Scottish Parliamentary Committee publishes report on draft NPF4

Following public consultation on Scotland’s draft National Planning Framework 4 (NPF4) the Scottish Parliament Local Government, Housing and Planning Committee has published its report.

… greater clarity on priorities is required if the ambitions of NPF4 are to be delivered…

The Committee writes:

  1. The Committee welcomes NPF4 and its ambition for Scotland. To best deliver on these ambitions the Committee wishes to highlight a number of key areas to the Scottish Government. An overarching issue, however, is the capacity of the current planning system to deliver on the aims of NPF4.
  2. Firstly, while recognising that it is for decision makers to make an informed judgement on a case by case basis, the Committee believes that greater clarity on priorities is required if the ambitions of NPF4 are to be delivered in a coherent and consistent way. What the Committee heard from stakeholders is that they do not feel they have sufficient clarity on what they should be prioritising in making decisions. The Committee urges the Scottish Government to consider again whether more could be done to provide decision makers with the clarity and certainty they are seeking.
  3. The Committee also considers that more clarity and certainty is needed in the choice of language in some cases to support the delivery of the ambitions of NPF4. The Committee notes the explanations provided by the Scottish Government for its choice of language. NPF4 should be an accessible and usable document and it is of concern to the Committee that there is such uncertainty about the meaning of terms and words. These concerns are being highlighted to the Committee by people very familiar with the planning system. If these people are struggling to understand its meaning and intentions then it brings into question the extent to which people without that understanding and familiarity will be able to use it. The Committee would ask the Scottish Government to reflect on the comments made to this committee about the language used in NPF4 and consider how to create greater clarity and certainty.
  4. The Committee wholeheartedly supports the prominence given to the climate emergency in NPF4. It is essential though that this prominence is reflected in planning decisions. This will require a significant change in approach for the planning system and we would welcome further reflection from the Scottish Government on how that change will be driven and how it will be balanced against competing priorities. The Committee would also welcome the Scottish Government’s reflections on the concerns expressed by the Climate Change Committee and in particular, how it believes NPF4 will match ambition with action.
  5. The Committee invites the Scottish Government to consider what more can be done to ensure that communities are supported to engage in shaping the places in which they live, particularly communities from more disadvantaged areas. The Committee would also ask the Scottish Government to consider what more can be done to alleviate consultation fatigue including ensuring that consultation is undertaken timeously and communities are involved in a collaborative rather consultative manner.
  6. The Committee welcomes 20 minute neighbourhoods and notes that stakeholders recognise this as a good planning concept. There are undoubtedly, however, very significant challenges associated with delivering on 20 minute neighbourhoods. Whether it’s a new development, an existing urban setting or rural or island context careful consideration will need to be given to how it can be applied in each context. Communities will need to be involved in shaping the places in which they are to live and amongst other things, there will need to be a focus on infrastructure and sustainable transport to deliver on these ambitions. The Committee welcomes the Minister’s recognition of the importance of STPR2 in delivering on 20 minute neighbourhoods, but would welcome further information from the Scottish Government on how it intends to deliver on 20 minute neighbourhoods across Scotland and in particular in rural and island areas where the challenges of creating 20 minute neighbourhoods would appear to be most pronounced.
  7. The Committee hopes that NPF4 can make clearer what is expected of local authorities when considering applications for renewables, so that ambitions for renewables can be delivered across Scotland in an equitable and timeous manner. At the same time the Committee notes the reservations of Scottish renewables sector and asks the Scottish Government to reflect on them. The Committee also emphasises that any application must be considered carefully and a balance must be struck between our renewable energy ambitions and their impact on biodiversity.
  8. The Committee welcomes the Minister’s commitment to affecting an improvement in our town centres through NPF4 and other initiatives and will be paying close attention to how these progress. The Committee is keen to see how NPF4 and any other powers available can be deployed effectively in order to improve our town centres. The Committee explored the use of amenity notices in connection with this and considered whether they were an effective tool in delivering change, but no conclusion was reached on this.
  9. The Committee would welcome the Scottish Government’s view on how the issue of resourcing planning departments is addressed. The Committee welcomes the Minister’s commitment to exploring how full cost recovery can be delivered. Having properly resourced planning departments will be essential to the success of NPF4. Given the current state of local authority planning departments it is debateable whether even with full cost recovery within the development management function they will have the resources to move toward the kind public led planning necessary to realise the ambitions of NPF4. In any event, it is key that any funding coming to local authorities from full cost recovery is retained by planning departments. It is also key that not only is there a very significant increase in the number of local authority planners but both current and new planners must be given the training and skills to work in this new environment.
  10. We need to properly monitor and evaluate the effectiveness of NPF4 and how it is being delivered by local authorities. To that end, the Committee would welcome a commitment from the Scottish Government to producing an annual evaluation of NPF4 against the outcomes set out in Town and Country Planning (Scotland) Act 1997. The Committee would also welcome consideration of how benchmarking in local government could be used to ensure that the ambitions of NPF4 can be delivered.
  11. The Committee highlights the concerns expressed to it about the lack of ambition inherent in MATLHR. While the Committee notes that these are merely minimums and not a cap it is concerned that having minimum targets may limit ambition at a time when we need to be ambitious to meet Scotland’s housing needs. The Committee asks the Scottish Government to review HNDA at the earliest opportunity to develop a tool that is up to date and fit for all areas of Scotland, so that more appropriate projections can be made for local authority areas. The Committee would also welcome further information on how that review will be conducted. The Committee also asks the Scottish Government to explain how it intends to ensure that MATHLR, Housing to 2040 and HNDA are better aligned to deliver on the ambitions for housing in Scotland.
  12. Finally, given these issues, the Committee is concerned that it will not have sufficient opportunity to consider the final version of NPF4. It is conceivable that a final version will be materially different from the draft version. The Committee welcomes the Minister’s commitment to appear before it on the final version of NPF4. At the same time, the Committee would welcome an assurance from the Scottish Government that sufficient time will be allowed for the Committee to undertake thorough scrutiny of the final NPF4 before Parliament is invited to approve it.

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