact future generations. Although there are indicators within the NPF which are highly relevant to tackling the climate and nature emergencies (including “carbon footprint”, “biodiversity” etc.), currently our ambitions to tackle these crises are poorly reflected in the National Outcomes, only weakly touched upon through references to sustainability, ecological accountability, and “preserving planetary resources for future generations”. This gap in the National Outcomes could be addressed by either reframing the current National Outcomes to embed Scotland’s commitments to tackling the climate and nature emergencies, or by developing a new overarching National Outcome which captures this commitment.

Question 2: Are there new National Outcomes that should be included in the National Performance Framework. If so, why should they be included?

Refer response to question 1 above.

Question 3: Are there any changes you would propose to the wider National Performance Framework on set of National Indicators?

RTPI research on Measuring Planning Outcomes[1] found that sitting above its basic regulation of land use, planning has a higher order role to create attractive, well designed, sustainable places which will improve the quality of life of the people who live, work, learn and spend leisure time in them.

Given the above, the planning system is clearly supportive of the NPF’s collective purpose and has a critical role to play in contributing to the National Outcomes and Indicators. However, for the planning system to meaningfully contribute to the National Indicators, greater attention needs to be placed on place-based collaboration through the Place Principle.

The Place Principle is an overarching concept which is clearly aligned with the National Outcomes. However, if the Place Principle is to be effective there is a need to ‘give it teeth’ and operationalise and monitor its work so it influences policy, practice and investment on the ground. There is opportunity to do this by embedding the Place Principle into the National Outcomes and Indicators through this review process. In particular, the “Communities” National Outcome is centred around the ‘quality and character of the places we live and the people we live among’, including access to affordable homes, green space, nature, sustainable transport, leisure activities etc. The Place Principle clearly has a central role to play in achieving the ‘friendly, vibrant and cohesive communities’ envisioned in the “Communities” National Outcome. However, reference to the Place Principle is noticeably absent from this Outcome, resulting in an unacceptable policy disparity at the national level. To give the Place Principle the necessary weight required to facilitate its enactment on the ground, it is essential that it be embedded into the vision and indicators associated with the "Communities” National Outcome. To further support this, RTPI Scotland also considers it vital that there be a duty on statutory bodies to report on their implementation of the Place Principle, including the actions they have undertaken and the monitoring of their success (or otherwise). Such a duty would be a significant step towards a transparent process for understanding if, where, and how the Place Principle has been applied and, we would argue, is essential if the Place Principle is to have the kind of meaningful and positive impact on Scotland’s places, people and communities that the Scottish Government and COSLA envisaged when this Principle was first adopted.

Question 4: What impact does the current National outcomes have on your work?

The RTPI is the champion of planning and the planning profession. Our mission is to advance the science and art of town planning, working for the long-term common good and well-being of current and future generations. We campaign to promote healthy, socially inclusive, economically and environmentally sustainable places in accordance with a number of the National Outcomes. The planning system has the potential to contribute towards each of the National Outcomes both directly and indirectly as a result of its role in shaping places. This has been firmly established in the Planning (Scotland) Act 2019, the NPF4 and the recently published LDP guidance. We have around 2,100 members in Scotland and a worldwide membership of over 27,000. RTPI Scotland’s members represent both the public, private and third sector interests and are extensively involved in all areas of planning matters across Scotland and represent a key means by which the National Outcomes can be achieved.

To help support the planning system in achieving the National Outcomes, RTPI Scotland has for a number of years been advocating for the recasting of planning performance measurements to be more focussed on outcomes. To do so we need to measure the outcomes of planning beyond simple metrics like speed of processing applications and number of housing units delivered and rather to assess planning in terms of placemaking aspirations and social, economic and environmental value, in order 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 national outcomes. The RTPI has commissioned research on the matter, which considers how local authorities can better measure the outcomes of planning and specific reference was made to the National Outcomes established by the Scottish Government[2]. 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 ‘result`s’ arising from its use include:

• Tracking performance/progress over time.
• Integration across policy sectors and themes.
• Understanding what has worked, what has not worked; identifying possible causes and what needs improving or abandoned in 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.

The toolkit has been piloted in Scotland which provided a range of lessons for its future implementation and 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.

Question 5: What are the main obstacles and barriers in the further implementation of the National Outcomes?

Fundamentally, to ensure the planning system can deliver on a number of the National Outcomes it needs to be resourced effectively. To understand resourcing needs of the planning system we need to take cognisance of the context of diminishing resources and increased workloads in planning authorities with recent research from RTPI Scotland 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 we welcome the increases to planning fees that took place last year, as set out in recently published research[3] RTPI Scotland does not believe this will bring in the appropriate amount of resource necessary for the planning system to undertake its statutory duties and deliver the National Outcomes. The need to resource the planning system effectively has been recognised by a wide range of stakeholders, as reflected in the Local Government, Housing and Planning Committees final report as a part of their scrutiny of the NPF4[4].

A further barrier to implementation of the National Outcomes is the current approach that is taken to measuring planning performance – principally based on process delivery (i.e. the number of consents granted and units delivered) rather than place quality outcomes. As set out in our response to question 4 above, RTPI Scotland advocates for the recasting of these planning performance measurements to be more focused on outcomes, utilising the toolkit developed as part of RTPI research into Measuring Planning Outcomes, which was supported by the Scottish Government. This shift of approach beyond narrow development outcomes towards wider place-based outcomes and impacts, would greatly enhance the planning system’s accountability to the National Outcomes of the NPF, particularly if the Place Principle is also embedded into the NPF (as set out in our response to question 3 above).

Question 6: How do you enable coherence and coordination between your organisation and the aims of the NPF and the National Outcomes?

Planners reflect the National Outcomes daily through the development management process, which can influence design to support the vision and objectives for place and restrict development which does not comply with national or local planning policy. The planning system also performs an important role through managing unauthorised development through planning enforcement.

As previously stated, greater coherence and coordination could be achieved between the planning system and the National Outcomes by embedding the Place Principle within the NPF and by shifting the focus of measuring planning performance towards wider place outcomes and impacts (enhancing planning’s ability to deliver on the National Outcomes).

Question 7: How could accountability be improved for delivering the National Outcomes?

Our research on Measuring Planning Outcomes found that there is significant variation in both the in-house performance management standards of different planning authorities and the reporting requirements of different jurisdictions. It is therefore important that local authorities are held to account and given the relevant guidance to effectively monitor their planning performance and outcomes. There needs to be more consistency across the board if we are to make progress towards the National Outcomes. The toolkit developed as part of this research sets out the key levels in the evolution of an outcomes/impact monitoring framework for planning:

• The first level (Level 1) calls for the monitoring of planning activities, including plan-making, and the immediate, short-term outputs of those activities – for example, planning permissions granted.
• The second level (Level 2) focuses on monitoring medium term planning outputs and development outcomes, notably the conversion of planning consents into development started and completed: at this point we can monitor progress towards the targets set out in development plans.
• The third level (Level 3) takes us into the wider policy domain by focusing on the evaluation of place value and impacts resulting from the operation of the planning system: have new developments conformed to best practice in architecture and urban design, and what inferences can we draw in terms of their contribution to policy goals.

The research found that Level 2 might be considered to be the minimum requirement for effective performance management and democratic accountability. However, there must be an effort made to ensure that local planning authorities advance to Level 3. If an effective monitoring and evaluation programme were to be implemented as part of the NPF4, this would go some way towards holding local authorities to account.

RTPI Scotland also wish to highlight the opportunity to improve how we measure and monitor outcomes delivered through the planning system via the new National Planning Improvement Champion role, set out in the Planning (Scotland) Act 2019. We are aware that an appointment has been made, and the role is due to commence in September 2023. RTPI Scotland previously set out our thinking on how this role can provide a powerful new resource for all users of Scotland’s planning system[5]. In particular, we believe this role should focus on an outcomes and impacts based approach, which measures the quality of outputs and outcomes rather than focusing (as has been the case in the past) on output quantity (for example, through the number of processed applications).

[1] RTPI | Measuring What Matters: Planning Outcomes Research

[2] RTPI | Measuring What Matters: Planning Outcomes Research

[3] RTPI | Resourcing the Planning Service: Key Trends and Findings 2022

[4] Report on the Revised Draft National Planning Framework 4 | Scottish Parliament

[5] RTPI | The Office of the National Planning Improvement Coordinator