National Planning Framework 4 - draft: consultation analysis

Spatial principles for Scotland 2045

The draft NPF4 notes that we will need to make the right choices about where development should be located but that no single policy or development on its own will deliver sustainable, liveable, productive and distinctive places. It sets out that, in order to build a climate-conscious and nature-positive future, our strategy and the policies that support its delivery are based on six overarching principles.

Question 6 – Do you agree that these spatial principles will enable the right choices to be made about where development should be located?

Around 380 respondents made a comment at Question 6.

Although views were mixed, more respondents agreed that the spatial principles will enable the right choices to be made about where development should be located than disagreed. It was suggested that the spatial principles seem to encapsulate what NPF4 is seeking to deliver, including by recognising that a 'one-size-fits-all' approach would not be appropriate.

However, there was also a view that, as currently formulated, the spatial principles might not enable the right choices to be made. Related concerns included that the principles lack clarity and definition. There was also a concern that it is not clear how this section is intended to be used by stakeholders of the planning system, what weight these principles will have, or how the spatial principles should or would inform consistent decision-making? Associated themes were that:

• It will be essential that the principles are translated into robust policy. There need to be specific objectives and targets and NPF4 should state what should be prioritised.
• Successful delivery of the principles can only happen if there is sufficient detail and clarity in the rest of NPF4 to inform and guide planners, developers and the wider public. It is not clear how the spatial principles will be used in decision-making, especially since they are not referred to in other sections of the draft NPF. There should be better links between the spatial principles and the Universal Policies set out in Part 3.
• Parts of this section could read as an effort to influence regional planning but there is lack of clarity on how this is to be delivered. More clarity and information on investment and delivery vehicles is necessary.

Other suggestions related to a wider reframing of this section of the draft NPF and/or the spatial principles themselves. Comments included that:

• There should be a general revision to make the principles less urban-centric and more appropriate to the needs of rural Scotland.
• The approach should be place-based, with rural, island, urban, and peri-urban principles.

In terms of how this section of NPF4 could be improved, suggestions were that it should:

• Make explicit reference to the aim to make tackling climate change a 'primary guiding principles for all our plans and decisions'. It should also include some read across to the four Place themes (at Questions 1-4).
• Set out wider linkages. There could be reference to other national strategies and legislation that underpin and reinforce the principles. It was also noted that the spatial principles should contribute to other policy programmes, for example to Scotland's NSET.
• Provide guidance on how the principles will be used in the planning application decision-making process.
• Reference the Place Principle as a means of delivery of the spatial principles.
• Use precise language and include further detail or expanded definitions.

a) Compact growth

Compact growth was the spatial principle that most divided opinion.

On the one hand, some respondents supported the approach set out, including by suggesting that it will be key to sustainable development. Other reasons given for supporting compact growth included that maximising the use of existing infrastructure and buildings will offer benefits to the existing community. It was noted that this type of approach can be particularly important for some groups, such as for older people.

Some of those who were generally supportive of the approach set out noted certain issues they felt needed to be taken into account, including that the planning system will require greater powers to ensure that such an ambition can be delivered. Other comments or suggestions were that:

• Consideration should be given to the impact of land use restrictions on land values. If the direction of travel is to limit urban expansion through land use planning, it will be important to ensure that the resultant increase in land values associated with residential planning permission is democratised and perverse incentives in terms of what is built are avoided.
• The value that people place on space, including outdoor space, has been highlighted by the pandemic. Flatted living suits a sector of society, but is not a universal answer for all.
• Compact growth should not be at the expense of local greenspace for food growing and recreation.
• The significant increased space needed for energy networks within and nearby settlements will need to be recognised.

Other respondents, including a number of 'Development, Property or Land Management Company or Representative Body' respondents, raised fundamental concerns about this principle. They centred around a view that it is not always appropriate to allocate vacant and derelict land, and in particular derelict land to be used for housing, rather than greenfield land. This was connected to the suggestion that the delivery of all-tenure housing to meet future needs across Scotland will be reliant on an appropriate blend of brownfield, vacant and derelict and greenfield land coming forward through LDPs.

Other comments related to the focus on brownfield, vacant and derelict land included that:

• While vacant and derelict land sites do contribute to the delivery of new homes, there are also examples of where use for housing simply may not be appropriate. This includes because of contamination, lack of access, remoteness or where the economic hurdles cannot be met.
• Limiting development to brownfield or vacant and derelict land sites is at odds with c) Balanced development and the intention to give people a choice about where they live, learn and work.
• Brownfield sites can be socially and environmentally important spaces and it may be inappropriate to develop biodiverse sites.

In relation to the general principle of focusing on compact growth, it was suggested that a blanket objective to increase density may be inappropriate and in some locations may be detrimental to effective placemaking and to new development achieving cohesion with the existing settlement pattern.

There was also a concern that increasing settlement density could have the unintended consequence of concentrating growth and development in existing urban places and will not support repopulation efforts in rural areas. It was also noted that compact growth is not so easy to manage in island settlements, where the development pattern is heavily influenced by land tenure, including crofting.

b) Local living

A number of the comments made about this spatial principle expressed support for the general principle, including in relation to 20-minute neighbourhoods, but noted that the 20-minute neighbourhood approach is not without its challenges.

These issues are covered in further detail at Question 29, but in summary points included that there is a need for information on how 20-minute neighbourhoods can be applied in practice, especially in rural areas. There was also a question about how the approach is expected to work in areas with established patterns of development that is supported by current and previous policy, and driven by market forces that are outwith the control of the land use planning system. It was suggested that the 20-minute neighbourhood principle needs to be considered alongside economic, social and environmental considerations.

Other comments focused on whether the 20-minute-neighbourhood concept is appropriate to rural areas, with points made including that in rural areas services are often more than a 20-minute journey away, with active or public transport travel options limited or unsuitable. There was a concern that the 20-minute neighbourhood terminology is potentially misleading in a rural context and may raise unrealistic community expectations about access to services.

In relation to other aspects of this principle, comments included that it should not be assumed that the decentralisation of energy networks will be easily delivered, and that land use planning alone will not deliver the shift to sustainable transport. There was a call for a national focus and funding to develop active travel infrastructure.

Finally, there was support for the inclusion of local circular economies as a feature of this principle, although it was noted that they are not referenced under Policy 7 (Local living). This issue is covered further at Question 29.

c) Balanced developments

A number of the comments about this spatial principle were focused on how it relates to other parts of the draft NPF, or to other planning policy. On this latter point, it was suggested that the current SPP of 'right development in the right place', should be carried through into NPF4, giving it formal status. A connected view was that it should act as a standalone principle within NPF4. Other suggestions for additional principles are set out below.

In terms of the draft NPF as it stands, it was suggested that there are a number of policies which will work against the objective of achieving balanced development, particularly in respect to the suggestion that people will have more choice over where they can live. There was specific reference to Policy 29 (Urban edges) and to the identification of Minimum All-Tenure Housing Land Requirements (MATHLR) at Annex B.

Other comments focused on the principle's reference to creating opportunities for communities in areas of decline and managing development more sustainably in areas of high demand. On the latter issue, there was a query as to how this will be achieved. In relation to creating opportunities for communities in areas of decline, views included that:

• The action areas set out do not support transformational change, particularly in coalfield communities.
• NPF4 should also cover the need to prevent negative economic impacts from loss of industry.
• There should be recognition of the impact that second homes and short-term holiday lets can have on communities, while also recognising that these can bring economic benefits in some instances.

Other comments included that:

• Balanced development in rural areas must be supported by investment in public transport. It was also suggested that equality in digital connectivity is crucial for transforming rural and island areas and promoting balanced growth.
• The aim of balanced development is to provide more choice for people about where they live, but the draft NPF fails to ensure that older people will have this opportunity.

d) Conserving and recycling assets

Most of those who commented were supportive of conversing and recycling assets, with connected points including that the retention and enhancement of assets will assist in leaving a positive legacy for communities. It was also described as key to the creation of a circular economy. Other benefits identified included that it will provide opportunities to enhance our understanding of Scotland's past and the public benefits that can be derived from the historic environment. It was reported that conserving and recycling assets is an area where Development Trusts and other community organisations are already playing an important role. There was reference to there being many examples of communities successfully improving assets, putting them to beneficial use and transforming areas that have been in decline.

One perspective was that there needs to be a presumption in favour of retaining and adapting existing buildings. However, there were also calls for a flexible approach to be taken, including by recognising that there may be instances when existing buildings cannot or should not be preserved. It was suggested that the retention of assets, and locking in of embodied carbon, should always be balanced against redevelopment being the best solution for social and economic reasons. It was also noted that, reflecting the Compact growth principle, there will be instances where redevelopment would be more appropriate to encourage higher density development.

Also, in relation to types of area, it was suggested that a focus on better enabling brownfield development and regeneration is particularly welcome for ports but that, when considering the use and reuse of infrastructure and land, it is vital to consider what is fit-for-purpose in the contemporary context. An example given was that road and rail links may not be configured for the volume or technical requirements of today's freight requirements.

In relation to the reference to including nationally significant sites for investment which are well served by existing infrastructure and sustainable travel modes, there was a concern that this risks seeing investment in locations that have already been well served, resulting in areas that have poor infrastructure becoming even poorer and more disadvantaged. It was also suggested that further clarification as to what constitutes a 'nationally significant site' should be provided, along with a consideration of what actions will be needed to unlock these development opportunities.

In terms of other issues that may need to be looked at, there was reference to:

• What is meant by the term 'embedded carbon', by what means will it be 'locked in', and how will this sequestration be maintained?
• Making the connection to Policy 8 (Infrastructure first). There was specific reference to planning for waste and resources infrastructure and ensuring key projects are enabled in line with resource efficiency and circular economy principles.
• Making the connection to policies relating to vacant and derelict land, blue-green infrastructure and sustainable travel.
• Considering issues around land banks.
• The connection to Energy Performance Certificate requirements, and the need to replace buildings that cannot be brought up to the required standard.

e) Urban and rural synergy

One view was that this principle is a little unclear, including around the need for synergy between areas that have distinct functions. It was suggested that, if the point is to synergise urban and natural, this principle could perhaps be renamed to make that clearer.

Others noted their support for improving the synergy between urban and rural areas, including welcoming efforts to bring more nature into our towns and cities. However, there was also a concern that the principle only focuses on bringing green spaces into towns and cities. It was seen as important that urban practice does not dominate this process and that there is room for distinct rural needs to be addressed.

Suggestions relating to how the focus could be expanded included to cover:

• The kinds of added value that come from locally determined planning objectives.
• Long-term maintenance and the whole life cycle approach.
• Landscape matters.
• Town centres, natural heritage housing and the historic environment.
• Links between food production and urban populations, developing local food, sustainable agriculture and a better appreciation of rural life.

f) Just transition

In addition to a call for more clarity around what is intended, respondents raised a number of issues that could support the delivery of the just transition principle. These included:

• Adding a presumption in favour of community-led development which builds significant community wealth.
• Including reference to the ability of local businesses to shape their places, and to support the transition to net zero and environmentally sustainable ways of living.
• Acknowledging the role of renewable energy generation and the requirement for large-scale renewable energy generation or energy storage, including meet energy demands created by investment to decarbonise transport infrastructure.
• Ensuring that renewable energy developments – most of which are of a scale that requires them to be determined nationally – deliver appropriate local benefits and mitigations. There was reference to quality job creation, the use of local supply chains and investment in supporting infrastructure.

The importance of listening to local communities was also highlighted, although there was also a concern that there is nothing in the draft NPF which actually enables and empowers local people to be more able to shape their places and the transition to net zero. It was suggested that NPF4 should:

• Enshrine powers and give greater weight to local decisions by community councils and local authorities.
• Complement the existing community empowerment legislation by providing genuine participative engagement around development decisions. Instances where communities are attempting to use Asset Transfer or Community Right to Buy processes, where engagement with planning processes would be a more appropriate avenue, were said to suggest flaws in the planning system that need to be addressed.

There was also a call for further information about how the proposals for community wealth building would be applied in decision-making terms by different local authorities.

Other spatial principles

There were also a number of suggestions for further themes to be covered, potentially as additional spatial principles. These were on the theme of:

• Energy. Comments included that there should be coverage of renewable electricity generation and the role of Distributed Energy Neighbourhoods. The lack of a national approach to onshore wind energy planning was described as a significant omission. It was also suggested that the evolution of the transmission and distribution network, the roll out of electric vehicle charging points, and infrastructure to support electrified heating also need to be considered.
• Infrastructure, and especially infrastructure first. Related to the call to focus on energy, was the suggestion that an infrastructure first principle should consider the transport and energy sectors in particular. This approach was described as in line with the recommendations of the Infrastructure Commission for Scotland, which was reported as having stated that infrastructure requirements should not be detached from spatial planning or only addressed through specific policies, but rather should underpin the development of spatial strategies and be integrated with planning decisions.
• Housing. It was suggested that, given its importance, delivering more affordable housing should be included as a key principle. It was noted that housing has been recognised by the Scottish Government as a National Infrastructure Priority, but there was a concern that the draft NPF does not reflect this priority.
• Health and healthy environments. Comments included that health and creating a healthy weight environment should be one of the spatial principles, as the planning system has a key role to play in promoting and supporting health and healthy environments. It was also suggested that having a health-focused principle would support the achievement of the other principles.
• Biodiversity. This was described as a notable omission, with the connected suggestion that there should be a commitment to protecting existing biodiversity from being damaged by development.
• Environmental carrying-capacity. The principle of working within environmental parameters of biodiversity and landscape was described as integral to the spatial principles.
• Sufficiency. There was a call for the concept of sufficiency to be included as a spatial principle: how do we use and develop simply what we need to thrive while enabling the natural world, of which we are a part, to do so too?
• Children. It was suggested that there may be some value in having a principle that relates directly to children and young people, with one option to have a principle defined as 'child-friendly'. This could articulate the need to ensure spaces are reflective of the needs of children and young people, and that their views have been considered.
• Advancing equality and eliminating discrimination. It was suggested that these requirements are not covered by the existing principles, despite it being a statutory requirement for NPF4 to contribute to their delivery.
• Community empowerment. There was a call for community empowerment and place planning to be the seventh principle. It was noted that there is some recognition of the value of participation in the just transition principle, but it was hoped that a separate principle would ensure that the wider principles are founded on good engagement and support for every community to take part.

Action areas for Scotland 2045

The draft NPF states that each part of Scotland can make a unique contribution to building a better future. It explains that our shared spatial strategy will be taken forward in five action areas. Each area can support all spatial principles.

Question 7 – Do you agree that these spatial strategy action areas provide a strong basis to take forward regional priority actions?

Around 300 respondents made a comment at Question 7. Most of those who commented at this question raised concerns about the proposed approach.

The analysis presented here focuses on general themes relating to the action area-related approach. Questions 8-17 cover issues raised about the specific action areas themselves. Question 18, and various questions in Part 3, set out themes or issues which respondents wished to see given greater coverage, including across the action areas.

General comments by those who agreed that the spatial strategy action areas provide a strong basis to take forward regional priority actions included that the Scottish Government's Advisory Group's Report 'Towards a Robust Wellbeing Economy for Scotland' said that differences between regional geography and sectors need to be 'recognised, respected and championed'. It was suggested that the draft NPF does appear to have identified appropriate priorities for different parts of the country, and that the action areas are well developed, with thoughtful actions designed to drive economic and social development in a manner suited to local characteristics.

A contrasting view was that this section of the draft NPF is too simplistic, appears to be contrived and does not add to what can be delivered by NPF4. It was suggested that the action areas are new and untested. There was also a concern about how area-focused actions will be delivered in practice, particularly given that NPF4 is a national policy framework.

Relationship to Regional Spatial Strategies

One of the most frequently-raised issues was the relationship between the action areas and other spatial areas, with respondents most likely to comment on their connection to Regional Spatial Strategies. It was noted, for example, that considerable work has been put into the preparation of interim Regional Spatial Strategies, but that the extent to which those have played a part in the preparation of the draft NPF is unclear.

It was suggested that the detail of the geography and characteristics of each action area needs to be better refined, including in terms of how these action areas fit with the Regional Spatial Strategies, and how Regional Spatial Strategies, and LDPs, are expected to reflect the action areas.

One understanding was that the preparation of Regional Spatial Strategies is to be informed by NPF4, with the action areas appearing to provide a starting point for the development and definition of the role of Regional Spatial Strategies. It was thought, however, that clarification through Scottish Government guidance would be useful. In particular, clarity was sought around what is expected of planning authorities and how Regional Spatial Strategies are to be developed within the action areas.

A number of respondents thought that, rather than creating new action areas, it might be clearer if Regional Spatial Strategy areas were used as the spatial expression of policy approaches.

Relationship to Regional Transport Strategies

A similar theme was that the action areas do not coincide with either the Regional Transport Partnerships or the second Strategic Transport Projects Review (STPR2) assessment areas. A concern was that this may lead to a disconnect between the detail of NPF4 and STPR2.

Relationship to local authority areas

Another frequently-raised issue was the relationship between the action areas and local authority boundaries. It was reported, for example, that in the Local Government, Housing and Planning Committee evidence sessions, concerns were raised about some local authorities being split between different action areas.

As an example, it was noted that the Highland Council area is included within three of the proposed action areas, with an associated concern that the multitude of geographies for planning strategies and priorities will get too complicated, which in turn will weaken the spatial strategy action areas basis for taking forward regional priority actions.

However, there was also a view that all parts of one local authority may not sit well within the same action area. For example, it was noted that North Ayrshire sits within the Central urban area, and that while this works for North Ayrshire's mainland areas, it does not relate well to the islands of Arran and Cumbrae.

Scale and coherence of the action areas

Other issues raised about the proposed action areas included that they are very broad and wide ranging and cover large geographical areas that contain places with significant differences. The connected concern was that the areas are far too geographically diverse to be coherent and have meaningful priorities.

As an example, it was noted that the Central urban area covers a vast area within the central belt of Scotland, which includes Edinburgh and Glasgow but also Loch Lomond and the Trossachs and parts of the island communities to the west. It was suggested that it is not clear how these areas benefit from a single spatial strategy, given that their needs are very different.

There was also a concern that dividing the country into action areas does not recognise the commonality and synergy that extends beyond the 'regional'.

A final observation was that the action areas appear to overlap one another in places. There was a query as to whether this is intentional, and a concern that if it is, this will cause confusion.

Focus of the action areas

As noted above, specific issues relating to priorities are covered at subsequent questions. A general observation, however, was that the main thrust of the five action areas (Innovation, Transformation, Revitalisation, Transition, and Sustainability) are likely to be relevant to other, or potentially all, areas of Scotland. It was also suggested that there is considerable repetition across many of the actions identified for the different areas.

There were also concerns about an approach which gives a theme-based title to each area. Further comments included that it is not clear what value these titles bring, including because they could give the impression that standards and principles – which should apply equally across all areas of Scotland – are somehow the only primary objective for each action area.

North and west coastal innovation

This area broadly comprises the island communities of Shetland, Orkney, the Western Isles, and parts of Highland and Argyll and Bute including the north and west mainland coastline.

Question 8 – Do you agree with this summary of challenges and opportunities for this action area?

Around 165 respondents commented at one or both of Questions 8 and 9.

General comments included that the draft NPF gives a reasonable summary of the challenges and opportunities for this action area, although cannot be comprehensive and should not be read as such.

There was also a view, however, that with such a widespread geographical area there are a lot of differences and, even where there are similarities, there are often some degrees of difference. Examples given included very different settlement patterns and that, while some areas are experiencing population decline, others are seeing their population increase.

Equally, it was suggested that many of the priorities identified extend to other action areas, and particularly to the Northern revitalisation action area. Highland Council noted that its area is included within three of the proposed action areas and contended that all three action areas have similar challenges and opportunities and require similar strategic actions to ensure they are fit-for-purpose and will deliver resilient robust local communities.

In terms of places or communities that should be included in this action area, or that should be given greater focus or priority, the following were noted:

• The challenges and opportunities identified for this action area are shared by Arran and Cumbrae, supporting their inclusion. It was reported that Brodick represents a key centre where lifeline links provide access to the islands and provide important services to the wider island of Arran.
• It is difficult to see why South Kintyre would not lie within the North and west coastal innovation action area, as opposed to the Central urban transformation.
• There is a sense that Caithness and North Sutherland, which is also in the Northern revitalisation action area, is on the periphery, with opportunities and challenges largely missed from both.

Renewables

A number of respondents commented on issues relating to the North and west being at the forefront of efforts to reach net zero emissions by 2045, and the key role that renewable energy will play in delivering that ambition. The recognition that marine and terrestrial planning coordination is important was welcomed. An associated comment was that it will be important to examine the infrastructure needed to support renewables, including offshore renewables, in the area.

Regarding the North and west's role, it was suggested that it would be useful for NPF4 to explain the statement that this is one of the most renewable energy rich localities in Europe, and whether this is in relation to marine or terrestrial renewables and in relation to wind, wave, tidal or other technologies.

In terms of other themes or issues that respondents wished to see given greater emphasis, the following were raised:

• The potential of the ScotWind Leasing and the Innovation and Targeted Oil and Gas (INTOG) options, particularly for north of the action area. The importance of infrastructure investment being focused in the right place to exploit these opportunities was also highlighted.
• The role that key ports and harbours play in supporting renewable energy. With reference to the recent Scottish offshore wind leasing round, and initial indications suggesting a multi-billion-pound supply chain investment, it was suggested that NPF4 could give better direction around a strategic plan for ports and infrastructure to support delivery.
• In relation to Shetland being at the forefront of efforts to reach net zero, how Shetland will sit at this 'forefront' in terms of clean energy provision. Specifically, it was suggested that it needs to be clear that not only onshore wind is required.
• The opportunity to look at wave and tidal innovation on the islands, as well as local energy systems. There was reference to the benefits that such alternative energy sources would bring to the overall resilience of the energy system, as well as to the islands being strategically placed to demonstrate the role wave and tidal can play.
• The vulnerability of the region's energy system and the lack of resilience and investment in the current grid infrastructure. It was suggested that there is a strategic need for grid reinforcements to provide energy security to communities, as well as to facilitate national energy transition.

A number of respondents commented that it is also important to recognise the quality of the environment in the North and west, and the level of environmental protection that will be required. For example, it was suggested that when focusing on innovation, it should also be acknowledged that there is a need to consider:

• The appropriate location and scale of associated development.
• The potential for community projects where local benefits can be realised.

Biodiversity and natural assets

The recognition of the richness of the biodiversity of the area and protected sites was welcomed, although it was thought that the challenge of balancing the protection of nature while developing renewable energy is not fully recognised. More widely, there was a concern that clear support for nature recovery on land and at sea is missing.

It was also suggested that the following could be referenced:

• The two UNESCO Global Geoparks (Shetland and North West Highlands) and the Wester Ross UNESCO Biosphere, all three of which exist to facilitate, generate and support sustainable development.
• The Alliance for Scotland's Rainforest, which is supporting the vital, unique, and globally important biodiverse habitat and carbon sink in Scotland's north and west.
• The risk from invasive non-native species to Scotland's islands. It was noted that any developments that could enhance pathways or create pathways for invasive non-native species to move around require careful consideration and appropriate mitigation. There was specific reference to ensuring protection of our internationally important seabird populations, and the associated nature-based tourism industry.

There was also reference to the challenges resulting from an unprecedented rise in visitor numbers over the last decade, coupled with inadequate infrastructure and a fragile ecosystem. It was suggested, for example, that there is pressure to develop tourism accommodation and services in National Scenic Areas (NSAs). There was a call for better direction on how to conserve tourism resources and support the livelihoods and culture of local communities, while managing the need for economic growth.

Climate change and infrastructure

It was considered important to highlight that island and other coastal communities could be disproportionately affected by the impacts of climate change due to sea level rise, extreme weather events and the associated impacts of coastal erosion and flooding.

There was an associated concern that there is little mention of the islands potentially requiring significant and expensive infrastructure upgrades due to climate change impacts. It was suggested that NPF4 should be supported by a policy to prioritise coastal adaption planning, actions, infrastructure, and the associated funding and investment in these vulnerable areas.

Connectivity

Connectivity, both in relation to transport and the digital infrastructure, was an important issue for a number of respondents.

In relation to transport infrastructure, it was acknowledged that decarbonisation is important, but it was also argued that connectivity itself is of critical importance to communities, businesses and individuals in the region. How to provide and maintain reliable and accessible infrastructure that improves resilience was described as a key challenge, with future investment in lifeline transport infrastructure described as a necessity. There was particular reference to:

• Overcoming ferry capacity and reliability constraints.
• Air services and alignment with the Scottish Aviation Strategy. It was also suggested that there are opportunities for innovation in low carbon air travel, as Orkney has been established as a Sustainable Aviation Test Environment.

Overcoming barriers to better broadband installation and maintenance was also seen as key and it was suggested that there is a strategic need for high-speed digital infrastructure throughout the region to enable more opportunities to work remotely and base businesses in rural and island areas. It was reported, for example, that the expansion of the blue economy and coastal communities' ability to attract growing specialist firms is inextricably connected to Scotland's ability to offer high quality modern business services in remote areas, of which superfast broadband provision is one.

The challenges of upgrading the network to particular areas of Scotland were noted, as was the limited window to upgrade due to the nature of the build being carried out via subsea cabling. There was also reference to the need to simplify the process of securing wayleaves, and that accessing property is especially challenging in Scotland owing to the more complex nature of property ownership compared to the rest of the UK.

Housing

In relation to housing, it was seen as important to acknowledge that the challenges relate both to availability and quality, as well as to how housing interfaces with many of the other challenges set out. It was noted, for example, that a lack of housing is linked to depopulation. It was also noted that although welcome, the enhancement of housing standards impacts on the cost of delivery and could have an impact on the number of private rented sector homes.

There was support for providing greater choice and more flexible and affordable homes to support the varied needs of rural communities, and for ensuring that demand is assessed accurately.

Land and asset ownership

It was suggested that there is a missed opportunity relating to community land and asset ownership, with the associated challenge being the particularly unequal nature of land ownership in this area of Scotland. It was suggested, for example, that the reference to relatively high levels of community land ownership does not reflect landownership patterns in Highland and the Western Isles. The associated concern was that communities are unable to develop sustainably to meet their needs without access to land, leading to depopulation and lack of community wealth.

Overall, however, it was suggested that community wealth is a major asset of the North and west but is underrepresented in the draft NPF. It was reported, for example, that 75% of the Outer Hebrides is in community ownership and volunteering rates are among the highest in the UK. It was also thought that the reference to community trusts as providing small scale investment to help manage the impacts of tourism undervalues their role; in fact it was suggested that community trusts can have a big impact and influence on social capital, enterprise, biodiversity and stewardship of the land.

Population levels

It was noted that population decline is not a blanket issue across the area, including across the islands, and there was a call for NPF4 to set out a more targeted approach and statement to reflect the diversity of demographic challenges across Scottish islands.

Overall, it was thought that population challenges deserve higher prominence and clearer actions, including around supporting a more balanced, sustainable age profile. It was suggested that this will require policies and actions to help to attract and retain more younger people, and those in the 25-49 age bracket, who are most likely to be economically active and have families.

Cost of living and employment opportunities

It was reported that the region has some of the lowest average household incomes, but highest cost of living, and that the coverage could reflect these challenges and in particular problems relating to fuel poverty. In relation to energy, it was noted that there will be significant challenges ahead for this region as the nation grapples with hikes in energy prices and supply issues. In relation to other financial challenges faced by those living in the North and west action area, there was reference to inbuilt transport costs adding a 30% surcharge to building materials in some areas.

It was accepted that, as set out in the draft NPF4, employment opportunities in some areas tend to be in the public sector, tourism and lower wage sectors. However, it was suggested that this does not reflect the diversity of job opportunities in some areas, such as Orkney, where some opportunities can be highly skilled and highly paid.

It was also noted that, while lack of economic diversification has historically inhibited in-migration to the region, the pandemic has created new ways of working and an opportunity for this area to be a destination for those working from home. It was suggested that this could be transformational as even the most remote communities can now benefit from the multiplier effects of new residents and well-paid jobs that are not dependent on the proximity of industry or service centres. Relating back to connectivity, it was suggested that universal high-speed broadband is currently a major inhibitor of this opportunity.

In terms of other types of employment opportunities, there was reference to encouraging growth in the workforce for forestry and environmental businesses.

Gaelic

It was suggested that, for areas which have a significant proportion of their population with Gaelic skills, there is a considerable opportunity around Gaelic as an economic asset. There was reference to the creative industries, tourism, heritage, and the food and drink sectors in particular.

It was also suggested that the Scottish Government should consider the extent to which NPF4 will contribute to the sustainability and development of the Gaelic language and culture.

Fisheries and aquaculture

A number of respondents made comments relating to fisheries or aquaculture. One view was that aquaculture is a major contributor to the economy and supports rural communities while enabling the achievement of net zero targets. It was noted that the west coast and islands are particularly important for both finfish and shellfish but that the only opportunity outlined is the development hub at Machrihanish. It was suggested that the opportunities for expansion in open net pen farming, and supporting innovation, should also be set out.

There was also a view that it is no longer adequate to refer to 'finfish aquaculture' as if it is a single activity and that NPF4 should deal separately with marine open net cage finfish farming, closed or semi-closed containment fish farming at sea, closed containment fish farms on land, and freshwater fish farming. There was a call for NPF4 to set a clearer direction as to the kind of aquaculture to be encouraged, especially to achieve its overarching aspirations for sustainable use of natural resources and supporting achievement of net zero.

Question 9 – What are your views on these strategic actions for this action area?

Four strategic actions were included for the North and west coastal innovation action area.

General comments included that there is potential for conflict between the different strategic actions proposed. Examples given were between peatland restoration targets and siting of onshore wind farms on peatland, and between nature-based tourism and other developments which may have a detrimental impact on nature.

In terms of the potential of the strategic actions, there was a hope that they can help to improve the governance and land management of natural assets for greater community and ecological benefits across the north and west region. Connected to this was a suggestion that this part of the spatial strategy could look to the developing vision and aims of emerging community collaborations such as the NorthWest2045 project.

There were also themes which respondents would have expected to see reflected in one or more of the proposed actions, or to form an action in their own right. These included:

• Community energy. It was suggested that this should be at the forefront of any discussions on carbon neutral places, and that the Scottish Government should acknowledge the life changing impacts community energy schemes, which are focused on fuel poverty, could have in this area.
• Local food production and provision. It was reported that island and coastal areas are vulnerable to food supply chain issues, so encouraging more local food production will improve equality, wellbeing and wealth building. Sustainable and fair access to affordable healthier food was seen as supporting future resilience and broader objectives, including reduced child poverty and improved health outcomes. It was suggested that this theme would also be relevant to the other action areas.

1. Create carbon neutral coastal and island communities

In relation to the title of Action 1, it was suggested that it should refer to 'net zero' rather than 'carbon neutral coastal and island communities'. It was also suggested that the specific actions set out do not go far enough and will not in themselves create carbon neutral communities.

20-minute neighbourhoods

A number of the other comments addressed the appropriateness of the 20-minute neighbourhood concept to rural and island communities. The recognition that island and coastal communities will need a bespoke and flexible approach to the concept of 20-minute neighbourhoods was welcomed. An associated suggestion was that Action 1 should recognise explicitly that 20-minute neighbourhoods cannot practically be delivered in many rural and island areas.

Other comments included that:

• In some island areas the approach runs the risk of leading to significant further centralisation around one or two main settlements, to the further detriment of the surrounding fragile rural areas.
• It is unlikely to be suitable for 'remote rural' and 'very remote rural' crofting communities which are likely to need a radically different approach that reflects their distinct needs. It was suggested that there should be a reference to islands and coastal communities needing a bespoke and flexible approach to the concept of 20-minute neighbourhoods connectivity planning, and that this should apply across NPF4.
• It should be made clear that LDP spatial strategies will be underpinned by bespoke sustainability principles that respond to the local context.

Coastal flooding

The recognition that coastal and island communities are vulnerable to the effects of climate change, sea level rise and extreme events was welcomed, although there was a call for clarity around the specific actions to be taken at local level to minimise and mitigate these risks. It was suggested that it would be helpful to explicitly promote nature-based solutions to mitigate coastal flooding and erosion. There was also a call for a commitment to invest in 'the proactive and innovative approaches'. Other comments included that:

• There should be reference to the impacts on land use in coastal areas, for example that large areas of coast will be unsuitable for future development and land will need to be allocated to relocate essential infrastructure and services.
• Planned population growth in the North and west action area needs to carefully marry mitigating risks of increased coastal flooding and erosion arising from future climate change.
• Some areas will become uninhabitable within the lifetime of NPF4, and some communities will be become unviable. It is not clear what can be done, but recognition that this is a possible outcome of failing to tackle climate change is needed.

Local communities and services

There was support for ports and harbours being a focal point for electric vehicle charging, as well as employment, although it was also suggested that there should be a stronger statement that ports and harbours are drivers for economic growth and regeneration in coastal and island communities.

It was also suggested that issues relating to communities should be framed within a broader explanation of place and how it directly shapes health, wellbeing, and inequalities.

Affordable housing

The importance of affordable housing was highlighted by a number of respondents, with further comments including that significant additional housing is required in many rural and island areas to allow communities to sustain themselves and attract an economically active new population.

It was suggested that planning authorities will need to take a more flexible, long-term approach to where housing can and should be developed, and that the Scottish Government and other partners will need to invest in affordable housing provision through direct and flexible funding.

However, there was also a view that any housebuilding should not be to the detriment of the environment and wildlife. One perspective was that climate and environmental issues must take priority.

The acknowledgement that there are additional costs for homebuilding and development more generally in islands was welcomed. It was suggested that NPF4 should state that the quality of building and development in islands will not be compromised in response to these cost pressures, and that Government infrastructure funding needs to factor in the higher cost of building/development in island communities.

Reversing population decline

Comments included that repopulation may be required in a range of areas, so references to peripheral and fragile areas need to be removed. It was suggested that a simple statement in favour of repopulation at the strategic scale, backed up by implementable policies, is what is required. There was also a call for decisions on where to support population growth to be made with the full involvement of communities.

Other comments addressed the relationship between repopulation and other NPF4 priorities. It was suggested, for example, that rural repopulation cannot happen hand-in-hand with nature conservation or meeting net zero targets.

There were also questions as to the appropriateness or viability of reintroducing people to previously inhabited areas. It was noted that repopulating uninhabited areas will further stretch public service budgets, and that this could reduce the quality of service provision for existing communities. There was a call for existing viable communities to be supported prior to the development of projects aimed at reintroducing people to areas that are not currently inhabited. However, if this approach is taken forward, it was suggested that there should be a focus on people being economically active, as this is what is required to create sustainable communities.

2. Support the Blue and Wellbeing Economies

Collaboration and alignment of terrestrial and marine planning

There was support for the focus on collaboration and the strong alignment of terrestrial and marine planning. Associated comments included that there is a potential role for Regional Spatial Strategies, which should be acknowledged in NPF4.

Renewable energy

A number of the comments addressed the potential of renewables in the north west and included that this section would benefit from highlighting the significant marine and coastal resources and the opportunities on offer from marine renewables. It was seen as important for NPF4 to support the terrestrial development and infrastructure requirements associated with offshore renewables development and the associated supply chain opportunity. There was specific reference to the recent Scottish offshore wind leasing round, and it was reported that initial indications suggest a multi-billion-pound supply chain investment in Scotland will arise from this. There was a call for NPF4 to give better direction for a strategic plan for ports and infrastructure to deliver this.

It was also suggested that NPF4 should:

• Providing clarity around how Shetland can be at the forefront of efforts to reach net zero.
• Include Port Askaig, Islay as a key strategic site for investment associated with port infrastructure to support offshore renewables and also refer to improved grid connection for Islay to support renewables.

Finally, it was suggested that there should be a focus on keeping some energy locally, with smaller-scale community owned renewables not only helping to broaden the means to achieve net zero but allowing communities to become more resilient and address fuel poverty.

Research excellence and innovation

There was a concern that the potential for this area to be a centre of excellence for research and technology has been underplayed. It was noted, for example, that the existing centres are internationally recognised, and provide a coherent network from the southern part of the area all the way up to the Northern Isles. It was suggested that the area is in a unique position to develop new marine research and technologies, not just in relation to renewables and aquaculture, but also for blue carbon.

It was also suggested that island communities are building on a legacy of innovation, not just on the natural advantage of having significant energy resources, and that this should be recognised. Specifically, there should be reference to the European Marine Energy Centre on Orkney and the first phase of the Orkney Research and Innovation Campus having been completed.

Sea ports

Respondents agreed that ports and harbours will be important to support the development of marine renewables and the associated supply chain. There was support for the reference to seaports being a focus for investment in the blue economy and that new infrastructure and repurposing of land will help to shift activity to supporting offshore renewables.

However, it was suggested that the draft NPF does not recognise the role of all ports and harbours adequately, and that a great many ports and harbours have many roles and functions, sometimes competing and other times unique or complementary. It was noted, for example, that mainland ports act as important provisioning centres for islands, can be a central part of the industrial basis of an area, or can provide a specialist facility such as at Kishorn.

Other suggestions included that Action 2 should recognise the importance of:

• Servicing offshore wind development or the provision of low/zero carbon fuelling for shipping.
• The Minch as a maritime route and all ferry routes, for example the ferry from Mallaig to the Small Isles is not shown.
• The development of Scapa Flow as a strategic asset. It was suggested that more should be made of the opportunities that exist within Scapa Flow as a whole, rather than having a singular focus on the specific pre-determined projects that have been identified within the area.
• Stornoway as a 'key port'. It was reported that Stornoway was previously identified as a 'key port and coastal and island hub' in NPF3 and there is commitment to develop a £50 million deep water terminal in the near future to support a range of diverse industries and economic activities.

Finally, there was support for ports and harbours being focal points for electric vehicle charging, although it was noted that most people in rural areas still rely on the private car and this needs to be acknowledged. It was also noted that rapid electrification of transport in this part of Scotland, which relies predominately on electric heating, will require onsite generation and storage to help balance the grid and manage consumer fuel costs.

Space ports

It was suggested that the reference to Space Hub Sutherland should be moved from Northern revitalisation into North and west coastal innovation, bringing all space port references together in one place. There was also a call for further emphasis on the supply chain potential, both upstream and downstream.

However, others were doubtful about whether there should be any emphasis on space ports. It was reported that they have attracted local opposition and decisions will need to take account of local concerns. There was also a concern that space port developments to date have generally not taken account of the rich biodiversity of the remote locations selected for their siting.

Food and drink

Issues raised included that:

• There is no reference to farming. It was noted, for example, that farming is Orkney's main industry and provides produce to international and national markets, as well providing a local source of food and quality produce.
• There is a focus on high value, mostly exported food and drink which does not support or encourage growing for local consumption and strengthening local food resilience.

Tourism infrastructure

Comments included that it is important to look at sustainable and active travel solutions, not simply providing infrastructure for the private car.

There were references to other tourism-related activities or facilities that should be covered, including:

• Recognising and giving equal value to Scotland's UNESCO Global Geoparks and Biospheres. It was noted that the North and west coastal innovation area contains three out of four of these territories.
• The role of venues, events, festivals and activities which celebrate traditional culture, support communities to live well, and attract visitors.

Finally, it was noted that the reference to the Rural Tourism Infrastructure Fund may need to be reconsidered, since it is designed to address inadequate infrastructure where pressure from visitors is causing problems. There was an expectation that NPF4 should be setting out a planning system that can deliver infrastructure development via planning authorities and key agencies.

3. Protect and enhance blue and green infrastructure

General issues raised included that, if NPF4 is to follow through on its commitment to building future net zero and nature positive places, it needs to be firmer in its approach to how natural and cultural assets are to be managed and protected. It was suggested that 'protection' should be added to the reference to careful planning and managing of natural and cultural assets.

Other comments included that:

• The coastal contribution to the protection of blue green infrastructure is under-represented, and developments in other action areas, such as around blue carbon, should not undermine the positive benefits of marine and coastal habitats.
• The significant contributions and resources private landowners can bring to creating an enhanced nature network should be recognised.
• Regional Land Use Partnerships (RLUP) are already a means of delivering the action needed to deliver climate and natural capital targets, in a way that is joined up with wider economic and land use planning. Thought should be given to how any local projects would complement the RLUP pilots that are already underway.

Peatlands and woodland

Although the prioritisation of peatland restoration and woodland creation was welcomed, there was a concern about the focus on offsetting. It was noted that the Scottish Government has already committed to not using overseas credits to meet domestic emissions targets, and it was suggested that NPF4 should not go down the path of opening up large swathes of Scotland's landscape for offsetting activities.

Similarly, it was suggested that NPF4 needs to consider how peatland restoration aligns with wider energy targets and polices on onshore wind development, particularly for the region which contains a large percentage of Scotland's blanket bog habitat.

Finally, there was a concern that the richness of our remaining temperate rainforest has been overstated and that urgent investment is needed, including around tackling invasive species.

4. Strengthen resilience and decarbonise connectivity

There were few specific comments relating to this action, although the proposed 'Islands Connectivity Plan' was very much welcomed. Associated points included that:

• Its inclusion was taken to be a commitment for the Scottish Government to fund the ferry investments that are required in Orkney to ensure inter-island ferry service are up-to-date and provide communities with the same connectivity that is enjoyed by the other island groups of Scotland.
• Ferry services provide a crucial link for stores in terms of how they receive or bring in supplies, but retailers must often contend with rising ferry costs or reduced return ferry services.

The commitment to investment in ultrafast broadband and to improve mobile coverage was also strongly supported, and the acknowledgement of a need for improved grid connections, including high voltage grid cables, was welcomed.

Northern revitalisation

This area broadly includes Highland with parts of Argyll and Bute, Moray and much of the National Parks. There are links west and north to the island communities.

Question 10 – Do you agree with this summary of challenges and opportunities for this action area?

Around 170 respondents commented at one or both of Questions 10 and 11.

One perspective was that the summary is considered and comprehensive. However, there was also a view that the focus is on what can be extracted from the area, in terms of renewable energy and carbon sequestration, rather than on creating vibrant, sustainable places. An associated comment was that the development potential and opportunities are focused primarily on the urban centres and growth corridors. In contrast, it was suggested that some areas, including the more rural areas of Caithness and North Sutherland, are largely overlooked.

The appropriateness of framing the action area around revitalisation was also questioned. It was suggested, for example, that revitalisation is not the over-riding priority for the Highland area, given some significant levels of growth and economic activity. There was also a query as to whether the reference to there being a need for low skilled and low paid jobs in rural areas is as intended. There was also a concern that badging the area as 'rural' is not helpful and that the vibrancy of the area's city and communities should be acknowledged.

Also in relation to Highland, it was noted that the area covers only parts of Highland, with the Highland Council area included within three of the proposed action areas, North and west, Northern and North east.

Relationship to other action areas

A number of comments addressed the relationship between the Northern and North and west action areas. They tended to suggest that there is a great deal of crossover, in terms of both the challenges and opportunities, as well as the strategic actions required.

Some respondents proposed combining the Northern and North and west action areas, with supporting arguments including that:

• Delivery across these two action areas will require coordination among the same planning authorities, with greater alignment enabling efficient use of skills and resources.
• From a management perspective, it would be simpler to ensure that each National Park, and any future National Parks, sit wholly within one action area.

A number of local authorities commented on how their area is divided between action areas, as summarised below:

• Highland Council suggested that all three of the action areas into which it falls have similar challenges and opportunities and require similar strategic actions to ensure they will deliver resilient, robust local communities.
• Moray Council commented that the split of its area between the North and west and Northern action areas causes confusion, and it would prefer to be entirely within one or the other.
• Perth and Kinross Council noted that parts of rural Perth and Kinross are within the Central urban action area, but that the challenges, opportunities and actions set out for the Northern action area are more appropriate to Highland Perthshire.
• Stirling Council commented that the northern part of its LDP area appears to lie within Northern, but also in Central urban. They sought clarity in relation to what is proposed.

Areas to be referenced

In terms of particular areas, or area-based plans, that respondents were looking to see covered, there was reference to:

• The contribution that the NorthWest2045 area already plays, and will increasingly play in the future, in addressing national ambitions for net zero and particularly the decarbonisation of energy networks.
• The proposed Moray Firth Coastal Natural Heritage Park.
• Moray's key role in terms of defence at RAF Lossiemouth and Kinloss Barracks.
• The inward investment at the Forres Enterprise Park, along with other innovative Moray Growth Deal projects and the Elgin City Centre Masterplan. An associated point was that one of the key challenges Moray faces is to continue to develop skilled jobs and diversify the economy from being defence dependent.
• The importance of the ferry connections to Orkney between Scrabster–Stromness and Gill's Bay–St Margaret's Hope.

Regarding the reference to the Flow Country as a possible World Heritage Site, it was noted that it will remain an internationally important habitat, irrespective of whether it achieves World Heritage Site status. It was suggested that its international significance for important blanket bog habitats and species, and considerable carbon storage value, should be referenced.

Biodiversity, landscape and National Parks

There was a concern that there is a lack of detail on biodiversity priorities or actions. It was also suggested that the role of landscape in creating and sustaining thriving communities should be better reflected.

Respondents also suggested that this action area should cover how landscapes are to be safeguarded, including opportunities for protecting the extensive sense of remoteness, openness and wildness of hill ranges and coasts. It was noted that the roles of NSAs, Wild Land Areas (WLAs) and National Parks are not set out. Other comments about National Parks included that the commentary should reflect that National Parks are places for some people to live and work, play an important role in Scotland's visitor economy and have a key role in conserving and enhancing biodiversity and mitigating and adapting to climate change.

It was noted that the action area covers part of the two National Parks, a number of NSAs and significant areas of wild land and peatland that are integral to the successful delivery of nature-based solutions. Careful planning and management was seen as vital to the delivery of travel networks, renewable energy infrastructure, and digital and mobile solutions without undermining landscape quality and the gains brought by biodiversity enhancement.

Other themes or issues that respondents wished to see covered included:

• That extensive commercial planting of non-native conifers on peatland can damage the peat and prevent restoration. It was suggested that consenting and funding systems must support the aims for a net zero, nature positive future.
• Opportunities for realising the potential for native woodland expansion and peatland restoration.

Housing

In relation to housing it was suggested that, while the reference to the acceleration of housing prices is welcome, there needs to be a more cohesive planning system intervention in response. In terms of supply-related aspects that need to be considered there was reference to:

• Recent house price increases not being solely attributable to the pandemic, with a major shift in housing use towards second homes and short term holiday accommodation also in play.
• Requiring a carefully balanced approach to development planning, with a wide range of mechanisms to support urban growth alongside the long-term sustainability of rural communities.
• Providing housing for young people to remain living in areas where they grew up, along with the challenge of creating suitable housing opportunities for the ageing population.

There was also reference to the urgent need to consider the limitations of existing housing, and there was a report that private landlords are starting to leave the sector. The connected concern was that the shortage of housing is going to worsen before it gets better.

Renewables

A frequently-raised issue was that the area's importance in relation to renewable energy, and particularly offshore wind, is underplayed. In terms of particular opportunities, there was reference to:

• The Opportunity Cromarty Firth consortium and its key projects designed to ensure Scotland capitalises on offshore wind opportunities.
• The Port of Cromarty being of national significance. It was noted that it also has substantial natural assets – peatlands and forests – that are carbon sinks.
• The ScotWind leasing round run by Crown Estate Scotland, which will catalyse a significant increase in offshore wind deployment in the northern North Sea with the grant of leases totalling ~25GW.
• The 4.5GW of offshore renewables in the recently announced INTOG Decarbonisation leasing round. It was reported that these will all be constructed off the north and east coasts, and that this will likely become Scotland's largest series of infrastructure projects in the next decade.
• Plans for a wind tower manufacturing facility at Nigg Energy Park.
• The electricity network facilities being developed in Highland, such as the major Convertor Station development in Caithness, which were described as being on an internationally significant scale.

In relation to onshore wind, the current proposal to make the Flow Country a UNESCO World Heritage Site was noted, and there was a query around what such a designation would mean in terms of planning policy, particularly in relation to wind energy development. It was recommended that NPF4 should make it clear that a World Heritage Site designation would not act as a constraint to future wind energy development.

However, there was also a concern that the development of windfarms in parts of the Northern action area often involves the removal of large amounts of peat.

Other themes

Other themes or issues that respondents wished to see covered included:

• Overcoming the barriers to better broadband installation and maintenance being key to unlocking opportunities for improved access to, and use of, digital technology across this northern area of Scotland.
• The acute visitor management issues and inadequate visitor infrastructure in many known visitor hotspots, and the resulting impacts on the natural environment. It was reported that there is often a mismatch between visitor numbers and visitor infrastructure at these hotspots.
• Local community-led food growing initiatives. It was reported that these cannot reduce food miles on volunteer labour, but that community-led growing initiatives could feed into the creation of local food jobs, for example through supported employments schemes.
• The importance of working with communities to understand their needs and ambitions for their place. It was suggested that a two-way flow of interaction, engagement and idea and knowledge sharing discussions from RLUPs down to community developed Local Place Plans, and back up the chain, will be crucial.

Question 11 – What are your views on these strategic actions for this action area?

Four strategic actions were included for the Northern revitalisation action area.

5. Strengthen networks of resilient communities

A general issue raised related to the title of this strategic action, with comments including that 'resilience' and 'networks' are difficult concepts to deliver through direct planning outcomes. Suggested alternatives included:

• Create a balanced and sustainable rural population.
• Repopulate and build climate resilience and community wealth.

In terms of locations or projects, it was suggested that the following should be referenced:

• Inverness' role in providing regional sports facilities should be acknowledged.
• Dingwall should be added to the list of key settlements.
• Better acknowledgement of the scale and range of investments within the Inverness and Highland City-Region Deal.
• Key land use and connectivity issues, such as Bus Revolution and Housing Mix Delivery.

Flood risk and water supplies

The inclusion of water systems and drainage under this strategic action was welcomed, and it was suggested that flood risk management should feature in all the action areas.

Other comments included that:

• Innovation will be needed to secure and maintain water supplies and drainage. This will include in relation to nature-based flood risk adaptation and affordable, low-carbon, distributed heat and electricity networks.
• The emphasis could be shifted onto nature-based adaptation solutions being essential to minimising the flood risk associated with changing ecosystems, and to protecting affected communities.
• There needs to be greater consideration of water and sewerage infrastructure to support increased tourism in remote areas.

Other themes

Other themes raised in relation to this strategic action included:

• There is reference to the reuse of redundant buildings but no policy suggestions to support this approach.
• While new homes may be needed to retain local people and attract new residents, there are an increasing number of planning applications for the development of homes on land rich in biodiversity and with no consideration being given to the vital habitats at risk.

6. Stimulate green prosperity

Clarity was sought as to what is meant by a 'flexible approach to planning' helping to attract investment and the growth and diversification of businesses. It was reported that flexibility is often taken by planning authorities to mean they should give approval to projects purely on the basis of economic gain. It was suggested that the emphasis should be on a flexible approach to planning which respects the need for thriving environments and nature-based solutions.

Other comments relating to the growth and diversification of businesses included that:

• Co-location of services should be considered. An example given was placing commercial greenhouses next to wastewater treatment plants so they can benefit from nutrients and heat.
• The exclusive focus on protecting 'higher quality' agricultural land is unhelpful in reducing food miles. This definition needs to be revisited, as a lot of land in the Northern action area that is used to produce food may fall outwith this category.
• It is important to make reference to selected aquaculture opportunities in this action area, including in relation to shellfish.

Tourism

Comments relating to tourism included that the tourist assets noted are based on private car use and hence are carbon-intensive and cause known issues around congestion and air quality.

It was suggested that future approaches should:

• Focus on a sustainable transport response based on community transport provision and capability. Shared transport and enhanced public transport provision was seen as having a strong role to play in determining how these tourist destinations meet the challenges of the climate crisis.
• Place an emphasis on longer stays in base locations, including through improvements to infrastructure.
• Recognise the need for continued investment to grow support services for outdoor activities.
• Recognise that the darker skies found in rural parts of this area are a valued asset and an aspect of the high quality environment that attracts tourists.
• Consider interactions between actions and priorities in NPF4 going forward. For example the impacts of the planned Coire Glas pumped hydro electric scheme on the Great Glen Way and the National Cycling Network's Caledonia Way during its construction phase, with appropriate mitigation needing to be a priority if these routes are to act as a spine for active travel networks.

It was also suggested that the reference to improving infrastructure for tourism should be expanded to include infrastructure for communities, as tourism does not sit in isolation.

Renewable energy

The reference to a carefully planned approach to renewable energy was considered unfortunate; it was reported that this is exactly what planning authorities have tried to do over the last 20 years, but decisions have continuously been made through appeals which have now completely eroded that carefully planned approach.

There was also a concern that the text reads as if renewables, growth and transmission upgrades are external to the NPF4 spatial strategy, rather than it being a strategy helping to maximise their potential. It was suggested that this approach is fundamentally inconsistent with the Infrastructure first and Green energy policies (as set out in Part 3).

There was support for the reference to the importance of renewable energy generation for climate mitigation, and the need for the repowering and extension of existing wind farms. However, there were also calls for clarity on what approach will be followed for new wind farm proposals. It was suggested that a strategic steer, informed by sensitivity studies, would be helpful. Another perspective was that there is a need for a clear and stated presumption in favour of development of onshore wind.

With regard to offshore wind, it was suggested that the reference to the potential to increase offshore wind energy capacity should be strengthened, including through reference to Crown Estate Scotland's programme of leasing rounds, including the strategically significant ScotWind leasing round.

Other issues raised included that:

• Electricity storage systems need further consideration. There was reference to gravity mechanisms, compressed air and batteries needing to be developed.
• There is little mention of geothermal solutions, despite large scale, deep drilled distributed heating systems having been very successful in Nordic countries and in Germany.

Ports

The recognition of the role of ports was welcomed, particularly in relation to the offshore renewable sector.

With regard to low carbon hydrogen production and storage, it was suggested that the investment required is considerable, as are the technical challenges involved. It was seen as important that NPF4 reflects the changing environment of renewable energy to ensure that national planning policy remains reflective of the current position up to 2045.

It was noted that the Opportunity Cromarty Firth project is referenced, but that its national impact and significance, irrespective of whether it is awarded Greenport/Freeport status, is not recognised. Specifically, it was reported that The Crown Estate Scotland Ports Study identified the area as a frontrunner for the creation of a strategic national renewables hub. There was a concern, however, that there is also no reference to the need for projects such as Opportunity Cromarty Firth to carefully consider biodiversity and designated wildlife sites.

Finally, it was suggested that Oban should be referenced as having the potential to support offshore renewables development on the west coast.

7. Nurture nature-based solutions

A number of the comments addressed the terminology used under this strategic action. Points made included that:

• The lack of definition of the term 'nature-based solutions' can open up the possibility of greenwash offsetting schemes.
• The use of 'natural capital' is unhelpful, including because it suggests that nature is a pawn which can be used and manipulated to human advantage.

Locking in carbon

The concept of this area acting as a 'mitigation bank' for national climate change commitments was described as interesting, but as raising some questions about the just transition and climate equity which should be addressed in NPF4.

The assertion that the area is a net carbon sink overall was said to not be supported by official figures, and there were also some concerns about the reference to locking in carbon. These focused around allocating land for carbon capture in order to offset emissions elsewhere, with the suggestion that there is a growing trend for vast tracts of land to be used in this way.

Woodlands

Although the references to the creation and enhancement of native woodlands were supported, it was suggested that:

• Engaging local communities in the forestry planning process will be key to ensuring that forests are accessible and will provide educational and cultural benefits to those living nearby or visiting from further afield.
• There should be an emphasis on improving the resilience of woodlands through natural regeneration, rather than planting and fencing.
• There should be reference to Forestry and Land Scotland's nationally important tree nursery in Moray.
• A reference to further opportunities to process and add value to timber products locally should be added.

Although the potential of forestry, woodland creation, native woodlands and peatland restoration was noted, it was also stressed that this must not be to the detriment of existing biodiversity and wildlife.

Biodiversity and land use

Other comments also referenced the importance of considering any impact on biodiversity. For example, it was suggested that both the 'Strengthen networks of resilient communities', and 'Stimulate green prosperity' strategic actions could have huge positive impacts on biodiversity if done in the right way, but that this it is not really mentioned.

However, there was also a question about what 'resilient nature networks' will look like, and how these will be accomplished. It was suggested, for example, that climate and nature conscious approaches to deer management and the rewilding of moorland will be required.

Other suggestions were that reference could be made to:

• The significant contributions and potential of private land managers and owners.
• The importance of RLUPs.

With regard to the reference to conservation at landscape scale, there was a view that conservation as a concept is no longer the gold standard, since our ecosystems are too degraded. It was suggested that, if we want the many benefits that come from revitalised ecosystems, the need for restoration should be made explicit.

8. Strengthen resilience and decarbonise connectivity

Better connectivity was described as vital to many of the plans for the Northern action area, including delivering the action to 'strengthen networks of resilient communities', and in relation to diversifying business, including the tourism industry.

Another general observation was that a strategy for future resilience is needed and that this should take account of the changing coast as a result of climate change.

Digital

It was suggested that the barriers to better broadband connectivity should be referenced. There was a concern that the very positive reference to making use of emerging broadband technologies is not supported through the national developments.

Public transport infrastructure

It was suggested that references to a low carbon future involving transport improvements should be strengthened, and that NPF4 must include transport improvements in line with those proposed previously as a possible national development for Highland.

There was a concern that the narrative on transport focuses on road and air, and that while there is a welcome statement around the 'continued modal shift to rail', there is no explanation of how this will be achieved. It was suggested that NPF4 could be more transparent about the types of major improvement planned, including by picking up on the transport interchange and park and ride opportunities set out in the Highland Indicative Regional Spatial Strategy.

Some of the comments considered particular destinations or routes, including that:

• There needs to be greater public transport connectivity to other regions, and especially to central Scotland.
• Aside from existing reference to electrification, there could be reference to alternative traction on other rail routes in Highland and linking east. There was specific reference to rural/scenic lines, including the Far North line.
• The City of Aberdeen and surrounding areas should prioritise shared transport solutions to complement existing active travel networks.

Other comments included that:

• For journeys beyond rail, electric shuttle bus services could link people arriving at train stations to wilder, more remote destinations.
• The emphasis of active travel networks should be expanded. Such networks would not only support connectivity for local communities but would be an important component in promoting sustainable tourism.

Roads

The recognition that local communities and businesses will continue to depend on road travel was welcomed, and there were a number of comments about specific routes. These included:

• Improving the A83 also goes beyond the issue with the Rest and Be Thankful. It includes the whole route, which is a lifeline link that requires investment to be safer and more resilient to climate change.
• Clarification is required as to what is proposed for the A96 and A9.
• Resilience problems on the A82 should be recognised. It was suggested that The Great Glen should be recognised as a strategic connection route (important as a route for both road and canal transportation) and that the need for investment in A82 improvements should be included.
• The Corran Ferry should also be acknowledged and strategic connections sense-checked. For example, the ferry route from Ullapool is shown as a strategic connection, but the A835 is not identified as a link to Inverness as part of a strategic connection network.

Other comments considered how the environmental impact of road travel could be managed. They included that:

• To complement existing physical connections, smart solutions, local mobility hubs, shared transport, demand responsive transport and active travel networks will help people to access services and employment and make low-carbon local living a more viable option.
• The provision of charging points in locations in this area will be determined by levels of utilisation and points of connection to the grid. If the minimum requirements are not present, delivery of this part of the action will not be possible. This requires further investigation to ensure that this part of the action has some possibility of success.

Other issues

Other issues raised about this strategic action included:

• Oban Airport should be identified as a hub for island communities given it serves the islands of Colonsay, Coll, Tiree and Islay.
• Wick John O'Groats Airport and the Broadford Airstrip on Skye perhaps provide opportunities for future service connections.
• Timber movement by sea is a major issue in rural areas.
• The planned space port in Sutherland is referenced but is not in the Northern revitalisation action area as it is currently drawn.

North east transition

This area broadly includes Aberdeen City and Aberdeenshire with links through Moray towards Inverness, and south towards the Tay estuary.

Question 12 – Do you agree with this summary of challenges and opportunities for this action area?

Around 165 respondents made a comment at one or both of Questions 12 and 13.

Overall focus on the action area

A general observation was that the North east action area is very much focused on the energy transition, but that there is much more to this region, and this should be recognised.

It was noted, for example, that NPF3 acknowledged the importance of life and medical sciences, food and drink and tourism. It was also reported that the investment by the UK Government and the Scottish Government in the Aberdeen City Region Deal reflects this focus on diversification. The importance of agriculture as a key industry was also highlighted, both in terms of the proportion of the labour force working in agriculture, but also how it is embedded in heritage, culture and the landscape.

Connected to the concern that this action area is overly focused on the energy transition was a view that there is a lack of ambition, vision and understanding of the region. It was suggested, for example, that the diagram appears to represent the North east as a place that you pass through or pass by, rather than having its own opportunities and challenges.

In terms of the energy focus, it was noted that a just transition relates to every sector of the economy, and it was suggested that there are missed opportunities to look at agriculture and to consider remanufacturing and the wider circular economy as being a significant part of the future industry for the area.

Another focus that was thought to be missing was the value of natural capital within the area. It was noted that the north-east region is characterised by its rivers, a varied coastline and wildlife, and it was suggested that these factors could also be acknowledged. There was specific reference to the restoration of the degraded habitats, such as the North east lowland peatlands, and a more general call for the use of nature-based solutions.

Relationship to other action areas

As at Questions 8 and 10, it was suggested that the North west, Northern and North east action areas have similar challenges and opportunities and require similar strategic actions to ensure they will deliver resilient, robust local communities.

In relation to which areas are included in the North east action area, there was a query as to whether the City of Inverness is within its scope. It was also noted that Elgin is referenced within this area, but also in the Northern revitalisation action area.

Areas or routes to be referenced

Respondents identified a number of locations, infrastructure elements or projects they wanted to see covered, or given greater coverage. In terms of wider areas, these included that:

• There is no clear reference to the important contribution Angus can make to the transition to net zero through green energy choices. This includes the Mercury Programme, as part of Tay Cities, delivering investment to support growth industries/renewable energy developments including offshore wind, the wider hydrogen network and other opportunities connected with Zero Four, Montrose Port and Brechin.
• Moray barely features in this section with the text dominated overwhelmingly by Aberdeen and Aberdeenshire.

Respondents also highlighted current or potential transport infrastructure that they wanted to see referenced or given greater prominence. This included:

• Strategic maritime routes from Peterhead. The international sea connections from Lerwick towards Scandinavia and further north.
• Lifeline ferry connections between Aberdeen, Orkney and Shetland.
• Strategic rail opportunities, including new rail routes across the North East or Scotland in general.
• Aberdeen Rapid Transit. Current references were welcomed, but there was a call for more tangible support given that, as Scotland's third largest city, it is evident that Aberdeen needs a rapid transit system of scale.
• Aberdeen International Airport, which supports the global offshore energy sector through direct connections to both energy cities and international hub airports.
• The transport corridor from Inverness, through Moray, to Aberdeen and the upgrading of the A96 and A95.
• Bridge infrastructure in the area, which was described as one of the biggest connectivity challenges facing Aberdeenshire Council.

A general concern was that this area has received inadequate transport infrastructure investment over the long term, and that based on the draft version of this action area, this lack of investment looks set to continue.

Projects or opportunities to be referenced

In terms of existing facilities or projects there was reference to:

• Strategic transmission opportunities from Peterhead to Norway and Hull, such as North Connect.
• The role of Buckie Harbour in servicing offshore wind farms.
• The role and potential at Blackhillock sub-station.

There was also reference to the Port of Aberdeen not being included as a 'green transition zone' and to there being minimal reference to potential future strategic maritime connections, such as those which could be offered when Aberdeen Harbour South has been completed. Aberdeen Harbour is covered further at the next question.

Respondents also highlighted a number of potential projects or opportunities that could be covered. These included:

• That the Fraserburgh Masterplan could support all of the strategic actions for the North east action area, for example through increasing capacity for operations and maintenance of the windfarm infrastructure, and through the potential to return added value from the larger vessels in Scotland's fishing fleet that are currently going overseas.
• Making customs sites more important in a post-Brexit scenario. It was reported that the Port of Aberdeen, Peterhead Port and Aberdeen International Airport are responding to the call by the UK Government and Scottish Government for two Green Freeports in Scotland.
• Opportunities associated with Aberdeen Airport around decarbonising aviation and for the North East to be a centre for sustainable aviation fuel.

Energy-related projects

Although some thought that the energy transition is overly prominent in this action area, there were also suggestions for renewable-related opportunities that should be referenced or given greater coverage. These included:

• The spatial aspects of offshore wind development.
• The opportunity presented by ScotWind Leasing and INTOG. It was suggested that there should be reference to the infrastructure needs and supply chain opportunities.
• Bridging technologies, such as Carbon Capture and Storage (CCS).

It was also noted that the Energetica Corridor sustainable development zone has not been referenced, and there was a query as to whether it is still considered to be one of the major opportunities for the area.

Other themes to be covered

In terms of other themes that respondents wanted to see covered, the following were suggested:

• The biodiversity agenda. It was noted that the area includes many existing wild spaces, including parts of the Cairngorms National Park, and it was suggested that a section reflecting this would be an obvious addition.
• Housing and service responses to the area's demographic profile. It was noted that the retired population of Aberdeenshire could grow by 43% by 2043, and it was suggested that the action area would benefit from some specifics around homes and other services for this demographic.
• The important role of arable farming in relation to local food security.
• The roll out of the crofting tenure.
• Small-scale shellfish-related aquaculture opportunities.
• The importance of commercial timber production and processing.

Question 13 – What are your views on these strategic actions for this action area?

Four strategic actions were included for the North east transition action area.

9. Transition to net zero

General comments about this strategic action included that it is applicable to the whole of Scotland. In terms of how it is currently focused, concerns included that:

• It is too heavily focused on Aberdeen and the Aberdeen Harbour national development proposal. There was a call for the action to reflect the potential of the entire north-eastern coastline, especially the existing assets and potential developments within the Moray and Cromarty Firths.
• There is a lack of detail outlining how the region will transition from oil and gas to renewable energy. There needs to be a clear strategy for how a just transition will be achieved, giving time to allow new industries to establish and provide a seamless transition.

It was suggested that the economic strategy needs to be focused on facilitating change within businesses. There was a concern, however, that while much of the supply chain will be able to transition, the oil and gas industry is incentivised towards not meeting climate commitments or achieving a just transition. As an example, it was reported that the Energy Transition Fund primarily supports reduced cost levels by reducing the number of fossil fuel-related jobs through technical innovation. Instead, there was a call for the focus to be on new non-carbon-based industries replacing the existing fossil fuel industries, rather than a transformation of those industries to being 'net zero'.

Greener energy choices

Please note that issues associated with greener energy choices are discussed in greater detail under the analysis relating to Policy 19 (Green energy).

A number of comments related to the commentary on greener energy choices. They included that to avoid ambiguity the term 'green hydrogen' should be used when referencing hydrogen produced using energy from renewable sources, such as wind power, via electrolysis. One perspective, however, was that hydrogen is a potential liability and that the suggested need for a hydrogen network would depend on a currently non-existent renewables-to-green-hydrogen strategy.

It was also suggested that the pursuit of blue hydrogen runs counter to the climate goals, and that embedding it in NPF4 for the long term is unacceptable.

If support is being given to blue hydrogen production with CCS, there was a call for this to be made clear.

Other comments also focused on CCS or Carbon capture, utilisation and storage (CCUS). It was suggested that the role of CCUS as a decarbonising technology in the North east action area should be set out explicitly. Further comments included that CCUS is a necessity, not an option, when it comes to decarbonising the economy and reaching net zero. It was also reported that deployment of CCUS can deliver significant socio-economic benefits, protecting and creating jobs and providing opportunities for the establishment of new supply chains.

Other greener energy-related comments included:

• The opportunity presented by offshore wind could be expanded on. A number of ScotWind sites are located off the coast of this action area, presenting a particular infrastructure need and supply chain opportunity.
• Only hydrogen and offshore wind are mentioned in this section, with no reference given to the new, repowered or extended onshore wind projects.
• The very significant role that solar photovoltaic generation will play in the Scottish energy transition is not recognised.

Ports and harbours

General comments included that ports all along the east coast can capitalise on the opportunities that will be presented by ScotWind Leasing, particularly in relation to operation and maintenance. It was suggested that NPF4 could include recognition of this potential, and outline the need for infrastructure improvements for east coast ports so that they are able to take advantage of the ScotWInd opportunity.

There were also a small number of very detailed comments relating to Aberdeen Harbour. Aberdeen Harbour is covered in further detail in the section covering national developments, but in summary points raised included that:

• The North East is a centre for the skills and expertise needed to meet Scottish climate change commitments. However, there are future risks and economic challenges if those skills and expertise are lost. Allocating and delivering the ambitions of Port of Aberdeen South and North Harbour and the Energy Transition Zone (ETZ) is time sensitive and needs focused, detailed and aligned policy at a national and local level to secure delivery.
• The recognition of potential environmental impacts arising from relocation of the harbour and new construction was welcomed by some, but it was suggested that the reference be strengthened to ensure the mitigation hierarchy is followed, as currently the implication is that impacts will just be mitigated to an acceptable level.

Other themes

Other themes that respondents wished to see covered, or given greater prominence, under this strategic action included:

• Nature recovery and natural capital. It was suggested that there is currently an infrastructure focus, but that the solutions to the nature crisis are also solutions to the climate crisis. Protecting and restoring natural habitats, peatland, rivers, grassland and native woodland needs to be a given prominence.
• Community empowerment. It was suggested that meaningful opportunities for community wealth building through community empowerment should be prioritised.
• The identification of skills gaps and opportunities to meet them. It was suggested that a partnership approach involving business, industry and education sectors will be crucial to meeting those needs. Opportunities to work with universities (including the University of the Highlands and Islands) to deliver targeted programmes of learning and vocational 'green jobs' courses should be explored.
• The material requirements of the energy transition, particularly the offshore renewable plans in this area. It was suggested that there is an opportunity to keep the high quality material from the decommissioning of oil and gas rigs in the area, and to use it to build the next generation of energy infrastructure.

10. Improve local liveability

Car dependency and growth

There was a concern that the reasons for high car ownership across this action area have been misunderstood. It was noted that a large percentage of the population live within the numerous small to medium size towns to the north and south of Aberdeen and along the Moray Firth Coast, and that they regularly commute between Inverness and Aberdeen for work, leisure and to access goods and services. An associated concern was that the national development proposal to establish an 'Aberdeen Mass Urban Transport' extending to just the city limit, is unlikely to reduce travel along the north-east corridor.

It was also noted that the examples of new communities mentioned (Chapelton, Grandhome and Countesswells) are greenfield developments that have required significant new infrastructure and generated further car travel. There was also a concern that there is a tension between the wider NPF4 policy aspiration for compact growth around cities and the proposed growth corridors in this action area. It was suggested that the expansion of these areas, while maintaining settlement character and identity, will be challenging and that collaboration with all stakeholders will be needed to ensure that successful places are delivered.

20-minute neighbourhoods and compact growth

There was a concern that 20-minute neighbourhoods are given too great an emphasis for an area which is mostly rural. Others saw the potential to limit sporadic growth and promote active travel. They noted that it will be important to understand how 20-minute neighbourhoods can be applied in a predominately rural setting. In terms of issues to be considered there was reference to:

• Assessment of the type of services that would be utilised on a regular basis, and which would bring the community together.
• Challenges associated with community facilities and services already experiencing capacity issues.
• A decline on the high street. It was suggested that we will need to look closely at our current town and city centres and adapt approaches to meet current and future needs, demands and consumer habits.

In terms of the type of development required, it was noted that higher density development on brownfield land is one option for delivering housing growth. However, it was also suggested that this needs to be balanced against a blended approach which includes greenfield release. There was a particular concern that depending on brownfield sites to deliver urban growth will exacerbate the area's housing crisis.

Water supplies

There was a request for clarification around new water supply, including how and when work will be undertaken, and how it will be funded. It was suggested that significant investment in public water supplies is required, and also that strategic actions are needed to address the resilience of private water supplies in the area, and particularly in rural Aberdeenshire.

It was considered important that any new water systems are designed to be net zero, climate resilient and to contribute to wider placemaking, circular economy and blue-green network solutions. It was also suggested that linking new water supply and waste-water systems to the further development of natural, zero carbon waste-water treatment technology could link jobs to local liveability, through an integrated systems approach.

11. Regenerate coastal communities

Comments included that this strategic action ties in directly with the City Region Deal priorities, Aberdeenshire Council's regeneration strategy and Local Outcome Improvement Plans. It was suggested that NPF4 should acknowledge that this is a continuing focus rather than a new strand.

In taking this strategic action forward it was seen as important to:

• Acknowledge the coastal vulnerabilities to climate impacts, risks of coastal erosion, coastal inundation and storm surge, and the need for shoreline management.
• Acknowledge that the delivery of homes and infrastructure in these areas can be problematic and cannot be left solely to the market to deliver.
• Further recognise the importance of the fishing industry to the strong sense of place, heritage, and community. It was suggested that support for the fishing industry has the potential to attract significant inward investment as well as lead to job creation.
• Emphasise quality of place and the potential of green tourism. Given the opportunities for attracting tourists to the North East, it was seen as important to identify and plan for sustainable visitor infrastructure and incorporate tourism into the regeneration of coastal communities.
• Reference and support the transition of the MOD land at Fort George to non-military use, and commit appropriate public sector investment to ensure a coordinated and sustainable new use is developed and delivered for this site.

12. Decarbonise connectivity

General comments included that this strategic action reflects the RTS. However, there was also a concern that the described approach lacks an understanding of the scale of the climate crisis, as well as imagination regarding solutions. In terms of the solutions required there was reference to:

• A systems approach being required, but as yet being absent.
• The need for a strong modal shift to electrified rail.
• Improvements to active travel and public transport connectivity, with NPF4 providing more detail and clarity on how these are to be delivered.
• Opportunities relating to low emission vehicles, including greater provision of e-vehicle charging facilities and the associated infrastructure.

Other themes or issues that respondents raised included:

• There is no mention of the importance of Inverness Airport, which acts as a lifeline route to the isles, especially for access to health care and the courts system. The innovation work it is doing around new sustainable aircraft design should also be acknowledged.
• In terms of actions to improve journey times and capacity between Aberdeen and the Central Belt, it is important not to lose sight of the needs and demands of intermediate stations along the network.
• The Central urban transformation action area recognises that the development of ports on the east coast will need to take account of the potential for a substantial increase in freight and passenger traffic between Scotland and continental Europe. The potential of Peterhead should also be recognised.

Additional actions required

In addition to the four strategic actions set out, it was suggested that there should be a further action around creating a balanced and sustainable rural population.

There was also a concern that Central urban's Action 14 – Reinvent and Future Proof City Centres – does not appear to be considered applicable to Aberdeen. This was considered to be unacceptable. It was also noted that all reference to the important role of cities and city centre regeneration is located within the Central urban action area but that, as Scotland's third city, the role of the city of Aberdeen must also be recognised. There were similar but more area-wide concerns regarding the applicability of many of the Central urban strategic actions to the North east action area. An example given was the importance of strengthening connections to the rest of the UK through high speed rail connectivity.

Central urban transformation

This area broadly covers central Scotland from the Glasgow city region and the Ayrshires in the west to Edinburgh city region in the east, including the Tay cities, the Forth Valley and Loch Lomond and the Trossachs National Park.

Question 14 – Do you agree with this summary of challenges and opportunities for this action area?

Around 260 respondents commented at one or both of Questions 14 and 15.

Size and diversity of the Central urban transformation area

Although there were some broad statements of support, a number of respondents raised concerns about either the size of this action area, or the diversity of the communities and places that it covers.

In terms of size, there was a view that the Central urban action area is far too wide in its geographical spread to effectively deliver on its aims. It was noted that the area covers a significant part of Scotland, particularly in terms of population, but is also a very diverse area. It was described as an area of great contrasts: from Scotland's two largest cities, Glasgow and Edinburgh, to the Loch Lomond and the Trossachs National Park and all scales of urbanisation in between.

The associated concern was that the high level and very summarised description of such a large and populated area oversimplifies the land use challenges and opportunities facing the myriad different areas. Particular aspects of this diversity that were highlighted included that a large proportion of the area is not, in fact, urban with a number of rural towns and villages and suburban areas. Other comments included that:

• The Edinburgh and Glasgow regions dominate the content of this section, with much less detail provided for areas such as Ayrshire and Fife.
• Glasgow and Edinburgh are also very different cities, and a single strategy is therefore potentially inappropriate.

There was a particular concern that there is a strong urban focus, and that the challenges and opportunities identified, and consequently the strategic actions, are not relevant to the significant rural population, including in Perth and Kinross, Stirling, Fife, and Argyll and Bute. It was suggested that for some areas, such as the Clyde Islands and south of Argyll and Bute, their challenges and opportunities have more in common with the rest of the Highlands and Islands.

Solutions to the size and diversity challenge

Solutions proposed included that NPF4 could:

• Reflect the individual Indicative Regional Spatial Strategy geographies, identifying the key strengths, challenges and opportunities of each area and how they can support the delivery of the overall Central urban aims. It was suggested that this approach would also provide greater alignment between the NPF4 and future Regional Spatial Strategies.
• Divide the action area into a number of smaller areas. Specifically, it was suggested that the area should be split into separate action areas, aligned with the Indicative Regional Spatial Strategy geographies. It was noted that this would also allow greater alignment with other regional and sub-regional strategies.

There was also a suggestion that the action area itself, and two of the strategic actions (Accelerate urban greening and Rediscover urban coasts and waterfronts) should be re-titled to better reflect the fact that they relate to Central Scotland and not specifically to urban areas.

In terms of specific areas, there were concerns as to how well East Ayrshire, and its rural areas in particular, fits into the Central urban action area. It was suggested that the majority, or at least the southern part of East Ayrshire, would be better represented within the Southern sustainability action area. It was also seen as more sensible for Argyll and Bute, together with the North Ayrshire islands of Arran and Cumbrae, to fall within the North and west action area.

Areas and strategic plans or relationships requiring greater coverage

There were a number of references to areas or strategic plans or relationships that should be covered, or afforded greater emphasis, under this action area. These included:

• The Forth Valley Region. It was suggested that the relationships that the Indicative Regional Spatial Strategy tried to foster have been lost, and that NPF4 does not reflect Forth Valley's more polycentric character.
• Ayrshire as a whole. It was noted that the substantial and costly infrastructure issues surrounding Ayr, Prestwick and Troon are not referenced, and that these will affect the deliverability of the Ayrshire Growth Deal. There was a concern that, if NPF4 does not recognise and address this issue, Ayrshire will be significantly disadvantaged compared to other parts of the Central urban action area.
• The Tay Estuary. It was reported that the Estuary has been recognised as a national asset. It was also suggested that when recognising the importance of the Tay Estuary, other strategic, regionally significant developments are important. There was reference to the James Hutton Institute Innovation Hub, Montrose Port, Eden Campus Energy Centre, Electric A9, Perth–The Biodiversity Capital of Scotland, and Perth Smart Energy City Programme.
• The Helensburgh and Lomond area of Argyll and Bute, particularly in relation to the off-site infrastructure and connectivity requirements necessary to support the largest single-site employment location in Scotland. This was connected to the development of HMNB Clyde, which was described as providing both significant challenges and opportunities.
• West Dunbartonshire. It was noted that limited specific reference is made to the significant opportunities and potential that exist within the area. Examples given included plans for Clydebank, Dumbarton and Alexandria town centres, the regeneration opportunity at Queens Quay, Clydebank and the plans for Esso Bowling and Carless, Old Kilpatrick.

It was also noted that the geographic description of Central urban omits reference to the area's coastline. This was described as a serious omission, since the Central Belt's coastline has been at the heart of Scotland's mercantile trade, industry, and global connectivity for centuries, continues to hold this position, and will be key to the future.

In terms of strategic relationships or plans that need to be acknowledged there was reference to:

• The Ayrshire Growth Deal, which is looking to realise Ayrshire's potential as a world-class business region for aerospace and space, energy, tourism, manufacturing, engineering industries, the blue economy, and nuclear decommissioning. It was suggested that, while the Ayrshire Growth Deal is referenced in the draft NPF, its key outputs and ambitions are not sufficiently developed or articulated, and there is limited or no reference to key regional projects.
• The relationship between the Scottish Borders and the Edinburgh City Region, including Scottish Borders Council's role in contributing to the delivery of the Regional Prosperity Framework.
• The need for closer partnership, as demonstrated by the Metropolitan Glasgow Strategic Drainage Partnership and the Edinburgh and Lothians Strategic Drainage Partnership.

Places or projects requiring greater coverage

Places or projects that respondents wanted referenced, or given greater coverage, included:

• The ports on the Firths of Tay and Forth. It was reported that these ports perform a key role in the country's infrastructure and will be a significant contributor towards the delivery of net zero 2045. With specific reference to Montrose Port, it was reported that it is playing a major role in Britain's East Coast energy cluster, and is strongly related to delivering key strategic actions in the North east action area.
• The CoRE project, located in Cumnock.
• A planned Marine Centre at Ardrossan.
• The aerospace and space cluster around Prestwick Airport.
• The Ayrshire Engineering Park and Ayrshire Manufacturing Investment Corridor projects.
• The digital and advanced manufacturing cluster at i3.

Changes of focus or emphasis required

In addition to concerns that areas or places have not received sufficient coverage, there were also concerns about some of the coverage that has been included.

For example, it was suggested that the opening paragraphs which contrast the Glasgow and Edinburgh city regions need to be revised. The challenges facing the Glasgow City Region were not denied, but the contrast between these city regions was said to be not as pronounced as described.

The suggestion that it can be more challenging to encourage the market to deliver new homes towards the west was said to be incorrect. It was also reported that developers operating in the west of the Central Belt area are extremely concerned by the low housing numbers being forecast for the next ten years in the Clydeplan area. It was suggested that there is a clear disconnect between the numbers as currently forecast versus real demand for new homes. In summary, there was a call for a more balanced presentation of the Glasgow City Region's potential as a place for future growth, innovation, and investment.

It was also suggested that there is no explanation in spatial or geo-political terms of the emphasis on the Edinburgh City Region for population growth and enhanced development proposals, especially relating to housebuilding.

Greener and sustainable places

A number of respondents commented on the ambition to create more inclusive, greener and sustainable places, including by suggesting themes that could or should be highlighted. These included that:

• The area's landscapes and natural heritage should be recognised more strongly.
• References to the need and opportunity for nature-based solutions should be strengthened.
• Alongside mitigation, the need for adaptation and resilience should be recognised.
• The references to green areas, natural space, nature restoration and landscape-scale opportunities should be supported by an indication of scale, planned delivery mechanisms and timescales.
• Where catchment scales and regional approaches are needed to address the nature and climate emergencies, including regional nature networks and climate and coastal adaptation, this should be highlighted.
• Key actions should include decarbonising existing industry and providing the infrastructure to draw in industries that have traditionally been high emission.

A more general concern was that the focus is disappointingly on grey infrastructure rather than green and blue infrastructure, and that there should be a much stronger steer towards sustainable riparian, wetland and coastal management in response to the challenge of flooding.

It was also suggested that sea level rise needs to be considered as a strategic land use constraint. It was noted that the recent Intergovernmental Panel on Climate Change (IPCC) report has suggested that it is now a matter of when, not if, sea levels will rise. It was suggested that this needs to featuring as a major land use challenge including, for example, in relation to the development of Edinburgh's Waterfront.

In terms of solutions to flooding challenges, it was suggested that a catchment-scale approach, using nature-based solutions, can provide benefits for the health and quality of life of Scotland's urban communities, particularly where solutions seek to deliver multiple benefits, including biodiversity gain and active travel routes. It was reported that this approach can also be more cost-effective than hard engineering solutions and can create lasting jobs.

However, it was also reported that nature-based solutions will not address the severe and long-standing fluvial flooding issues that affect this part of Scotland, and which will require different solutions, some of which will need to be 'hard engineered'. The connection was made to the role that the substantial vacant and derelict land assets in this part of Scotland can play in flood alleviation.

Other themes requiring greater emphasis

Respondents also identified a number of other themes or issues that they saw as relevant to the Central urban action area. Infrastructure and travel-related comments included:

• The opportunities for the action area should include ensuring that essential infrastructure is delivered so as to facilitate the other aspirations.
• The SEStran Strategic Active Travel Network should be referenced, as it has a key regional role to play within the National Walking, Cycling and Wheeling Network (NWCWN) national development.
• There should be a focus on public transport, which has an important role to play in connecting communities and opening up access to jobs, education and social activities.
• There is a need for national level active travel freeways, with strategic status on a par with motorways and trunk roads, linking the settlements from Tayside through the Forth Valley to the west coast settlements.

Other comments and suggestions included that there should be a focus on:

• Positive health outcomes for all. The commitment to tackling poor health outcomes in west central Scotland was welcomed, but there was a query as to why such a commitment should not apply across the Central urban area, or indeed the rest of Scotland.
• Communities in pockets of deprivation, and that are often coalfield communities. There was reference to communities in Fife, Lanarkshire, West Lothian, Mid Lothian and East Lothian. It was acknowledged that there is reference to progress in restoring and reusing areas which were historically a focus for heavy industry and mining, but it was also suggested that there is a long way to go.
• The role of town centres, both urban and rural, as an important element of regional relationships. The value of having a strong network of towns that are multi-functional, and are closely linked to their landscape setting and natural and cultural heritage, was described as regionally significant, including from a tourism perspective. The importance of maintenance and repair, and the need to ensure existing places are fit for purpose and resilient, were highlighted. It was suggested that keeping our buildings and neighbourhoods in reasonable condition should be a firm objective of NPF4.
• The role of the established tourism industry and its future potential, including in coastal areas of central Scotland. It was suggested that, while the draft NPF acknowledges the potential of urban coasts, the accessible urban fringe coasts and rural coastlines are all but ignored. It was noted that the tourism industry is a key component to local economies and job growth in such areas.
• Renewable energy generation, heating, or transportation. Given its scale and success as both an energy park and destination, it was suggested that Whitelee Windfarm should be referenced. It was described as disappointing that the Central urban action area does not set out any priorities related to renewable energy development, or the repowering of strategic-scale onshore windfarms.
• Energy security, including by placing a greater emphasis of integration of Passivhaus standards in all housing developments, and through the development of heat networks.
• Reskilling and green jobs linked to low carbon energy technology installation, peatland restoration, natural flood risk management, tackling the biodiversity crisis, and afforestation.
• Food security and food deserts. It was suggested that this will be a significant issue over the lifetime of NPF4, and that it may be appropriate to look at a ban on using prime agricultural land for development.

Question 15 – What are your views on these strategic actions for this action area?

Nine strategic actions were included for the Central urban transformation action area.

In addition to comments on the particular strategic actions, there were also some general observations about the package of strategic actions. They included that they are in line with Indicative Regional Spatial Strategies, or that the strategic actions will provide a focus for the formation of the next LDPs, as well as Regional Spatial Strategies.

However, there were also questions as to whether all of the strategic actions will be relevant to all of the areas falling under Central urban. There was also a concern that there is too much reliance on action at development proposal stage, rather than adopting a plan-led approach. An associated recommendation was to rework the proposals to align with Policy 1 (Plan-led approach to sustainable development) and a 'plan-led system'. There was also a call for greater involvement of local residents.

It was noted that realising a number of the strategic actions will require a regional and catchment-scale approach and that the role of the Regional Spatial Strategies, to spatially coordinate activities and guide delivery at scale and across authority boundaries, will be key. It was suggested that this is currently underplayed and that the Regional Spatial Strategy groupings could be shown in NPF4 and a clearer outline of their status and importance provided.

There was a concern, however, that due to the lack of delivery detail there is no apparent link between the aims of the strategic actions and their subsequent implementation. Also in relation to delivery, it was reported that the strategic actions can only be delivered if additional resources from Scottish Government are made available. There was also a call for the establishment of a national delivery vehicle.

13. Pioneer low-carbon, resilient urban living

Deliverability

The reality of creating low-carbon, resilient living in existing settlements and communities was one issue raised. There was a concern that there is insufficient recognition of established patterns of physical, transit, economic, natural, and social development, along with the scale of the challenge. It was also reported that effecting the change envisaged will require actions that are outwith the influence of the land use planning system. In terms of specific challenges, an example given was that retrofitting infrastructure to improve active travel connections depends on the availability of space, and the strength of LDPs to challenge and refuse inappropriate development.

In terms of possible solutions, it was suggested that a culture change and new approach to considering these areas will be required, as well as significant investment in both resources and infrastructure to make it happen. It was seen as important that the planning system supports a shift to more balanced development where the mix of economic, social, and environmental assets in an area support one another.

20-minute neighbourhoods

In terms of opportunities, it was suggested that the Central urban action area will be able to deliver on a network of 20-minute neighbourhoods, perhaps more so than any other action area. It was noted, for example, that many areas in Clackmannanshire already benefit from the principles of 20-minute neighbourhoods thanks to the way they evolved. However, it was also noted that some of these areas may need retrofitting of certain services.

Although one perspective was that Central urban has the benefit of physical and human scale to support more sustainable approaches to development, living and travel than other areas, there were concerns that this does not apply across the whole action area. As at other questions, its appropriateness to more rural areas was queried, and it was suggested that, while particularly applicable to Central urban, this reflects the current urban focus of the action area.

Travel, including active travel

Connected to 20-minute neighbourhoods was a concern that, while active travel is mentioned specifically, consideration of public transport is missing. It was seen as important to recognise that not all 20-minute neighbourhoods will have all the facilities, employment, education, and services that locals need. To access these and link with friends and family, people will need to travel between 20-minute neighbourhoods, distances often out of cycling or walking range. It was suggested that this is when sustainable public transport comes in, and that travel hubs and bus prioritisation options will play a key role making sure that active travel and public transport are seamlessly linked.

In relation to active travel networks, it was suggested that the Central urban action area presents an opportunity to deliver at a wider scale, improving and extending access to country parks and National Parks, including through connections to public transport.

However, it was also reported that there remain areas, particularly outwith the cities, where the car often remains by far the most convenient, and in some instances, the only practical way of getting about. It was also noted that promoting active travel has been in planning policy for several years and yet car dominated developments are still being built. It was suggested that a fundamental re-think is required to move away from this.

Other issues

Other issues raised in connection with pioneering low-carbon, resilient urban living included:

• It is also important that the need for economic growth and job creation is acknowledged in Scotland in a broad sense, including that not all job opportunities created will be classified as 'green'.
• Investment in heat networks, energy storage and the circular economy could have positive impacts on reducing fuel poverty if done effectively. Former coalfield communities should be prioritised because they are impacted by transport poverty, rural poverty because of their location, and by the lack of choice of power supply, often being off-mains.
• The Scottish government should amend Building Standards to ensure developers primary choice is contracting full fibre in all new build properties in in this region and beyond. It was reported that better connectivity is vital to the future creation of the 20-minute neighbourhoods mentioned.

14. Reinvent and future proof city centres

The scale of the challenge associated with reinventing and future proofing city centres was acknowledged, but there was a concern that by grouping the cities and large towns together the vision and ambition may get clouded and diluted. However, advantages were also identified, including that there is great benefit in considering investment in infrastructure at this geography, including by benefiting the investment plans of infrastructure providers.

In terms of particular cities, or parts of cities, the following points were made:

• Perth. Ongoing and important work to deliver local heat and energy networks for the city, and to make Perth the 'Biodiversity Capital of Scotland', should be referenced.
• Glasgow. There should be reference to doubling the Glasgow City Centre population and transitioning the city centre into a viable and liveable neighbourhood.
• Leith Docks. There was a concern that the reference to 'industrial and cultural heritage' undermines the Dock's continued operation and contribution to the Scotland's infrastructure. The port-related development at the Port of Leith, to support the climate change emergency, must not be undermined by placing an over-emphasis on the City's heritage.
• Aberdeen City. There was a concern, as referenced above, that Action 14 does not appear to be applicable to Aberdeen, but only to cities in the Central Belt. This was considered unacceptable.

Towns

A number of respondents commented that, while the need to support our city centres is recognised, this action should also embrace town centres. Further points included that town centres:

• Face challenges that are nationally significant in scale when aggregated.
• Are arguably less resilient, their long-term viability more under threat, and investment more difficult to attract, than as this case for cities.
• Are vital to the promotion of 20-minute neighbourhoods.

It was also noted that towns, and particularly larger towns, can be significant economic drivers and the focus of large communities, as well as being of historic and cultural value.

Other issues

Infrastructure issues raised in connection with reinventing and future proofing city centres included that:

• By weaving blue and green infrastructure into our city centres we can make them more resilient to cloudbursts and flooding, whilst improving health and wellbeing and nature recovery.
• NPF4 provides an opportunity to focus on wellbeing employers and the importance of providing facilities and greenspace for workers to be healthy and active during the working day.
• Mass transit options have an important role to play in any city transformation plan.
• Broadband connectivity, and the associated installation and maintenance access requirements for previously vacant buildings, should be a key consideration for future urban regeneration.
• Consideration should be given to the opportunities for using abandoned coal mines in heating.

Other issues raised in connection with reinventing and future proofing city centres included:

• This action underplays the wider green belt and its ability to guide development into the urban area. Reference should be made to the role of the green belt in a city region context.
• It would strengthen plans if the roles of culture and creative organisations were fully considered. The role of culture in reinventing and future proofing city centres is varied, and includes providing both workspaces and performance areas, as well as places for communities and visitors to participate in creative activity.

15. Accelerate urban greening

There was support for the aim of urban greening, and its use to restore biodiversity in the urban realm, but also questions about the type of natural solutions being proposed. There was disappointment that the strategic action does not recognise, and give policy support for, significant investment in green and blue infrastructure or the need to take a proactive and transformational approach to coastal flood management.

In terms of the types of solutions respondents wished to see, suggestions included that true urban wild spaces will be important in addition to park space, albeit the latter remains important. It was also noted that greenspaces and infrastructure can support the wellbeing economy by providing areas for allotments, orchards, bee keeping and community growing which can link into an integrated food and growing system, as well as space for learning outdoors.

It was agreed that delivering this strategic action will require a change in approach and mindset across all stakeholders to recognise the potential opportunities. Other delivery-related comments included that:

• Planning authorities will need all stakeholders playing their part, as well as strong support from the Scottish Government, to ensure developers sign up to this agenda, understand the benefits to be realised and deliver.
• As with the other actions, significant investment in both resources and infrastructure will be necessary.
• Large-scale investment across a wide range of public sector agencies does not always result in empowered, informed and involved communities. Effective delivery mechanisms need to be established to deliver transformational change.

Finally, there was a request that the reference to the work of the Inner Forth Futures Partnership be changed to more accurately describe the role of the partnership in urban greening.

16. Rediscover urban coasts and waterfronts

General comments included that there needs to be some acknowledgement of climate change implications for urban coasts and waterfronts, including sea level rise and storm surges, along with the resources that will be available to either mitigate these or manage the consequences of not doing so.

Ports

A number of the other comments on this strategic action were focused on ports. They included that. although the role of ports around delivery of the net zero target is considered, there is little about their wider role.

In terms of issues that could be referenced, the continued need for freight handling capacity was highlighted. It was reported that recent global events, including COVID, Brexit and Russia's invasion of Ukraine, have all put pressure on established port infrastructure, with ports experiencing an increase in demand for their services. It was suggested that we must have a resilient port network, capable of accommodating the swift handling and management of cargoes, and sufficient land to support operations.

In relation to specific ports, the following points were made:

• Clyde Mission. The Clyde Mission could be linked to Govan Riverside Innovation District, River Park and other City Deal funded projects like the quay walls.
• Port of Leith. The section should set out the nature of operations at the Port of Leith, and that a master planned approach to the development of Edinburgh's Waterfront not only can, but should, take into account opportunities to facilitate the offshore energy sector and modern port operation requirements.
• Grangemouth. It was noted that opportunities for hydrogen production and CCS are referenced. This was a concern for some, including because of a view that we cannot rely on Negative Emission Technologies to meet our climate commitments. Others welcomed the reference and suggested that there are much wider applications of CCS at the site than just bioenergy hydrogen production with CCS. It was suggested that there is also the opportunity to put the CO₂ transport infrastructure in place, both to decarbonise existing operations and to support future low carbon manufacturing in the area.
• Cockenzie and Blindwells. It was reported that the area provides the opportunity to deliver environmental improvements that can help to address deprivation, but can also lead to the opportunity for significant investment and employment-generating opportunities. There was a request for the reference to Blindwells to be amended to reflect local planning processes.
• Greenock Ocean Terminal. While the reference to the opportunities for enhanced cruise facilities on the Clyde and for Greenock Ocean Terminal to act as a key gateway was welcomed, it was report that the Ocean Terminal already serves this purpose in the west of Scotland and is set to significantly increase its capacity with a recently installed dedicated berthing key quay and a new visitor terminal/centre in development.

Facilities or themes to be covered

Respondents also highlighted a number of other facilities or themes they wanted to see covered in relation to rediscovering urban coasts and waterfronts. These included that:

• Building on the reference to the strategic location and rail connectivity of Longannet to benefit local communities around this part of the Forth, more detail could be given on the potential for extending the Stirling-Alloa-Fife rail line along the existing route, with opportunities for new stations to serve existing and expanded settlements.
• In addition to referencing regeneration in coastal communities such as Dunoon and Rothesay, it could be noted that Helensburgh provides significant employment opportunities.
• The canal corridors of North Lanarkshire, which run through or adjacent to its urban areas, should be considered as waterfronts under Action 16. There was also reference to the Union Canal.

17. Reuse of land and buildings

Comments about the reuse of land and buildings included that while the emphasis is welcome, reuse has been a national and local planning policy position for decades but turning that policy aspiration into development, and remediating on the ground, has proved difficult in practice.

It was acknowledged that NPF4 notes the benefits of de-risking sites by taking an infrastructure first approach but there was a concern that there is no information of the means that will be made available to assist local authorities in this respect. Another note of caution was that the scale of public investment required to unlock the most problematic sites will remain a challenge and should not be underestimated.

In terms of delivery, further comments or suggestions included that:

• There is significant appetite for community-led regeneration of vacant and derelict land and buildings, and enabling more community-led activity in this area strongly aligns with the spatial principles set out in NPF4. Communities need practical and financial support to enable their ambitions.
• Planning authorities will need strong and robust enforcement powers for incidences where building and landowners do not comply and where unlawful demolition occurs.
• The aim to 'steer development away' from greenfield is not a strong enough response to the climate emergency. More incentives, investment and direct policy will be needed.
• Depending on their location, vacant and derelict sites may be ideal for providing strategic blue-green infrastructure, while providing high quality local green and blue space. This can unlock wider areas for development, although they must include blue-green infrastructure to keep surface water out of the combined sewer system and to meet future needs.

There was also a query around the intended reach of this strategic action. It was suggested that it reads as if the only vacant and derelict land is within city regions, and therefore it could be assumed that this part only relates to cities.

18. Invest in net zero housing solutions

General comments included that, given the population and densities found in the Central urban action area, the focus of significant investment in net zero housing solutions is key and presents the greatest challenge for this action area.

In terms of meeting the challenge, one broader concern was that, despite acknowledging that there will be a continuing demand for more homes, reuse and adaptation of existing building stock is not headlined as part of the solution.

Existing buildings and retrofitting

Upgrading the existing housing stock to reduce emissions was seen as more testing than meeting the requirement for new homes. It was noted that the existing housing stock will account for the significant majority of homes, but that resources and deliverability are challenging, with issues including but not limited to: market capacity; skills and labour; and availability of new technologies. Issues associated with mixed tenure and mixed-use buildings were also noted, including that they are numerous in parts of the Central urban action area.

There was a call for more clarity on how retrofit is considered in NPF4 and other planning policy. There was specific reference to more detail on planning's role in relation to energy efficiency, sustainable accessibility, zero emissions heating solutions and water management.

In terms of how the upgrading of the housing stock can be taken forward, there was reference to:

• Highlighting the role of fabric first interventions and regular maintenance of buildings.
• No longer referring to retrofitting energy efficiency measures to social housing as innovative, but rather as part of a clear direction of travel for all buildings.

Affordable net zero housing

The importance of affordable new homes was also acknowledged, although there was a query around whether the objective is about more homes being classified as affordable, or that all homes should be more affordable. It was suggested that any definition of affordable should include the cost of the climate emergency-related transitions required up to 2045. It was also suggested that new homes targets must include some indication of the energy resources required.

It was suggested that investing in net zero housing solutions will be a challenge for housebuilders and infrastructure providers and will need a step change in the way housebuilders think about their 'product'. One view was that developers will need persuading of the benefits of more sustainable nature-based solutions and how they can not only contribute to achieving net zero, but also how they can improve the health and wellbeing of a community and make their developments and the surrounding area more attractive.

Connected to this was a view that a minimum standard-based approach will not work, and that to be meaningful any approach will need to consider the whole site and beyond. It was suggested that it should not be possible for agreed natural solutions to be squeezed later down the line to improve profit margins via applications to vary conditions. It was also noted that planning authorities will require the necessary policy support to enforce these features and measures.

With reference to flooding, the recognition that net zero housing solutions require zero emission water management was welcomed, as was the catchment-scale approach. It was suggested that planners will need guidance and technical knowledge to assess how blue-green interventions can be aggregated to deliver a cumulative solution across neighbourhoods, towns and cities.

Developer contributions

A number of respondents commented on the reference to the Edinburgh and South East Scotland City Deal including a commitment from partners to put in place a regional developer contributions framework. Given the diversity of the area, there were questions about how the approach would be achieved in practice. Other queries included:

• How an effective and deliverable approach can be achieved given current approaches to developer contributions as set out in Planning Circular 3/2012?
• Specifically, whether the intended approach is competent within the current section 75 agreement framework?

It was suggested that the development of a framework is out of step with the regional planning system, which no longer has a context to allow such a document to be developed.

Other comments addressed the scale of the cross boundary transport challenges, with comments including that given the level of consented development, a clear understanding of what is reasonable and deliverable in terms of any cross-boundary developer obligations is needed. One view was that, given the scale of new development compared with the transport movements, the impact of such a levy would be minimal and would not address the challenges that all parties are looking to solve.

There was also a specific concern around how the development of a regional development contributions framework would impact on the Scottish Borders' housing market. It was reported that there are real challenges in making sites viable for development and that the consequential impacts of an additional development contribution on their deliverability will be much higher than in other areas.

Groups to consider

Finally, the importance of ensuring that housing solutions, and particularly new developments, are age and disability friendly was highlighted. It was suggested that new homes need to suit the needs of an increasingly ageing and more disabled population, with ground floor living essential for many and stairs often not being manageable. It was also suggested that residents should have access to private or semi-private garden space to be close to nature. It was recognised that this need may challenge plans for densification, but it was suggested that it can be addressed through good design and planning.

19. Grow a wellbeing economy

General comments in relation to growing a wellbeing economy included that there has to be a recognition that providing facilities and employment for a significant population can require the use of locations that are less accessible to some sectors of the population without interventions in the provision of public transport.

It was also suggested that the reference to investment opportunities should better highlight the importance of delivering the City Deals and Regional Growth deals already in place, and should also help to steer potential future deals.

Area references

In relation to projects or plans already referenced, it was suggested that:

• For West Edinburgh, it would be appropriate to add reference to shorter and longer-term timescales, given the Proposed City Plan 2030 applies the approach of higher density, residential-led, mixed use neighbourhoods to its sites.
• It is suggested that the Ayrshire Growth Deal is aligning with Clyde Mission. North Ayrshire is referenced here but is not part of the Clyde Mission. Argyll and Bute, on the other hand, is a key part of the Clyde Mission, working alongside the Glasgow City Deal partners, and needs to be referenced as such given the inclusion of Helensburgh and Dunoon.
• The Ayrshire Growth Deal will play a major part in the growth of a wellbeing economy in East Ayrshire but is only mentioned in passing, and without recognising any of the projects that will be delivered in East Ayrshire.

There were some concerns about the reference to the Ardeer Peninsula and that it is potentially supported as a site for redevelopment of the Ayrshire coast. The area's significant value for biodiversity was highlighted and there was a call for biodiversity to be recognised and protected as part of any future plans. There was also a call for a Strategic Environmental Assessment (SEA) to be carried out ahead of the proposed large-scale development on the peninsula.

In terms of other projects that need to be referenced, or given greater prominence, the following were noted:

• The Stirling and Clackmannanshire City Region Deal should be highlighted, and in particular the investment in Scotland's International Environment Centre, and Clackmannanshire's ongoing commitment to community wealth building in an area with some of the most deprived communities in Scotland. More generally, it was noted that Forth Valley is not referenced.
• The contribution that Renfrewshire makes to the Scottish economy, and the potential opportunities for growth, need to be better reflected. It would be useful if opportunities for growth that exist across all of the action area are identified.

Themes to be covered

Respondents also highlighted additional themes they would like to see covered under this strategic action. They included:

• That the growth of remote and local working, and the creation of hubs, may not be commercially viable in smaller communities. There was a call for creative, joined-up solutions to avoid market failure preventing such service provision.
• The contribution from social enterprises and the voluntary sector in maximising economic, social and environmental wellbeing and providing new models of working.

20. Reimagine development on the urban fringe

Comments included that the title of this strategic action should reference sustainable development.

There were also questions around what is meant by the urban fringe, and a suggestion that it seems to be being confused or conflated with distinctly recognisable rural areas, such as Loch Lomond and the Trossachs National Park. It was also reported that in East Lothian, the urban fringe is largely active and productive agricultural land, and that while some areas across the Central Belt may need reimagining, East Lothian's rural areas do not.

In terms of issues or areas that could be covered, it was noted that Glasgow's local context of housing estates on the urban fringes is not represented in the text. It was reported that they have specific challenges, including lack of fixed and reliable transportation to the urban centre, concentrations of vacant and derelict land, inter-generational community blight, limited learning and employment, poor quality local shopping and community facilities, alongside low market interest for private sector housing.

It was also suggested that consideration should be given to referring to the Clyde Muirshiel Regional Park, which straddles Inverclyde and Renfrewshire and is an important biodiversity asset.

Also in relation to identifying important assets and features for protection, as well as opportunities for enhancement and innovation, it was suggested that landscape capacity studies will have a role to play.

There was also reference to ensuring the relevant active travel infrastructure and connections are in place to provide access and to allow people to continue to access and enjoy these places. A connected point was that while there is reference to rail and active travel, there is no mention of the role that coaches can play in the development of urban fringes, especially around tourism and linking urban dwellers with more rural Scotland.

21. Improve urban accessibility

Comments included that retitling this strategic action to 'Improve urban accessibility and decarbonise connectivity' would be more consistent with net zero and the connectivity actions in other parts of Scotland.

Public transport

A number of the other comments were public transport-related and included that

significant investment will be required to ensure alternatives to the private car are available, not just in Glasgow and Edinburgh, but in the other cities within the Central urban action area. It was noted that this should include a viable and reliable public transport system. Other comments were that:

• It is disappointing to see no reference to bus services. The text does not emphasise the decline in bus ridership and how this might be rectified through future interventions. It was suggested that there should be specific mention of bus prioritisation measures, including around speed and reliability.
• Mass transit developments are welcome but must be completed with a holistic approach, which takes into account the safety of other road users and facilitates the use of active travel as part of journeys by mass transit.
• Rural and island accessibility is also an issue that should be addressed in this action area.

In terms of specific transport links, comments included that:

• Glasgow Metro should be referred to as Clyde Metro and should be seen as an enhancement to, rather than a displacement of, current transport provision. It was suggested that this strategic action should reflect the importance of existing bus, rail and subway provision, alongside the need for enhancements to transport interchanges and infrastructure standards.
• Passenger rail services on the Glasgow and South Western Railway line should be improved, including double tracking, electrification and reopening railway stations such as Hurlford, Mauchline and Cumnock.
• There is no information on how the rail network in Inverclyde could also be strengthened in relation to high speed rail. It was reported that this would offer a reduction in journey times, expanding the attraction of Inverclyde for a range of purposes.

Active travel

The need for continuing investment in active travel infrastructure was also highlighted, along with the importance of the active travel infrastructure being connected to mobility hubs and public transport across the area if communities beyond the cities are to enjoy better connectivity by sustainable means.

A specific suggestion was that more could be done to improve the National Cycle Network to transition more toward a utility-based system and not just leisure.

Road travel

In relation to the road network, comments included that there should be recognition that pinch points in the strategic road network need to be addressed.

With specific reference to improving accessibility from East Ayrshire into the city region, it was reported that improvements to the A77/M77 corridor would be required and improvement of the connections between the M74 and East Ayrshire would help address the area's relative isolation from markets. It was noted that these have been identified as priority projects in the Ayrshire Indicative Regional Spatial Strategy and there was a call for them to be included under this strategic action.

Community wealth building and remote working

It was seen as important that the concept of community wealth building is properly understood and defined within NPF4, in order that it is successfully implemented.

In relation to this strategic action, it was suggested that reducing car use and vehicle emissions is an incidental rather than a core benefit of a community wealth building approach. For example, there was a query around whether the reference to opportunities for longer-term remote working implies that community wealth building approaches would reduce the requirement to commute to higher paid jobs through the creation of local fair work opportunities?

It was also noted that it will not be possible to provide all employment, secondary and further education and many other services and opportunities at a local level. To complement local living, it was seen as important to make sure that there are interventions to address the strategic trips between major centres which make up much of peoples' personal mileage.

In terms of remote working and increased local employment opportunities, it was noted that the roll out of digital infrastructure will be fundamental.

Southern sustainability

This area broadly includes Dumfries and Galloway and the Scottish Borders, with links to the Ayrshires and Glasgow city region in the west and to the Edinburgh city region in the east.

Question 16 – Do you agree with this summary of challenges and opportunities for this action area?

Around 155 respondents commented at one or both of Questions 16 and 17.

Relationship to the Indicative Regional Spatial Strategy and other plans and strategies

It was noted that the Indicative Regional Spatial Strategy for the South of Scotland summarised the challenges for the area, but that the Southern action area does not take into account the significant work and planning that has gone into the Indicative Strategy or the South of Scotland's Regional Economic Strategy. There was an associated concern that there appear to have been omissions in terms of some of the issues and proposals that have not made it into NPF4.

Overall, the concern was that the action area is not ambitious enough and needs to better reflect the realities of the region. As part of this, the primary focus being on sustainability was questioned, including as being less proactive than the branding of other action areas. It was also noted that other action areas set out ambitions that are already present in the South's Indicative Regional Spatial Strategy.

In addition to generally making the language more proactive, it was suggested that the following opportunities should be given greater overall emphasis:

• The region's contribution to achieving net zero. It was noted that every other action area references net zero, and its omission was seen as serious, given the strengths of the South. A specific suggestion was that natural capital and renewable energy opportunities should be highlighted, and it was noted that there is also no reference to the Natural Capital Innovation Zone (NCIZ) being delivered through the Borderlands Inclusive Growth Deal.
• The economic ambitions of the region, including reference to the Borderlands Inclusive Growth Deal and the South of Scotland Regional Economic Strategies in which a number of these policies and actions are identified. There was also reference to the Edinburgh and Southeast Scotland City Region Deal and the Regional Prosperity Framework.

It was also suggested that the region's strategic role and relationship to other areas could be better articulated, with comments including:

• Suggesting that the area is linked to the Edinburgh city region underplays the fact that the entire eastern part, the Scottish Borders, actually forms an integral part of the city region. This narrative should be amended to better reflect that important connection.
• The strategic importance of the region's links to Northern Ireland to the west and England to the south, should be set out.

Wider area references and emphasis required

There were also comments about areas that are not, or are not sufficiently, referenced under the Southern action area. They included that a spatial strategy for Southern Scotland that does not include Ayrshire is incorrect and does not reflect the realities of the area. Further comments included that:

• The southern part of East Ayrshire, around the Doon Valley and Cumnock, shares similar challenges and opportunities with neighbouring Dumfries and Galloway, and relates far more to this area than to the Central Belt, which is more distant spatially and completely different in character, land use and population dynamics.
• It is disappointing that South Ayrshire is not referenced. There is also a failure to promote a joined-up approach to the sustainable, low carbon and tourism development of the coast stretching from Stranraer into South Ayrshire and then into North Ayrshire. The was a concern that the action area seems to portray South Ayrshire as a strategic through route instead of a destination in its own right.

Comments relating to other areas were that:

• Although rural South Lanarkshire constitutes a significant part of this action area, there is no reference to the towns and villages of this part of South Lanarkshire. There are significant opportunities to utilise natural resources for power generation across this area, with wind, solar and ground source all opportunities to enable local towns and villages to become more environmentally sustainable.
• East Lothian appears to be located in this area but is not mentioned. The need to maintain the identity of East Lothian's rural communities and the surrounding high-quality countryside should be referenced, as should agriculture as an economic driver.

Projects or specific area references required

Suggestions for particular projects or areas that should be highlighted included:

• The Galloway and Southern Ayrshire UNESCO Biosphere, which encourages development to demonstrate innovative approaches to sustainable communities and economies and supports the enhancement, understanding and enjoyment of the area as a world class environment. It was suggested that NPF4 should give recognition to the role and value of the UNESCO Biosphere designation, in a similar way to how other UNESCO designations are reflected within the draft NPF4.
• The Gold Tier Dark Sky Park and the Merrick Wild Land area in the Galloway Hills. It was suggested that, along with the Biosphere, these designations reflect the national and international significance of the region's natural capital.
• The potential to develop Logan, the regional garden of the Royal Botanic Garden Edinburgh, as a delivery and outreach hub for the region, supporting sustainable development and resilience in the southwest.
• The application for National Park status by people in Galloway, including that this could be a useful tool to increase economic activity that is in sympathy with the environment.
• The bid which has been submitted for Dumfries to be recognised as a city. It was suggested that, if successful, this could help the wider region to promote its world class green spaces, such as the UNESCO Galloway and Southern Ayrshire Biosphere.

Themes to be given greater emphasis

Respondents also highlighted a number of themes that they wished to see emphasised, or given greater emphasis, in relation to this action area.

Natural capital

The region's high natural capital value, and the importance of land management being sustainable and of multi benefit, was also highlighted. The example given was around the carbon dynamics of afforested peatlands and making it an absolute priority for southern Scotland to ensure intensive land use does not undermine achieving net zero or accelerate biodiversity decline. It was also noted that there is no overall reference to the sustainability of agriculture and forestry.

Housing

Providing the required number and range of homes that people need and can afford was also considered to have received insufficient emphasis. There was a concern that the difficult housing markets in some parts of the region have not been recognised and it was suggested that pressure is currently disadvantaging both employers and those wishing to relocate to the region.

Other housing-related points raised were that:

• It is important to create suitable housing opportunities for the ageing population.
• It will be vital to ensure there are adequate housing offers available to retain and attract a younger, working population.
• Second homes are an increasing issue, particularly in some towns and villages, with younger people and those on low incomes being priced out of the market. NPF4 could be used to address the balance between the visitor economy and the residential one, and could support a fairer economy through affordable provision at a time of an escalating housing market.

Flood risk

It was noted that, although there is a mention of creating places resilient to flood risk, there is no mention of dealing with existing surface water flooding risk through new development or retrofit within existing developments.

Onshore wind

Comments included that the importance of the onshore wind sector, both in economic and renewable energy generation terms, needs to be emphasised. In particular, it was noted that there is no reference to the impact of Eskdalemuir Seismic Array on renewable energy development in this area. It was also noted that there is no acknowledgement that, within the lifetime of NPF4, a substantial programme of repowering will be needed across this action area if Scotland is to achieve its net zero target.

Transport

A general point was that the transport challenges in the area would be better aligned if reference were made to the RTS. Other transport-related comments included that:

• The summary glosses over the weakness of the public transport network in the region, particularly for intra-regional journeys.
• There is a lack of any rail connections westwards from Dumfries, or any proper bus connections between Dumfries and Galloway and the Borders.
• Although the region has untapped potential for active travel for short journeys, and even some longer ones, realistically there will need to be much more emphasis on buses and rail if development in this area is not going to drive up unsustainable trips.

Access to affordable food

It was reported that one of the major challenges in some of the region's villages is around accessing good quality food, and particularly fresh food, at an affordable price. It was also reported that there are several places that are classified as food deserts.

Outdoor recreation and tourism

It was suggested that the importance of outdoor recreation and tourism to the region, for walking and cycling in particular, and including Scotland's Great Trails, should be emphasised and there should be an aspiration to become a centre of excellence for this sector.

Question 17 – What are your views on these strategic actions for this action area?

Four strategic actions were included for the Southern sustainability action area.

General comments included that the focus of the actions is too narrow and prioritises sustainability over other aims and ambitions for the region. Other comments included that the strategic actions could be more ambitious, particularly around improving wellbeing amongst relatively deprived communities, by prioritising access to nature.

In terms of additional strategic actions, it was suggested that there should be an action on growing the working population. It was reported that there are significant population issues facing the South of Scotland, and ways of developing the growing opportunity of the region as a place for younger people to come and live and work would be a helpful focus. A similar suggestion was for an action around creating a balanced and sustainable rural population.

22. Create a low-carbon network of towns

Comments about creating a low carbon network of towns included that there is no mention of communities being actively involved in planning their future, which is one of the aims of the Indicative Regional Spatial Strategy for the South of Scotland.

It was also suggested that the draft NPF is very light on ambitions for settlements to be vibrant and diverse. It was noted, for example, that there is no reference to the creation of links between housing supply and economic development growth, and it was also suggested that the coverage on the repurposing and reinvention of town centres lacks positivity.

Another perspective, however, was that this strategic action is in line with East Ayrshire's aspirations and is supported by the Ayrshire Growth Deal through the CoRE project, which will transform Cumnock into a prototype self-sufficient, low-carbon town, with a locally distributed grid.

Other area-focused comments included that, other than Stranraer, all the suggested low-carbon towns are in the east of the region. It was suggested that Galloway's market towns and villages have similar aspirations but need support to achieve this. It was also noted that many are already working with the Biosphere to become Biosphere Communities, with a focus on delivering new sustainability initiatives, development of community resilience and promotion as destinations in the UNESCO Biosphere.

20-minute neighbourhood

One of the themes covered in relation to the 20-minute neighbourhood approach was its applicability to the southern, and particularly southern rural, context. It was noted that the strategic action appears to acknowledge that a tailored approach is required, but also that it does not go into detail about how that is to be achieved in practice. As at other questions, it was suggested that further guidance will be required as to how the approach would work in a rural area.

A different perspective was that acknowledging that a low-carbon network will have to rely on a tailored response to the 20-minute neighbourhood concept amounts to a recognition that the concept has little relevance outside individual towns themselves, and that it is not possible within each town to provide for all needs and services. There was also a note of caution that settlement expansion becomes Edinburgh commuter territory, counter to the 20-minute neighbourhood concept.

In terms of how the 20-minute approach could be delivered, there was a view that the existing network of towns in the south of Scotland present a good opportunity for future growth. It was reported that there are already strongly identified local centres, and that these would be ideal candidates for implementing 20-minute neighbourhoods. There was also reference to including service hubs in key locations with good public transport links. It was suggested that Demand Responsive Transport will be important in meeting travel needs where there are no conventional services.

It was also suggested that the development of community hubs in smaller communities could be highlighted. There was reference to the successful Humbie Hub in East Lothian as an example of the connection between rural hubs, economic activity and the concept of the 20-minute neighbourhood as it applies to rural areas.

Transport

A number of other comments also considered travel-related issues. They included that there should be reference to the STPR2 recommendations and the aims of the route map to achieve 20% reduction in car kilometres by 2030. However, it was also suggested that car use will, inevitably, be higher in rural areas where there is a lack of range and choice of public transport connections or local services.

In relation to active travel, it was suggested that it is unrealistic to apply city strategies and that wheeling, walking and cycling between towns is going to be an option for only a tiny proportion of residents and businesses.

Suggestions around achieving reduced car use included that:

• There needs to be a strong commitment to integrated public transport, especially better bus and rail connections across the region.
• The introduction of new homes can assist with the overall sustainability of a rural place by helping to sustain and grow local services and create greater economic justification for the funding of public transport.
• There is a pressing need to develop a 'Central Borders Transport Network', based on sustainable principles of reducing private car use by providing better and more convenient alternatives for travel between towns in the Network. Such a network would then provide a more extensive range of development opportunities, as well as greatly improving residents' access to employment, leisure and learning opportunities.

There was also a call for greater reference to the potential for the extension of the Borders Railway and the feasibility work that is already committed. It was suggested that it is difficult to think of a more important infrastructure proposal in terms of achieving the aims of NPF4 at a local, regional and national level.

It was also suggested that the Ayr-Stranraer railway line should be referenced, and that it has the potential to reduce car journeys and support cycle and walking tourism in the south-west of Scotland if the service is supported and improved.

Flooding and blue green infrastructure

In terms of delivering this strategic action more widely, it was suggested that planned and coordinated measures to build resilience to climate change, including flood risk management in key settlements, will be required.

However, there was also a concern that there is very little reference to the need for blue-green infrastructure and other climate adaptation actions, which was seen as surprising given the flooding challenges experienced by towns across the South of Scotland. It was suggested that there is a missed opportunity to highlight the links between flood mitigation and blue-green infrastructure and learn from the implementation of the Central Scotland Green Network (CSGN).

23. Support sustainable development

General comments included that the focus on supporting sustainable development aligns with East Ayrshire's aspiration, through the Ayrshire Growth Deal, of focusing investment on strategic growth corridors. Should East Ayrshire be included in the Southern action area, it was suggested that the Ayrshire Manufacturing Investment Corridor and the Ayrshire Engineering Park should be referenced.

It was also suggested that the UNESCO Biosphere designation, with its primary focus on sustainable development, should be highlighted within this section. It was reported that the Biosphere team work extensively with local communities and that almost 200 local businesses are signed up to their sustainability charter, supporting a transition to a more sustainable way of life.

High quality, green jobs

While job creation was seen as important, it was also thought that the importance of existing economic activity, including farming, should be acknowledged. In relation to the creation of jobs, it was suggested that they do not all have to be 'green'.

The importance of the digital economy in supporting job creation was highlighted. It was suggested that improvements in digital connectivity could be a catalyst to making the region a more competitive place to work and live, which in turn would assist in meeting the objectives around employment opportunities and retention of young people. A connected suggestion was that, as with all opportunities to invest in specific activities, consideration should be given to the local training and employment opportunities that would be part of this process.

Renewables

In terms of other job creation opportunities, there was reference to the region's untapped potential to become a centre of excellence for manufacture, research and development for the renewables industry. In particular, it was suggested that Eyemouth's role in supporting the offshore renewables sector should be referenced, and the Blue Economy delineation that appears along the entire coast of Scotland extended down the eastern seaboard of the Southern region.

Recreation and tourism

The potential of recreation and tourism was also highlighted, including through reference to the Galloway and Southern Ayrshire UNESCO Biosphere and proposed National Park.

Given the natural assets in the area, the aspiration to become a prime destination for outdoor recreation and green tourism was supported. However, it was noted that green tourism comes with its own challenges, and there was a call for serious thought to be given to how any negative effects caused by an increase in visitors to the area will be mitigated.

Higher and further education

It was reported that there is currently great interest in moving forward a proposal to establish a new medical school at the Crichton Campus in Dumfries, potentially a hub and spoke model with Glasgow University medical school being the hub and NHS Dumfries and Galloway being the partner. It was suggested that this proposal would help people from across the South of Scotland region's areas of multiple deprivation access medical training.

However, a general observation was that while this strategic action highlights the importance of higher and further education institutions in the region for retaining young people, it omits to discuss the near impossibility for getting to them by public transport in time to start a working day.

24. Innovate to sustain and enhance natural capital

A general concern was that this strategic action does not really cover prospects for working on nature restoration at a landscape-scale across the south of Scotland, including promoting corridors for species and habitat recovery.

In terms of issues or approaches that should be covered, there was again reference to the UNESCO Biosphere and its key focus on delivery of ecosystem services. It was reported that it is a delivery partner for the Borderlands Natural Capital Programme, with an initiative focused on realising wider public benefits through working with the farming community.

Forests and woodland

Although it was agreed that the forests and woodlands in the south of Scotland are of national significance, there were some concerns about their depiction as assets. It was considered vital that forestry, and other intensive land uses in this region, do not increase greenhouse gas emissions and there was particular reference to the significant areas of afforested deep peats in Dumfries and Galloway.

It was suggested that any forestry expansion should in all cases be multifunctional and take the form of diverse, resilient forests that take into account a sense of place and offer enhanced recreation for everyone. Other comments included that:

• There could be more precision in differentiating woodland types and land use priorities according to types. Native woodland and habitat restoration or improvement is needed throughout the region to redress the region's natural ecological balance.
• We should strive to plant trees that will not disturb soil carbon and that will have a 50+ year carbon lock up after harvest. This should apply to private as well as public forests.
• The need for resilience against future disease, and issues like increased potential for fires and windthrow should be considered.
• Without effective engagement with both local communities and communities of interest, these forests can become a huge block on public access and enjoyment of the area. The importance of consultation and engagement with communities of both place and interest before planning the creation of new woodlands was stressed.

The reference to rewilding on the Carrifran model was welcomed, although there was a call for more specific guidance on which land should be rewilded and how this should be done.

Rural land use and the Regional Land Use Pilot

Other comments addressed land use more widely and included that planning authorities and RLUPs should have a mechanism for assessing development and changes in land use against climate and biodiversity ambitions. It was also suggested that projects and initiatives, including the Borderlands Natural Capital Programme and the South of Scotland Regional Land Use Pilot, will need to work together with partners and different sectors to restore biodiversity and to maximise natural capital opportunities. It was suggested that a National Nature Network would be a way of bringing projects such as these together in a clear framework.

With specific reference to the South of Scotland Regional Land Use Pilot, one perspective was that it appears to have ended up as a way of talking about, rather than tackling, issues and has been under-funded and under-resourced for tackling the very complex issue of conflicting land use needs and wishes. To work going forward, it was suggested that more funding and a bottom-up approach will be required.

Renewable energy

It was noted that references to existing renewable energy developments are limited to Chapelcross, and there were suggestions that other projects, including the work of East Ayrshire's CoRE project, could be included.

A number of other comments welcomed the recognition that proposals for consolidating and extending existing wind farms, and associated grid improvements, will require a carefully planned approach. As part of that approach, it was suggested that NPF4 should place greater emphasis on balancing the renewable energy generation necessary for reducing carbon emissions with the protection of landscapes that provide a number of benefits to human and natural health, including as vital carbon sinks.

For example, it was reported that Policy 19 (Green energy) and Policy 33 (Peat and carbon rich soils) do not set out requirements for LDPs to have a carefully planned approach, with the requirement for spatial frameworks for onshore wind having been removed and no strategic approach to avoid peatland damage being proposed.

Other comments focused on meeting the need for increased renewable energy generation. They included that:

• The text makes no mention of repowering or the need for new sites or co-location of different renewable energy technologies.
• The reference to consolidating existing wind farm sites is unclear, impractical and inappropriate. It was suggested that responding effectively to the climate emergency requires increased, rather than simply consolidated, renewable energy generation capacity through repowering, life extensions and new development on appropriate sites.

The recognition that any renewable energy development in the Solway Firth would require careful planning was welcomed. However, there was a concern that the Solway Firth is a vital habitat for many species of wildlife, birdlife and plantlife and should not be put at risk without extensive scientific evidence to understand the implications of any development. It was suggested that NPF4 policies need to ensure that the sensitivity of the environment, and its international importance for nature conservation, are given weight in the decision-making process. This was connected to Policy 3 (Nature crisis) and Policy 32 (Natural places).

Also in connection to the Solway Firth, it was reported that Crown Estate Scotland is funding a post with the Solway Firth Partnership to develop a business case for the Borderlands Growth Deal looking at marine natural capital opportunities in the Solway Firth. It was suggested that support for innovative natural capital approaches in this action area would help bolster the business case necessary to unlock this funding opportunity.

25. Strengthen resilience and decarbonise connectivity

General comments included that the need for improved transport connectivity beyond the borders of the Southern action area is clearly identified in the draft RTS.

Rail

In terms of issues or themes that require greater coverage, there was particular reference to the potential for the extension of the Borders Railway and the feasibility work that is already committed and funded through the Borderlands Growth Deal. It was suggested that the extension is fundamental to creating stronger economies, attracting investment and increasing connectivity for more remote communities. However, there was a concern that concentrating development around the existing Borders Railway, without expanding other rail links, will lock in regional inequality.

Other rail-related comments included:

• There is nothing specific around better connectivity between the Scottish Borders and Dumfries and Galloway.
• There is a real opportunity to consider how NPF4 could support the Stranraer and Nithsdale rail lines by creating, new stations and improving the frequency of connections. This could benefit commuters and provide an alternative option for freight/timber transportation.
• The opportunity that cross border collaborations with Northumberland and Cumbria could bring to the area is underplayed. For example, more emphasis should be placed on the future potential of approaches such as extending Borders Rail to Carlisle and improving and developing passenger rail and freight facilities.

Public transport

The suggestion that further work needs to be undertaken to build the case for improvements to public transport routes was seen as disappointing. Other comments included that it suggests a lack of commitment to improving the shortcomings of the existing infrastructure and service provision, including around east-west connections.

Given the importance of buses (in the absence of rail across large parts of the region) it was suggested that there needs to be greater consideration of how they interact with active travel modes, especially for those using cycles and mobility aids. There was also a call for urgently-needed sustainable transport investment. A connected point was that any development should be used to drive the delivery of infrastructure, and cannot just rely on existing developments such as the Borders Railway.

Digital connectivity

It was also suggested that the reference to digital connectivity could be expanded as it has significant potential to make the region a more competitive place to live and work. Further comments included that:

• Longer distance commuter travel demand can be reduced with good digital connectivity, and this should be given greater emphasis.
• Digital infrastructure improvements must be prioritised. Not only will improved digital connectivity unlock rural living for home and hub working, but it will contribute to the growth of digital learning opportunities, improve the digital economy, and will deliver the strategic drivers of the Borderlands Inclusive Growth Deal.

Overall views

Question 18 – What are your overall views on this proposed national spatial strategy?

Around 280 respondents made a comment at Question 18. Many of these comments referred back to issues raised in relation to one of the action areas and to the analysis at the previous questions.

General comments included offers of support, or support in principle, for the aims of the proposed national spatial strategy. Further observations included that it is coherent, logical and well-presented. The structure of the draft NPF was also welcomed, and it was said to flow well, with the national spatial strategy to the front, followed by national developments and then the National Planning Policy Handbook. It was also suggested that the spatial strategy will be a useful guide to the preparation of Regional Spatial Strategies, LDPs and Local Place Plans.

In terms of particular themes that respondents were pleased to see identified in the spatial strategy, there was reference to climate change, placemaking, addressing the nature crisis and enhancing biodiversity. There was also explicit support for embedding the 20-minute neighbourhood approach, and the focus on retrofitting existing buildings and homes.

Others, however, suggested that the national spatial strategy serves little purpose, or is unclear. It was described as a collection of disjointed, high-level aspirations and there was a concern that there is no clear indication of the role its contents should play in the planning system. A connected comment was that it will need significant refinement and expansion if it is to become a useful element in the LDP for any particular area.

There were also questions about how the spatial strategy relates to other sections of the draft NPF, with a suggestion that the spatial principles do not need their own section and could be incorporated into the place themes. Other suggestions were that:

• The spatial strategy would be more directional if the identification of national developments was clearer and more specific, and these national developments were clearly identified spatially.
• There is a need for further guidance to explain the role and function of the spatial strategy, including how the actions relate to the policies set out in Part 3 of the draft NPF.

Links to other strategic plans

As at Question 7, a number of respondents commented on the relationship between NPF4 and other national, regional or local strategies or plans. General comments included that the spatial strategy would be helped by setting out the important relationships with other plans, programmes and policies which are fundamental to delivering the overall ambitions. More widely, it was suggested that the National Spatial Strategy map (on page 5) should show wider connections to other parts of the UK or to the EU. In terms of national agendas, there was specific reference to:

• NSET.
• The Onshore Wind Policy Statement.
• Housing to 2040.
• The Heat in Buildings Strategy.
• Achieving Net Zero Emissions in Scotland's Buildings.
• Energy Efficient Scotland: Improving Energy Efficiency in Owner Occupied Homes.
• The Land Use Strategy.
• A Scotland for the future: opportunities and challenges of Scotland's changing population.
• The Skills Investment Plan for the Historic Environment.

In terms of regional or local strategic relationships, there was reference to:

• Regional Spatial Strategies. There was a call for Regional Spatial Strategies to be developed as quickly as possible to provide more detailed regional guidance for LDPs, and to inform and be informed by Regional Economic Strategies.
• RLUPs and the Regional Land Use Frameworks.
• RTSs. It was noted that RTSs are essential to the delivery of transport that helps support the delivery of the shared spatial strategy.
• City Region Growth Partnerships.

On the relationship between NPF4 and other strategies, it was suggested that potential conflicts and tensions need to be acknowledged. An example given was that there is a required integration of NPF4 with other complementary strategies and policies, specifically the Land Use Strategy, yet there is little detail on how this will be achieved.

Deliverability

Some of the comments focused on whether or how the spatial strategy can be delivered, often reflecting some of the issues covered under the analysis for Part 4 – Delivering our spatial strategy (Questions 54 and 55).

Issues raised included that:

• There too many subjective aspirations that are not easily measured, and which are not rooted in land use planning.
• Connected to this, the spatial strategy covers factors over which the planning system does not and cannot exert control.
• The Part 1 narrative does not indicate the weight that should be afforded to the spatial strategy in planning decisions. Carrying forward the statement from NPF3 that LDPs must have regard to the NPF, and that Scottish Ministers expect planning decisions to support its delivery, would go some way to addressing this point.

Other comments addressed resources and included that NPF4 has to be backed up with funding to help deliver the good intentions of the spatial strategy. Further comments included that there needs to be:

• A capital investment programme to deliver the development and infrastructure required.
• A non-political focused national delivery vehicle.
• Adequate investment in planning services to ensure there are planners in place to manage the service and deliver the ambitions set out in NPF4.

Other comments also addressed how the spatial strategy will be delivered on the ground. Specifically, it was reported that NPF4 will bring further complexity and place additional requirements on planning authorities, including when assessing and determining planning applications and reviewing LDPs. It was suggested that this will require additional resources and the upskilling of planning staff and elected members.

Area-focused themes

In terms of how well the spatial strategy considers the needs of Scotland as a whole, it was suggested that the spatial strategy needs to be more consistent across the regions and recognise the links and interdependencies between them. It was also thought that the spatial strategy and action areas could do much more to address the disparities and inequalities between communities across Scotland, particularly in the larger area authorities with networks of communities that are most distant from each other, and therefore face greater challenges and require more significant per capita investment to achieve net zero.

One perspective was that there is an emphasis towards urban needs, with not enough support for the rural parts of Scotland. It was suggested that NPF4 should aim to support rural communities with the increasing challenges these areas are facing into the future. There was specific reference to the national ambition for appropriate rural repopulation and to considering the needs of remote communities.

An alternative perspective was that there is insufficient emphasis given to urban areas, and a lack of differentiation around towns and cities, which have different requirements and different needs. For example, it was suggested that the draft NPF often talks about town centres, but the needs of core city centres are also vitally important to the economy and attractiveness for tourism and employers.

In terms of the location of urban areas, it was felt that the application of a rural label to areas such as Highland misses the very significant urban context and opportunities that these areas also have.

Missing themes across the spatial strategy

There were also a number of suggestions for themes that respondents wanted to see covered, or given greater coverage, in the national spatial strategy. These included:

• Net zero and climate resilient communities. It was suggested that the spatial strategy does not go far enough in addressing the climate emergency and ensuring Scotland reaches its 2030 net zero targets.
• Renewable energy. Points included that, given the urgent requirement for the expansion and generation of renewable energy, it is unclear why the emphasis changes fundamentally from area to area. It was suggested that the delivery of renewable generation projects should not vary from region to region and should be a national and regional 'Golden Thread Policy'.
• The circular economy, including an industrial transition that creates a more circular economy, support for geographical areas of circular economy expertise in particular sectors, and opportunities to support industries focused on closed-loop recycling.
• The emissions associated with the creation, maintenance and refurbishment of buildings and infrastructure. It was suggested that this involves evaluation of construction processes and material choices, but also ensuring that existing materials can be reused.
• Halting and reversing biodiversity loss. It was suggested that the need to protect biodiversity and irreplaceable habitats has not been fully recognised.
• Safeguarding iconic and other valued landscapes for future generations to enjoy.
• The 'Precautionary Principle'. It was noted that it currently appears only in relation to coastal flooding and major landscape impacts.
• Food and agriculture. It was suggested that food security and resilience is a vitally important issue but is largely ignored. It was also noted that agriculture is also a major economic activity in many rural areas, with the potential to be even more valuable in the future. There was also a call for growing initiatives - bespoke to communities needs and local conditions - to be included in all the action areas.
• Health and particularly health inequalities. There was a concern that, despite improving the health and wellbeing of the people of Scotland being one of the identified outcomes of NPF4, the content of the national spatial strategy makes little reference to health.
• Safe space. It was suggested that any spatial strategy which is looking at developing and improving space for our communities needs to have safety as a core theme, and should prioritise areas of inequality.
• The needs of older people. It was seen as surprising that there is no reference to the key issue of an ageing population within the national spatial strategy section. There was also a call for detail on housing for varying needs and how the spatial strategy will ensure there is an adequate supply of accessible housing and housing that will meet the needs of an ageing population.
• The sustainability and development of the Gaelic language. There was a call for NPF4 to support the Scottish Government's commitment to increasing the number of people using and learning Gaelic.
• The role of culture and creativity. It was suggested that the challenges and opportunities are not addressed sufficiently and that while the focus on cultural heritage is welcome, the cultural sector is wider than this.
• The contribution of heritage to the vision for Scotland's places. It was suggested, for example, that reference to heritage assets under the Sustainable places and Productive places themes would help set out the vital role that these assets play in driving tourism, creating jobs, attracting business, and ensuring high quality and unique places.

A number of comments related to infrastructure and included that there needs to be more direction and focus on infrastructure delivery. It was seen as vital that NPF4 addresses infrastructure delivery challenges, and acknowledges that a failure to do so will be a major obstacle to investment and inclusive economic growth. There was specific reference to:

• Electricity infrastructure and the importance of grid investment. The concern was that this does not feature across all of the action areas, despite being critical to achieving many of the priorities identified in the spatial strategy. There was a call for grid investment to be recognised as a vital enabler to each action area's decarbonisation and resilience objectives.
• Waste and recycling infrastructure and the role of the planning system in delivering what is needed for the delivery of circular economy objectives.
• Expansion and full electrification of the Scottish railway network, as one of the key methods of reducing emissions from travel and achieving a zero carbon society.
• The spatial needs of the freight industry. It was suggested that consideration should be given to the support the sector needs, for example in relation to: the decarbonisation journey and the relationship with energy networks; infrastructure requirements to support the shift from road to rail; and infrastructure requirements to minimise the impact of freight and logistics on towns and cities.
• Airports. It was seen as disappointing that the spatial strategy fails to recognise the importance of connectivity by air, other than for island communities, and the importance of tourism to the Scottish economy, along with the sectors that enable the tourism industry.
• Resilient broadband and connectivity infrastructure. This was described as underpinning the Scottish economy and there was a concern that the spatial strategy does not detail the importance of building and maintaining a resilient digital network using fibre.

Finally, there was a concern that the spatial strategy does not recognise the importance of community empowerment. Connected points were that:

• It is too centralised and will not reflect local need and aspiration.
• Greater recognition must be given to community empowerment legislation with planning policy formulation stemming from this.
• A presumption in favour of community-led development is needed. To ensure that this presumption has substantive outcomes for communities, it was suggested that it is qualified to apply to community-led projects which build significant community wealth.