Introduction
This briefing is for the debate of the Revised Draft National Planning Framework 4 (NPF4) which will take place in the Scottish Parliament on the 11th January. The Royal Town Planning Institute (RTPI) is the champion of planning and the planning profession. We work to promote the art and science of planning for the public benefit. We have around 2100 members in Scotland and a worldwide membership of over 25,000. RTPI Scotland’s members will in large part be responsible for the successful implementation of the NPF4 if it is approved by parliament.
RTPI Scotland sees the upcoming parliamentary debate as an important opportunity for MSPs to reflect on the fundamental role of the planning system in tackling the key societal issues of our time including, the twin biodiversity and climate crisis, the need to reduce health inequalities and delivering the new green economy.
RTPI Scotland welcomes the progress made in the preparation of the NPF4, with more clarity and consistency alongside the continued emphasis given to the twin climate change and biodiversity crises. Given this, we support its approval in Parliament. However, in taking forward the NPF4’s implementation and delivery three key considerations will be around how to resource the new system, how to ensure the production of a revised Delivery Programme which is fit-for-purpose and how to monitor progress and impact of NPF4.
Resourcing
In order to achieve the laudable aspirations of the revised draft NPF4 we need to ensure that the planning system is effectively resourced to do so. As set out in the concluding remarks Local Government, Housing and Planning Committee’s (LGPHC) report on the revised draft NPF4:
“Of greatest concern to the Committee is that the ambitions of NPF4 will simply not be met due to a lack of planners and more specifically a lack of planners with the skills to meet the challenges of NPF4. This must be addressed with some urgency.”
The revised draft NPF4 will create additional work for all ready over-stretched planning authorities. It also demands a significant upskilling of the planning workforce to manage new and expanded policy areas. To address this, we call for the inclusion of a comprehensive skills and resource strategy in an updated Delivery Programme. Such examples can be seen in other sectors, for example, the recently published national health and social care workforce strategy[1].
The additional potential workloads deriving from the revised draft NPF4 need to be contextualised in years of disinvestment in our planning services. Recently published research by RTPI Scotland[2] has revealed the stark resourcing issues facing planning authorities with:
- The planning service is the one of the most severely affected of all local government services in terms of budgets with a reduction of 38% since 2010;
- A quarter of planning department staff have been cut since 2009;
- Planning application fees do not cover the costs of processing planning applications;
- The new Planning Act has introduced 49 unfunded duties to local authorities which could cost between £12.1m and £59.1m over 10 years to implement
- It is estimated that over the next 10 to 15 years the planning sector will have demand for an additional 680 - 730 entrants into the sector; and
- The planning workforce has both demographic and succession challenges in the short, medium and long term.
Given this, if we want to ensure that the planning system meets its fullest potential to and effectively manage the transition to the new national policy framework there is a need to:
- provide additional resource and enhanced support from Scottish Government to planning authorities through the transition period
- ensure planning fees are ringfenced used to support planning purposes
- provide the resources to undertake the new duties from the Planning (Scotland) Act 2019
- increase planning fees to ensure they meet their costs, or introduce a subsidy for planning authorities to overcome this shortfall
- invest in initiatives such as planning apprenticeships to improve the supply of planners in the face of increased demand for their services
Delivery Programme Review
RTPI Scotland wishes to highlight the important opportunity for MSPs to reflect beyond the policy content of the revised draft NPF4 and towards its implementation. Of particular note, it’s Delivery Programme requires appropriate scrutiny alongside collaborative support towards the development of its next iteration, with a review process programmed for 6 months’ time.
We are disappointed that no capital investment programme has been published alongside the Framework and would like to see this included as part of future iterations of the Delivery Programme. RTPI Scotland wish to see more consideration in the Delivery Programme of how we can achieve corporate buy-in to the Framework across government and key stakeholders. We welcome the point made in the Local Government, Housing and Planning Committee’s report
“as the Committee monitors NPF4 and its delivery we will be paying close regard to whether the absence of a specific capital investment programme has in any way undermined the delivery of NPF4.”
NPF4 is to be aligned other national plans, programmes and strategies - particularly the Infrastructure Investment Plan (IIP), the Strategic Transport Projects Review 2 (STPR2) and the National Strategy for Economic Transformation (NSET). We understand the intention is to position the proposed Planning, Infrastructure and Place Advisory Group as central to the production of the next IIP and we welcome this. However we would wish to see thinking on how this will work in practice further developed. We note the intentions are to agree and factor in funding requirements derived from the NPF4 into the Capital Spending Review and through the annual Budget process, but would wish to see how key stakeholders can be included in this process.
Monitoring
We believe that the future monitoring of NPF4 needs to check that its policies are effective and useable; that there is buy-in across government to the framework’s ambitions; and that planners are equipped to support its delivery.
As set out in the LGHPC report:
“It is not satisfactory to simply assume that planning policy is now set for ten years and can be left as it is […] it is critical that NPF4 and the planning authorities who are there to deliver it are subject to effective monitoring to ensure that the ambitions of NPF4 are actually delivered.”
We need to fully consider now how to effectively monitor whether the policies are working as intended, ensuring they are practicable through implementation and provide the appropriate clarity for decision makers.
Beyond this we must ensure that the Framework plays an important role in governance and serves as the core of future policy development in Scotland. To do so it is crucial that monitoring arrangements take consideration of broader governmental activity in this process, to ensure new and existing funding streams and strategies are making a strong and clear connection to the NPF4 and vice versa. This is highlighted by the LGHPC report:
“There must also be clear cross-Government commitment to NPF4, ideally adopting a similar approach to the one taken in Ireland.”
Given the importance of ensuring enough planners with the right skills are able to implement the Framework close monitoring of skill development needs and resourcing should be a key pillar of any monitoring arrangements going forward. This is pointed out in the LGHPC report where it says
“The Committee has set out in this report a number of issues it will pay close regard to as it monitors the effectiveness of NPF4, perhaps most notably the capacity and skills within planning authorities to deliver on the ambitions of NPF4.”
Contact
We would be happy to discuss these points with you. Please contact Robbie Calvert, Policy Practice & Research Officer on 07971 651480 if you would like to do this.
[1] https://www.gov.scot/publications/national-workforce-strategy-health-social-care/pages/8/
[2] https://www.rtpi.org.uk/research/2022/december/resourcing-the-planning-service-key-trends-and-findings-2022/
