National Planning Framework 4 - draft: consultation analysis

Part 1 – A National Spatial Strategy for Scotland

Sustainable places

Our future net zero, nature-positive places will be more resilient to the impacts of climate change and support the recovery and restoration of our natural environment.

Question 1 – 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?

Around 430 respondents made a comment at Question 1.

Some comments were extensive, addressing issues considered in more detail at subsequent questions on national planning policies. The analysis presented below focuses on the more frequently-raised themes that address the commentary on Sustainable places set out in the draft NPF4.

Many of those commenting supported the prominent role given to sustainable places and the vision of net zero, nature-positive places. This included particular support for the commitment to deliver positive biodiversity impacts, encouraging low and zero carbon design, retrofit and energy efficiency, and reducing unsustainable travel. Comments also included support for what was seen as a clear change in tone from previous NPFs, with a stronger focus on climate change and nature recovery. Respondents agreed that these must be central principles for the planning system.

However, it was also suggested that the commitment to sustainable places should be strengthened, reflecting a view that the national policies set out in the draft NPF do not reflect the urgency required to achieve net zero targets. These respondents suggested a much more ambitious approach to the delivery of the priorities set out under Sustainable places. In addition to calls for stronger use of language across the national policies, some wished to see a statutory requirement for planning decisions to favour net zero and nature recovery objectives, for example over economic growth. There were also calls for NPF4 to specify long-term and interim targets, detail the investment required to achieve these, and set out an effective delivery mechanism, including robust monitoring. Some suggested that, in the absence of these elements, NPF4 does not represent a genuine commitment to deliver the transformative change referenced.

Respondents also suggested that a more coordinated approach to delivery of sustainable places is required. There were calls for better integration of the Sustainable places ambitions with other strategic priorities set out at Part 1 of the draft NPF4, and with the national policies (at Part 3) which are expected to deliver these ambitions. It was also noted that several relevant plans and policies are yet to be finalised, such as the consultation on Environmental Principles, the revised National Marine Plan, the Vision for Aquaculture, and the new Biodiversity Strategy. Some suggested that these must be in place before the NPF4 approach to delivering sustainable places is finalised. Some also felt that the draft NPF is too focused on the delivery of future sustainable places, and called for a more balanced approach that also prioritises making existing places sustainable.

There was also some concerns that the introduction to the Sustainable places section presents a limited definition of sustainable development. In particular, there were calls for it to better reflect the social and economic aspects of sustainable development, alongside the environmental ones. This included reference to broader definitions set out in existing SPP and reflected in NPF4 national policies such as Policy 6 (Design, quality and place). Some suggested that, in contrast to environmental sustainability, the draft NPF4 takes a more passive approach to the social and economic elements of sustainable places. However, comments also highlighted the need to address the potential for conflict between the economic aspects of sustainability, and the focus on climate change and nature recovery.

Delivery of sustainable places

Most of the comments at Question 1 addressed the deliverability of sustainable places as set out in the draft NPF. This included observations that the policies set out in Part 3 lack the detail required to support the ambition of the introduction to the Sustainable places section. Specific concerns raised included that:

• The absence of a Delivery Programme makes it difficult to understand how the ambitions set out will be delivered.
• NPF4 should recognise that the delivery of sustainable places must respond to differences in community needs and infrastructure requirements across urban and rural areas. This reflected a view that the draft is overly focused on planning and development in urban areas.
• Planning authorities will require additional resourcing to deliver the necessary assessment and enforcement functions, and a deeper pool of technical knowledge, including through a role for external expertise.
• There is a need to define key concepts for Sustainable places, such as 'nature positive', 'nature-based solutions' and 'positive effects for biodiversity' – the latter including some preference for the term 'biodiversity net gain'. There were also calls for these definitions to be supported by practical examples of how concepts are expected to be reflected in local decision-making.
• Detail on the potential scale of investment required to deliver NPF4 policies would be helpful, including concerns around the investment required to deliver necessary infrastructure improvements, for example to support active travel and decarbonised energy supply. This reflected a view that the delivery of sustainable places is likely to incur a higher cost than unsustainable alternatives.
• There were calls for NPF4 to reflect the presumption in favour of sustainable development as set out in SPP. The removal of this presumption was described by some as a retrograde step.

Several respondents expressed a view that a successful and sustainable property development industry has a key role to play in the delivery of sustainable places, and meeting climate change and emissions reduction targets. These respondents highlighted the role of the industry in working with authorities to plan for sustainable places, including more sustainable transport modes, decarbonised energy and heat and integrated blue green infrastructure.

Some felt that the delivery of sustainable places and climate targets will require a shift in attitudes and design approaches across the development industry and other sectors. It was suggested that the draft NPF4 could be more forceful in its language use to encourage this.

The circular economy was seen by some as critical in the delivery of sustainable places. In addition to a perceived need for a more prominent role for the circular economy in national policies, it was also suggested that this should be an overarching theme.

The climate emergency, biodiversity and nature recovery

Many of those commenting welcomed recognition of the significance of the climate emergency for planning, including reference to the risk to ecosystems and the biodiversity crisis. There was also support for reference to the need for a rebalancing of the planning system to set climate change and nature recovery as the primary guiding principles.

However, some wished to see a stronger position taken on the climate emergency. This reflected a view that there is a significant possibility that net zero emissions targets for 2030 and 2045 will not be achieved in the context of the draft NPF4. There were calls for a stronger focus on emissions reduction, suggesting that the draft does not currently deliver the required rebalancing of planning considerations to achieve net zero targets. Respondents also wished to see reference to the reuse and retrofitting of existing buildings to support the delivery of carbon reduction targets.

Some saw a need for clearer links between nature restoration and climate resilience. This reflected support for the identification of climate change and nature recovery as key guiding principles, and it was suggested that these principles must have primacy over other NPF4 policies. There were also calls for further detail on what constitutes 'nature-based solutions' to support nature recovery. Comments also identified the potential for conflict between climate and nature recovery objectives, for example where development or mitigation measures required for carbon reduction, may have unavoidable adverse impacts on biodiversity. Respondents sought further clarity on how these 'trade-offs' should be determined.

It was suggested that reference should be made to how the planning response to the climate emergency and nature recovery relates to other policy, including the Land Use Strategy.

Reducing unsustainable travel

The reference to reducing unsustainable travel was welcomed, reflecting a view that reducing transport emissions will be a key element in delivery of net zero targets. This included calls to support the integration of transport planning and development planning to ensure a cohesive approach.

Some felt that the language used at this section could be improved, for example suggesting a more positive focus on increasing use of sustainable travel, rather than reducing use of unsustainable modes of travel. It was also suggested that NPF4 should make reference to the need to reduce travel as a whole (including reference to the role of 20-minute neighbourhoods), in addition to ensuring that all travel is sustainable.

Respondents highlighted a range of considerations relating to transport sustainability which they wished to see reflected. These included the role of active travel in reducing transport emissions, ensuring that the location and design of new development supports sustainable travel, and the need for built spaces that are accessible and equitable for everyone.

Renewable energy generation

There was support for the reference to renewable energy under Sustainable places, with respondents suggesting that the planning system has a key role to play in ensuring the expansion of renewable energy generation.

However, some wished to see a stronger focus on the role of renewable energy production, including on transmission and distribution infrastructure. It was suggested that NPF4 policies must recognise that a rebalancing of planning considerations is required to achieve the necessary increase in renewable energy generation. Respondents also saw a need for greater clarity on the weight to be attributed to climate change, nature recovery and energy. This included calls for a spatial framework for the delivery of onshore wind infrastructure, while ensuring that biodiversity is protected and enhanced.

Other themes to be referenced

Respondents also highlighted a range of other themes they wanted to see referenced in relation to sustainable places. These included:

• The role of the historic environment in creating sustainable places.
• How Scotland's housing crisis can be addressed alongside net zero targets and nature recovery, including calls for reference to Housing to 2040 and A Scotland for the Future.
• The role of adaptation for flood risk in building climate resilience.

Liveable places

Our future places, homes and neighbourhoods will be better, healthier and more vibrant places to live.

Question 2 – 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?

Around 400 respondents made a comment at Question 2.

Some of these comments were extensive, and addressed issues covered in greater detail at subsequent questions. The focus of the analysis here is on more frequently raised themes, and in particular those which address the commentary on Liveable places.

Many of those commenting welcomed the focus of the Liveable places section, with some suggesting that the overall approach appears to cover most of the important aspects of delivering homes and neighbourhoods which are better, healthier and more vibrant places to live.

However, it was also suggested that this section could be better articulated, or that it needs to be reinforced and strengthened into something that resembles an approach to development that can be delivered by the planning system. An associated comment was that this section of the spatial strategy has the weakest links with Part 3 (National Planning Policy Handbook).

With reference to some of the language used, it was suggested that there is a lack of clarity, and that some of the terms used are ambiguous. Examples given included what 'better' places means in practice, and how 'high quality' and 'great places' can be defined.

Other general concerns included that the approach appears geared towards urban living, and that many of the aims will be less achievable in more rural and dispersed areas. It was suggested that a one-size-fits-all approach does not take into account differing needs, and geographical and climate challenges.

It was noted that communities have adapted over time to work with their environments, but that this spatial principle seems to suggest that all communities need to change the way they live in the future. It was reported that in some areas, many communities do not require transformative social and economic change of the kind described.

Other general comments included that:

• The Place and Wellbeing outcomes identified by the Improvement Service (as set out in their 'Integrating land use planning and public health in Scotland') should be referenced.
• Net zero is not mentioned anywhere within this section and liveable places by their very nature should be shaped by net zero.
• The opportunity NPF4 offers to address longstanding inequality and eliminate discrimination is welcome, although there is little mention throughout the document of specific attention to women, those with disabilities or people from ethnic minorities, for example.
• NPF4 should consider the needs of wheelchair users throughout.

Delivery of liveable places

• A number of the comments addressed the deliverability of liveable places, with observations including that there is very little detail on how transformative social and economic change is going to be delivered. It was suggested that:
• Planning will not achieve this on its own and a multi-agency, public/private approach will be needed. Delivery and implementation of this approach will require a radical rethink as to how we plan places, and the approach from key agencies, the private sector and the development industry.
• A deep understanding of local context is required, so NPF4 should be more explicit in stating that LDPs will be key to delivery, and what policies mean in different authorities.
• Stronger policy wording is required throughout to assist with decision-making on planning proposals. The transformative change advocated will be difficult to achieve without empowering local planning authorities to implement planned improvements.
• Practical detail would be helpful, including in relation to how the necessary investment will be found. There was also a suggestion that delivering the intended approach is likely to be more expensive than current approaches.

Healthy and active communities

It was noted that encouraging healthier lifestyles and more physical activity can improve the quality of life and mental wellbeing of society, and there was support for it being seen as a priority.

Explicitly recognising planning's role in supporting better health and wellbeing actions was seen as encouraging, and it was suggested that planning policy is pivotal in creating healthier communities. Taking a public health approach to planning was described as central to efforts to tackle health inequalities, and it was suggested that the Liveable places principles, along with Policy 14 (Health and wellbeing) could be strengthened. However, it was also suggested that addressing the significant health inequalities that our communities experience will take generations and, in some instances, a major societal shift that is outwith the remit of planning.

There was a call for more clarity and direction around how NPF4 will achieve or influence these real-life issues. There was also a suggestion that the population groups most affected need to be identified, and that there needs to be recognition of the many factors that may impact on whether someone views their community as being inclusive, empowering, resilient and safe. There was also a call for NPF4 to recognise the barriers that different people may experience, and the need to ensure that these are addressed in order to achieve the vision of creating better, healthier and more vibrant places.

Impact of COVID-19

The recognition of the impact of the pandemic on changing views of place was generally welcomed, although it was suggested that it could be expanded upon to set out how this will impact on the liveability of spaces, and what changes will be needed in the future to create resilience and capacity.

Further comments included that this is a key time to enact positive change, building on lessons learned throughout the pandemic, and that this also creates an opportunity to address the deep-rooted inequalities in our communities, some of which have been exacerbated by the pandemic. It was noted, however, that as a nation we also have wider, more long-standing health issues that need to be addressed.

Empowering communities

A number of respondents commented on the importance of communities being empowered, including that in order to make our future places better, healthier and more vibrant, communities need to be empowered to be the key drivers of this change. However, there was a concern that referring to 'hoping' to empower more people to shape their places seems to suggest that the knowledge, resources or ambition to do so is lacking.

There was a call for a clear commitment to community empowerment, with planning taking a proactive approach to enabling communities to shape, and benefit from, the development of their places. Further comments included that communities need:

• A level playing field, where they are recognised as key stakeholders and given the same rights as developers, including a right to appeal planning decisions.
• To be given the resources and active support to develop community-led Local Place Plans. It was suggested that the sharing of experience, skills and resources is required and that some communities are likely to required significant assistance.

There was a concern, however, about the lack of reference to additional resources being required. It was reported that many community groups lack basic building blocks, including funding, skills, a good quality meeting place, and an inclusive structure, all of which are required to effectively represent a community and meaningfully influence local regeneration on the community's behalf.

In relation to different members of the community, it was noted that input from children and families will be key to making places, homes and neighbourhoods better places for them to live. It was also suggested that ensuring that women are involved in consultation and planning will have a beneficial impact.

Good quality homes

The reference to good quality homes was also welcomed, although it was noted that there is no reference to the Government's first long-term national housing strategy, Housing to 2040. As with other policy themes, there was a call for further detail on how more affordable homes can be delivered.

It was seen as critical that the policy background within NPF4 translates into a supportive planning environment that delivers the mixed tenure homes needed. A specific suggestion was that housing delivery should be identified as a national development.

In terms of particular housing needs, the lack of reference to older people's housing was considered disappointing. It was seen as vital that housing for older people is central to the Scottish Government's plans to ensure we are building for the future, but there was a view that at the moment NPF4 falls well short, including around joining up housing and social care.

It was also noted that for people with terminal illnesses, creating communities which are inclusive, empowered, resilient and safe must also include homes which are accessible and adaptable.

20-minute neighbourhoods

The inclusion of 20-minute neighbourhoods was also welcomed, although it was suggested that despite being frequently referenced, there is a lack of information about how the approach can be delivered in practice, particularly in rural areas. It was suggested that the concept has strong urban connotations, and could actually lead to the displacement of smaller, more fragile communities towards bigger population hubs. It was thought that this does not fit with NPF4 objectives around population and sustaining rural communities.

There were also questions about how the approach can work in existing communities, including the retrofitting of existing areas lacking in facilities and linkages, and how these can be made viable. It was also suggested that there should be focus on communities themselves defining what their neighbourhoods look like, rather than having a centrally-imposed expectation that they should fit the 20-minute model.

Other comments addressed the travel and other infrastructure required to deliver 20-minute neighbourhoods, but also liveable places more broadly. Given the importance of sustainable transport and connectivity, it was suggested that these themes should be referenced along with housing, services, open space and culture. More generally, it was suggested that transport considerations need to be properly built into the planning system if Scotland is to reach its net zero target by 2045 as planned.

Other themes to be referenced

Respondents also highlighted a range of other themes they wanted to see referenced in relation to Liveable places. These included:

• The Place Principle and place-based approaches. Also, local design initiatives and the role they can play.
• The demographic structure of Scotland, and the nature of the need and demand that will flow from it. Also, increasing the population of rural areas.
• Changing work patterns following the pandemic, and the need to accommodate increased working from home.
• Green spaces and community food growing.
• The food environment and the important role of planning in this regard.
• The ambitions of the National Culture Strategy and the role of local creative activity.
• Recognition that the historic environment plays an important part in the wellbeing agenda.
• The Gaelic language and culture, and its connection to health and wellbeing.

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.

Question 3 – 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?

Around 385 respondents made a comment at Question 3.

There was support for the focus on the just transition to net zero and a nature-positive economy. It was noted that the move to a greener economy could provide opportunities for business development, job creation and investment in communities, through community wealth building.

Other respondents welcomed the approach but commented that the policy lacks detail. It was felt that this could make it more difficult to enforce and deliver, as there is no delivery strategy or no timescales have been set out

Some respondents commented that the ambition of the Productive places section is too narrow and similar to what is currently in place. Others were concerned that the idea of a 'wellbeing economy' is relatively new to land use planning. It was suggested that without training, planners may find it challenging to interpret approaches such as 'community wealth building' and other concepts when considering development proposals or LDPs.

There were also concerns about the dichotomy between economic growth and zero carbon and green recovery objectives. There was a view that the latter objectives cannot avoid being compromised to achieve business and economic growth. It was suggested that guidance and best practice advice are needed to help planning authorities accomplish the balance of delivering investment, sustaining existing businesses, and building a wellbeing economy. It was noted that this tension is also apparent in the NSET. Other respondents observed that there should be alignment between NPF4 and the NSET.

Other general comments included:

• There is an alignment between a community wealth building approach to local economic development and 20-minute neighbourhoods, which is not reflected in Productive places.
• There is reference to using places to stimulate entrepreneurship. However, there is a lack of reference to direct interventions that will deliver the level of stimulus needed to boost Scotland's entrepreneurial base.
• Land ownership inequality undermines productive places. The planning system can play a role in addressing unequal land ownership and use by supporting community wealth building.
• To avoid misinterpretation, definitions should be provided for a number of terms used including 'community wealth', 'fair work', 'good green jobs', 'green investment', 'wellbeing economy', 'nature-positive economy', and 'just transition'.

Rural, highlands and islands

Some respondents made specific comments on applying the policy to rural, highland and islands settings. It was observed that the distinctive socio-economic contexts and particular market characteristics of these areas include increased social enterprise, under-employment, and a plurality of employment that requires a flexible, responsive approach to development, taking account of local context and need.

Comments relating to these issues included:

• Remoteness from economic and population centres results in relatively expensive transport, and associated challenges for developing businesses. Investment is needed to unlock the economic potential of island communities, depending on the needs and characteristics of the area.
• Businesses in rural locations that significantly increase car journeys should not be supported unless there is a locational requirement or adequate sustainable travel provisions.
• Housing is essential as the population increases (especially in rural areas) as it can bolster local economies.
• Some planning authorities have resisted the pressure for developments in smaller towns, rural areas and areas around large cities. Embracing localism, and a more sustainable future where people travel less, may require a rethink.

It was also observed that digital connectivity should be addressed more fully as it will contribute to increasing the attractiveness of productive places, particularly those in more rural locations. It was acknowledged that digital infrastructure and planning policy is set out in Policy 23 (Digital infrastructure), but it was suggested that it should also be referenced under Productive places as it is critical to the economy and wellbeing of remote, rural and island places. The connection was made to combatting the ongoing depopulation of Scotland's rural communities and making these areas more attractive to working-age people.

Net zero

There were a number of comments on the role of net zero and renewables.

Some respondents observed that it would be helpful to set out a specific ambition to support a circular economy that could use Scotland's low-carbon energy system to manufacture goods with lower carbon footprints. It was noted that this could also provide local employment through increased opportunities to repair, reuse, refurbish and refill.

It was suggested that distribution networks need support to become more sustainable and that reaching a net zero, nature-positive economy requires rethinking centralisation and economies of scale. It was reported that this can be applied to transporting both raw materials and finished products and that modern technology can facilitate processes locally that were formerly only available at scale.

Other comments included:

• NSET identifies support for the transformational economic potential of Scotland's offshore wind sector. The Productive places section should position Scotland's planning system as an enabler of growth in the offshore wind and low carbon infrastructure sectors.
• Care needs to be taken that the requirement to stimulate investment and business does not work against the achievement of the over-arching requirements to restore ecological function and biodiversity, and address climate change mitigation.

Omissions

Several respondents highlighted areas that they felt were omitted from the policy.

There were concerns that issues of poverty and inequality are not highlighted prominently enough, particularly as many deprived places will not become productive places without long-term regeneration and support. A related observation was that community planning legislation needs to be focused on the economic, social and environmental wellbeing of local people rather than being driven by market forces and big business.

Some respondents noted the contribution that housing could make, with further comments including:

• The delivery of good quality social housing in deprived places, where high housing need is often evident, can act as a balance to market pressures.
• Prioritising the refurbishment of vacant buildings could reduce the high carbon cost of new housing developments.
• House building provides homes and economic benefits, including job creation, supply chain support, and improvements to existing local infrastructure.

Other suggested omissions included:

• The policy should support ambitions around health and wellbeing.
• There is little or no mention of the importance of community business and social enterprise.
• There is no reference to the production of food, through crofting and agriculture, or otherwise.
• Reference should be made to the contribution that culture and heritage can play in improving economic, social, and environmental wellbeing. Cultural and heritage assets can be an anchor for the regeneration of places, helping to build a sustainable local economy.
• This section of NPF4 could reflect that land is not a commodity, but should be viewed in terms of the social and environmental benefits it provides to all.

Distinctive places

Our future places will be distinctive, safe and pleasant, easy to move around, welcoming, nature-positive and resource efficient. This will ensure that people value, enjoy, protect and enhance their environment.

Question 4 – 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?

Around 360 respondents made a comment at Question 4.

Many respondents expressed support, or support in principle, for the focus of Distinctive places. Others noted that they supported the aims or aspirations set out, or highlighted particular elements with which they agreed. It was observed that the concept of distinctive places is already well embedded in the planning system and that Scotland already has many distinctive places which should be celebrated. Providing further detail on measuring the distinctiveness of a place was suggested.

There was also a view that the policies grouped in this section lack coherence, with a specific suggestion that 'safe and pleasant, easy to move around' would sit better under Liveable places, allowing Distinctive places to focus on the importance of protecting and enhancing the built and natural environment. There was also a perceived emphasis on managing new development, with a lack of consideration for the protection or improvement of existing places, and the opportunities they present.

Concerns were raised about how high level strategy can translate into the individual policies required for delivery, or that the delivery mechanisms are unclear. It was also noted that delivery will depend on factors beyond the planning system's influence and will require a multi-agency, multi-sector approach. The importance of resources, including for planning departments, and of investment (particularly in relation to the remediation of vacant and derelict land), were also highlighted.

It was also suggested that more robust language, and greater consistency of wording and terminology, is needed along with more detail, more explanation and more guidance. Specifically it was suggested planners will require guidance with respect to the relative weighting of the various objectives.

Safe and pleasant, easy to move around and resource efficient

Comments on the phrase 'safe and pleasant' included that there should be greater ambition to create 'inspiring' places rather than just 'pleasant' ones. In relation to safety it was suggested that:

• Ensuring women feel safe in public spaces is very important.
• Development must not be supported in areas where it poses a risk to community safety.
• Existing businesses and operators should be protected if development encroachment occurs close to a hazard site.

While the need for ease of movement was supported, it was suggested this will be challenging and will require substantial investment. There were calls for:

• Prioritisation of active travel.
• Investment in cycling infrastructure.
• Improved public transport provision and better rural public transport in particular.

Consideration of the needs of people with mobility difficulties was also highlighted as important, with a requirement for inclusive design that relies on close engagement with access panels and other organisations representing people with disabilities.

It was suggested that there needs to be greater clarity on what is meant by 'resource efficient', and also that creating resource efficient places will require the use of circular economy principles.

Addressing past decline and inequalities

Interventions to address past decline and inequalities were welcomed, and it was observed that, at present, many multiply deprived places are not safe, pleasant or welcoming. However, it was also suggested that the draft NPF4 offers no targeted, specific interventions for places such as coalfield communities, which have experienced some of the greatest economic and environmental decline, compounded by the pandemic.

Natural environment, biodiversity and blue and green infrastructure

Respondents often supported the statement that nature recovery and connected blue and green infrastructure must be at the heart of future places. It was also argued that this infrastructure should not just be connected, but strategically planned from a local to national level across catchments. Reference to other benefits of blue and green infrastructure, beyond biodiversity value, was suggested.

It was argued that the reference to Scotland having a rich and high-quality natural environment is at odds with the later commitment to 'restore the richness of Scotland's natural environment' and that NPF4 should recognise that Scotland is a nature-depleted country. While the commitment to restore the natural environment was welcomed, it was also argued there should be greater protection in the first instance. Some respondents made the case for a National Nature Network as a means of improving biodiversity, or argued that NPF4 should reference a new National Park.

In terms of assessing biodiversity, the need for a clearer metric on how to measure net gain was highlighted.

Placemaking, a design-led approach and a focus on quality

There was support for a stronger commitment to placemaking, although it was also argued that, at present, the design-led approach and quality outcomes identified do not feed through into policy. There was also a request to clarify the definition of 'quality' – whether quality of build, quality with respect to the volume of natural assets, or in relation to community expectations.

However, it was also suggested that a design-led approach does not necessarily equate to better places and that linking placemaking and design-led approaches focused on quality is too subjective. Instead of focusing on quality as a primary outcome, it was thought preferable to have outcomes of creating places for people and a green infrastructure first approach.

Other comments on placemaking included both that the role beauty plays in people's experience and enjoyment of place should be recognised, and that landscapes must be a key consideration of placemaking.

It was also suggested that the need for new design and architecture to contribute to distinctive places could be addressed and that developers should be encouraged to focus on creating high-quality distinctive spaces rather than meeting minimum standards. There was a call for support for local authorities to refuse applications that fall short and to insist on high quality proposals. It was reported that decisions to refuse applications due to sub-standard design are often overturned at appeal.

Reshaping town centres

It was argued that part of what makes town centres distinctive is a mix of small and independent businesses, and that the improvement of local high streets requires a presumption against out-of-town development. Another perspective was that the current 'town centre first' approach should be retained to allow for local assessment of any proposed development.

An opportunity for NPF4 to ensure that public health priorities are considered in plans for town centres was also highlighted.

Reusing vacant and derelict land and buildings

Although the principle of reusing vacant and derelict land and buildings was supported, it was suggested that, since content elsewhere in NPF4 identifies other functions for vacant and derelict land (for example in greening urban areas, or in providing nature-based solutions), support for reuse should be caveated with 'where appropriate'. It was also argued that sustainable design and sustainable use of resources must be prioritised, as referred to under Sustainable places.

Some respondents noted that the reuse of vacant and derelict land should not always be seen as a priority and it was argued that building on vacant and derelict land is not inherently 'greener'.

Creating rural opportunities

There was a view that some policies in NPF4 feel urban-centric, and that this may affect the creation of new rural opportunities. There were calls for:

• Recognition that rural areas require a more flexible and specific approach to planning policy.
• A clear approach to defining and capturing rurality in Scotland and a clearer vision for rural communities.

Our best places

There was support for the commitment to value, enhance, conserve and celebrate our best places, which was said to align with the national strategy for the historic environment 'Our Place in Time'. However, it was also suggested that there is not enough emphasis on creating 'the best places of tomorrow' and that an intention to conserve our best places might be seen as implying that other places are not worth conserving.

Concern was expressed that an emphasis will be placed on conserving places when sensitive, locally agreed and locally beneficial development could be advantageous to communities without being environmentally damaging.

Other themes

Respondents also highlighted a range of other issues they would like to see considered in relation to distinctive places. These included:

• Responding to climate change, achieving net zero and the changes this will bring.
• The importance of landscape.
• Community input to decision-making, community-led approaches, and a focus on Local Place Plans and community empowerment.
• Natural and historical heritage as a means of increasing a sense of place and belonging.
• Resilience of coastal assets.
• Heritage assets and the importance of adaptation and mitigation in relation to enhancing, valuing and conserving the historic environment.
• Consideration of Natural Capital.
• The role of culture and creativity in sustaining successful communities and places.

Question 5 – Do you agree that the spatial strategy will deliver future places that overall are sustainable, liveable, productive and distinctive?

Around 325 respondents made a comment at Question 5.

This included some extensive comments which addressed issues considered in more detail at Questions 1 to 4, or at subsequent questions on national planning policies. For example, many expressed a view that the spatial strategy will not deliver sustainable, liveable, productive and distinctive places without the planning system responding with robust policy and decision-making. The analysis presented below is focused on the most frequently-raised points relating to the relationship between the four spatial strategy themes, and the identification of any additional themes for inclusion in NPF4.

Most of those commenting expressed support for the spatial strategy, especially the focus on climate change and nature recovery. These respondents identified NPF4 as a key opportunity for the planning system to contribute to the change required to deliver against net zero targets, and expressed a view that the four themes around which the spatial strategy is structured provide a sound basis for doing so.

However, some suggested that the way in which the spatial strategy is communicated could be improved. This was primarily related to a perceived need for clear definitions of key concepts, including what these should mean for development planning and planning decisions. Respondents also highlighted the importance of the spatial strategy being phrased strongly enough to ensure buy-in from developers and other stakeholders.

While some supported the focus on climate change and nature recovery, others felt that the spatial strategy should go further to ensure that all development is guided by the delivery of net zero targets. Some respondents wished to see a commitment to sustainable economic growth.

There were calls for greater clarity on the connection between the four spatial strategy themes. This reflected a view that the draft NPF4 does not recognise inherent tensions between specific aspirations, for example between economic growth and net zero and nature recovery. Respondents suggested that more was needed to integrate the spatial strategy with national planning policy and other components such as the six spatial principles, the action area priorities, and the proposed national developments. It was suggested that a detailed map of the relationships between all parts of NPF4 should be provided. Some also wished to see the National Spatial Strategy map (at page 5) include further detail on the change which the strategy is seeking to achieve.

Respondents also saw a need for further detail on the prioritisation of aspects of the spatial strategy, including how these components should be balanced in planning decisions. It was suggested that this could be addressed by the addition of an overarching guiding principle that sets out how delivery of places that are sustainable, liveable, productive and distinctive will make Scotland a net zero nation. This reflected concern that the spatial strategy lacks a single vision comparable to that included in NPF3. There was also a perceived need to ensure that interpretation of the spatial strategy does not treat the four themes separately, resulting in plans and proposals focusing only on individual aspects of place.

Concern was also expressed that the spatial strategy does not make specific reference to net zero targets. It was suggested that NPF4 would benefit from a clear roadmap to 2045, including anticipated milestones, resourcing considerations and outcomes. This was seen by some as essential in giving stakeholders confidence that the strategy will be implemented.

Some respondents expressed a view that the national spatial strategy does not do enough to respond to the variation in characteristics and needs across Scotland's regions. This included calls for the spatial strategy to differentiate between urban and rural areas, and between cities and towns. Respondents noted that this requires planning authorities to be permitted sufficient flexibility to ensure LDPs are tailored to local needs and circumstances, and to changing circumstances over the plan period.

Respondents highlighted the role of other frameworks and strategies in supporting the spatial strategy. There was thought to be a need for NPF4 to provide a clear account of the external strategies and plans which are expected to have a role to play in delivery of the national spatial strategy. In this context, respondents made specific reference to SPP, the National Marine Plan, the National Biodiversity Strategy, the Scottish Climate Change Adaptation Programme, NSET, Housing to 2040, and the Heat in Buildings Strategy. There were also calls for the spatial strategy to provide more detail on how it will guide preparation of other plans and strategies, such as Regional Spatial Strategies, LDPs and Local Place Plans.

Respondents highlighted several principles that they saw as underpinning the spatial strategy, and approaches that they wished to see better reflected. These included:

• Use of a collaborative design approach to drive improvements in the quality of development design, including user-led approaches to ensure that the delivery of the spatial strategy reflects what communities want and need. This included calls for the spatial strategy to provide clarity on the role of communities in delivery of NPF4.
• More weight being given to the adaptation of existing places, land and buildings, in line with the recommendations of the Climate Change Committee and supporting the focus on conserving and recycling assets.
• Recognising the link between climate change, health and inequality across the spatial strategy.
• Emphasising the importance of 20-minute neighbourhoods.
• Ensuring the spatial strategy is supported by a robust evidence base to guide delivery.

Some respondents also identified policy areas or themes which they wished to be given greater prominence by the spatial strategy. Specific suggestions included:

• Greater emphasis on the importance of strategic and local transport connections across the spatial strategy, recognising the requirements of a decarbonised transport sector.
• A stronger focus on the role of renewable energy as part of a just transition away from fossil fuels, and consideration of how this will be balanced with other spatial policy priorities. This included calls for the spatial strategy to specifically address the need to direct renewable energy development in a way that does not undermine nature recovery.
• A stronger focus on the importance of housing for Scotland's communities, recognising the need for sustained action in response to the current housing crisis, and including housing for older people.
• Greater emphasis on the need to protect and enhance Scotland's landscape and historic environment, including the role of landscape designations.
• Calls for a greater focus on the circular economy and embodied carbon.