Local Living and 20 Minute Neighbourhood - draft planning guidance: consultation analysis

4. Part 2 – What local living looks like

This chapter presents an analysis of Q2 and Q3, which asked for respondents views on the key considerations for local living and the Local Living Framework, presented in Part 2 of the guidance. Responses to these two questions overlapped; to avoid repetition, views on the Local Living Framework concept and diagram are presented under Q2 and views on the themes and considerations included in the framework are presented under Q3.

Almost all organisations (98%) agreed that the framework diagram in part 2 of the guidance is helpful; 28% very helpful and 70% somewhat helpful. The sectors most likely to consider it very helpful were third sector organisations (56%) and retail (50%), followed by place-based organisations (40%) and health and social care (40%). Among individuals, 82% felt the guidance was not at all helpful.

The framework diagram is not accessible or clear

Over seven in ten respondents left an open-text comment in Q2. Many respondents felt the framework was not straightforward to understand. Comments included that the diagram appeared to show each component as equivalent in status or was too high level, cluttered with icons and caused confusion. For instance, one queried why the movement illustrations showed a car and a tram when the focus in the movement section was on walking and cycling. Another queried why social interaction was included with resources and suspected it was related to social capital.

A few commented on the diagram’s place in the guidance. For instance, the diagram was not embedded in the main body of the text, and the illustrations were unclear or open to misinterpretation. A small number felt the Place Standard Tool Design Version was easier to follow and had fuller explanations, though there was a feeling many tools were already in use, which could lead to confusion, especially for community groups.

“The Place Standard tool was already considered by many users (specialists and generalists) to be complex. Many practitioners believe there should be some simplification and tailoring to make it easier to use. However, the many new versions and lenses are making it seem even more complex. In effect, it is considered this framework diagram may be adding more complexity to an already complex concept and diluting the place standard.” – Angus Council

The framework diagram is helpful for supporting local living

Conversely, however, the next most prevalent theme was many positive comments about the framework diagram. Comments described it as helpful, comprehensive, a useful visualisation and enabled an easy understanding of the main features of local living. Organisations commonly indicated it would be useful for operationalising the guidance at local level, for instance, by helping identify gaps or opportunities, facilitating community and stakeholder engagement and providing a basis for assessment of local living.

“Creating a single diagram that incorporates the multi-faceted complexities of the myriad qualities, services and amenities that support local living is a major challenge. It will not be possible to please all stakeholders. The diagram does an admirable job in capturing a wide range of fundamental characteristics.” - SURF

“The diagram appears to be relevant in the identification of categories to consider local daily needs.” – North Lanarkshire Council

More detail is required to enable effective planning decisions

The next most common theme was that the framework needed to be more specific to be useful in planning decision-making. Geddes Consulting suggested adding a narrative of: ‘When assessing or establishing 20 minute neighbourhoods as part of LDP preparation and planning applications, the principles set out in Part 1 of this guidance should be utilised’. It was argued that the framework should facilitate community involvement while noting the potential for consultation fatigue.

“This diagram does not really explain anything beyond summarise the key aims. It does not help me to understand how it will actually be implemented or what the result will look like.” – Individual

“The guidance should clarify how the Local Living Framework relates to development planning and decision-making.” - Heads of Planning Scotland (HOPS)

One suggested producing a complementary local living checklist for developers, providing a spreadsheet tool similar to that adopted elsewhere, e.g. Transport for London’s Healthy Streets indicators, stating:

“Such a tool will help developers to make sure any proposed development results in improvements in line with the local living Approach, scoring the proposals against the identified local living indicators. Such an assessment could be used to show planning authorities and the public alike how development will result in improvements.” - Tactran

Alignment with the Place Standard Tool

Aligning the guidance with the Place Standard Tool was positively received by several. However, several others felt the Tool and Local Living Framework were too similar or required more distinction.

The Place Standard Tool was considered to be well-established, evidence-based, commonly used and recognised locally. Therefore it was felt to provide a robust framework for the development of local living initiatives. For instance, Dundee City Council noted that the categories aligned with data currently being mapped and analysed using GIS. East Dunbartonshire Council outlined earlier difficulties in marrying NPF4 requirements with the place principles and felt the framework offered a ‘very clear steer’ on which tools to use and easily allowed engagement to be aligned to the Place Standard Tool Design Version.

Public Health Scotland called for their report - Evidence behind Place Standard Tool and Place and Wellbeing Outcomes - to be referenced more explicitly in the guidance. The Place and Wellbeing Collaborative suggested the Outcomes would be better suited to the end of the section on the benefits of local living and to state that achieving them “can positively influence the delivery of all the impacts of local living”. It highlighted the need to clarify that the Place and Wellbeing Outcomes set out the characteristics required in every place to enable wellbeing, while the Place Standard Tool provides a set of questions to assess how much an area meets key place and wellbeing considerations.

Several felt that the framework was too similar to the Place Standard or that there should be more clarity about the difference between the two. A few called for the Place Standard Tool to be used instead of the framework, or to strengthen existing processes. A few felt better linkages and explanations of each of the place-based concepts or tools, perhaps including a summary diagram, would be helpful.

“Our preference would be the development of a more coherent, less fragmented process to underpin place-based approaches, including supporting local living within the planning system. Either a companion to the Place Standard tool, which explains how to interpret that tool in the context of local living or an ‘add on’ which facilitates this as a next step in the process would be preferable.” – North Ayrshire Council

Use of data at a local level

The need for firmer guidance on how measures could be used to achieve local outcomes intended by the framework was raised by several. There were calls for a framework that could be applied in practice, following a determined methodology and structured around outputs and outcomes; it was felt that this could aid consistency and reduce local resource requirements. Calls were made particularly for more quantitative measures and data, for instance, to measure the term ‘high quality’. However, one suggested more creative methods could help engage communities in data-gathering processes.

“It would be useful if the guidance provided further in-depth detail of the 20 minute neighbourhood approach being investigated and actioned within an area, both in terms of what the data looks like, how it was gathered, how partnerships were formed and the practicality of actions coming to fruition. NLC have recently appointed a person specifically for the undertaking of data collation and analysis. It would be interesting to see what others have done or plan to do as more of the authorities begin to progress with the local living and 20 minute neighbourhood concept.” – North Lanarkshire Council

Anderson Bell Christie suggested such a framework should consist of: a clear definition of 20 minute neighbourhoods with assessment criteria and key performance indicators (KPIs) to help plan, implement and monitor the neighbourhood; a guideline for how a 20 minute neighbourhood and its KPIs can be assessed and integrated with planning, implementation and operational phases; a KPI assessment tool to monitor performance; neighbourhoods with different ambition levels and pilot projects to validate the definition through testing and implementation.

Practical suggestions on the use of data included:

• Providing guidance on how the concepts should be implemented and assessed.
• Referring to the www.usp.scot toolkit, a free online platform providing consistent and robust data on local areas in Scotland, allowing comparison between them.
• Developing an accessibility tool or reference to map-based approaches such as the shared data resource being developed by the Scottish Government’s Digital Transformation team.
• Quantifying distances for what are considered necessary to meet everyday needs. The Scottish Government could release available datasets to produce GIS-based maps with isochrones^[3] for various travel modes.
• A before, during and after assessment of each component of the diagram could help evidence change over time.
• Considering cross-boundary assessment across local authorities to consider linkages and proximity of facilities.
• A minimum set of proximity-based standards could allow investment to be better targeted at areas failing to meet those standards.
• Exploring habitability indicators for viable Island communities developed in the Åland islands for creating local place plans.
• Indicators could be linked to the Scottish Government’s wellbeing economy approach, drawing on the Wellbeing Economy Monitor measures which include inequalities. This also links well with community wealth building.
• Methodology and data sources to conduct local accessibility assessments could be included, the output of which could map good, limited or poor accessibility areas.
• Using an approach similar to the toolkit set out in the RTPI’s Measuring Planning Outcomes research could enhance the ‘implement and review’ stages.
• Emphasising the role and importance of equalities impact assessments.
• Improving data sharing between private and public sectors.

More detail is needed

Several called for more clarity on this part of the guidance. Requests were made for more specificity to allow it to be used, including providing more illustrations, examples or case studies of how it can be applied to differing types of communities or populations. For instance, Environmental Protection Scotland felt the definition of health was not robust enough and noted key health and community living enablers, such as GP surgeries and supported living facilities, were not mentioned in the Health and Wellbeing section. It was suggested that other dimensions of health could usefully be referenced, such as social, emotional, mental and spiritual, while one suggested using the WHO (World Health Organisation) definition of health.

A few called for the research cited on page 16 to be referenced. Geddes Consulting noted a concern about how the 20 minute concept could be interpreted by authorities and potentially used to reject developments not in line with the definition of ‘key destinations’. They called for this phrase to be further defined. Public Health Scotland argued that wording about using the approach should better recognise the complexities involved:

“The framework risks being too high-level to constructively support the various components of civil society which must all be engaged in delivering the Local Living Framework. Current wording only states [the concept] “should be considered and where appropriate, addressed in delivering successful local living”. This gives insufficient weight to their delivery and fails to acknowledge that no single organisation or sector can deliver these key considerations in isolation.” – Public Health Scotland

Some respondents in Q2 and some in Q3 suggested improvements to enable the framework’s use in practice. One felt the text should clarify that the key considerations formed the overarching themes when undertaking the process set out in Part 3. Others preferred the diagram to be located alongside a key and explanatory text. South of Scotland Enterprise suggested adding a separate diagram for rural areas, perhaps using a jigsaw illustration to demonstrate that different elements may combine uniquely in one or more places to form a whole.

Prioritise the elements of successful local living

Some felt the guidance and the Local Living Framework should determine which themes or considerations were essential for local living, or how aspects should be prioritised, as this better reflected reality and assisted planning decisions. Greater recognition of these spatial challenges was recommended, particularly the need for communities to be designed around good transport links to work, education and health centres.

A few highlighted the need for the guidance to address competing priorities and trade-offs. One individual cited research^[4] that found housebuilders' claims went largely unchallenged and that planners felt the public appeals process prioritised housing delivery over other objectives such as design. Another pointed to the proliferation of student flats and holiday homes when market forces prevailed.

The Young Foundation highlighted their research findings that residents were prepared to make trade-offs if these would facilitate other benefits of local living, with good transport infrastructure always prioritised.

“The document could do more to assist planners in situations where the localities are inherently constrained in how it can implement competing demands, or where demand for one land-use or amenity is a more important trade-off due to local conditions.” - Individual

All but two organisations who answered Q3 (98%) considered the categories and key considerations in part 2 helpful; 27% very helpful and 71 somewhat helpful. The proportion who felt they were very helpful ranged from 17% of local authorities to half (50%) of health and social care and retail organisations. None of the seven housing/property organisations who answered found the categories very helpful, but all found them somewhat helpful. Over three quarters (78%) of individuals answered not at all helpful.

Additional aspects to include in the framework

Just over three fifths of respondents left an open-text comments in Q3. The most prevalent theme in Q3 was many suggestions about other aspects to include in the Local Living Framework across all of the five overarching themes. Features respondents felt should be added or strengthened included:

• Health - food, healthy eating and community gardens, other health benefits, hospitals, health centres, GP practices.
• Education – schools, educational activities, outdoor learning centres.
• Community – volunteering, burials and cremations, culture and creativity, community centres, sporting and leisure facilities.
• Spaces and climate – green and blue infrastructure^[5], nature networks, landscape, land use, air quality, water and flood management.
• Economy – local businesses, shops, digital connectivity, home working, practical and commercial economic realities of what can be achieved.
• Built environment – historic and existing buildings, landscaping, high density of new development in urban centres.
• Legal – policing, enforcement measures, personal safety, local democracy.
• Principle-based - inclusive, resilient, affordable, connected.

Many organisations provided detailed responses, particularly those with expertise in a particular area or representing interest groups, with some giving reasons and suggesting how these could be incorporated into the framework. For instance, The Built Environment Forum Scotland felt the historic and existing built environment should be reflected across other themes, such as Space, not just the Civic category. RTPI Scotland suggested that quality be extended across all themes, including Movement and Resources. The reader is advised to refer to the individual responses to the consultation for more information.

“The diagram doesn’t make it clear where specific items would fit within the themes in the diagram. For example, the preceding paragraphs of the diagram include a mention of core daily needs, including eating healthy food, but it is not clear under which of the 14 themes eating healthy would be placed.” - Obesity Action Scotland

Two organisations called for consistency in referencing wider policies, noting that several policies are references in the Movement section, but other sections have limited or no references. They argued that similar references would give each section equal weight.

Comments on the Movement section

The next most frequently raised comments related to the five themes in the Local Living Framework: Movement, Space, Resources, Civic and Stewardship.

Suggestions were made for additions and corrections to the Movement section. Mention of public transport was welcomed, with suggestions made to explicitly reference various types of movement as these are used as part of a public transport journey, strengthen commitments to accessibility and address cost and service reliability. Bus travel was felt to be a more accessible form of travel than other types of movement, such as cycling. It was felt that the movement of disabled people should be considered further, with, for instance, accessible public spaces and pavements and car use and the Blue Badge scheme.

CLD Standards Council expressed concern that some learners and families were unable to access community facilities as public transport no longer operates in their area. It recommended a mapping exercise such as using a digital space to record and share information on community groups and mobility/transport support, e.g. bike lending and buddy lifts.

“Scottish Government funding and long-term commitment is needed to address transport issues and support the development of public/community transport where service buses are not willing to run, but the route is a lifeline to those isolated and vulnerable.” – CLD Standards Council

“The Highland Council’s Active Travel Strategy includes a prioritised list of infrastructure interventions for the Inner Moray Firth area and for a number of settlements across the area. The prioritisation process scores possible interventions on a number of criteria, including social deprivation, car ownership/access and existing transport interconnections, including public transport. This makes explicit the connections between local living and access to travel options and allows the Highland Council to focus resources on the interventions which will have the greatest positive impact.” – The Highland Council

Other specific aspects considered worth including were low and no parking provision, trades access and parking, travel information provision especially at bus stops, car use by disabled people, and strengthening references to: driving speeds and road safety, quality of required infrastructure e.g. footpaths and cycle lanes, 20 mile per hour zones, bike (included adapted bike) storage and reduction of travel distances. A few pointed out that the reference to Sustainable Transport Hierarchy should read ‘Sustainable Travel Hierarchy’^[6]. Falkirk Council suggested reframing the section into separate categories of walking, wheeling, cycling and public transport to reflect the Sustainable Travel Hierarchy.

Comments on the Space section

Suggestions were made by several to strengthen the Space theme. In particular, examples of blue and green infrastructure could be incorporated based on the NPF4 definitions, or the diagram could include a quadrant on this topic. Two mentioned including Sustainable Drainage Systems (SuDS) for their rainwater management function as part of this, with one suggesting SuDS be included in the descriptor of spaces.

An explanation of how the climate crisis could be addressed could be included. This could, for instance, make stronger reference to nature networks and existing natural land use such as landscapes, the historic environment, natural heritage, productive growing spaces and the interconnectivity between streets, spaces and facilities.

‘Growing’ was felt to require clarification, for instance, using ‘food growing’ instead and referencing community food production. Public Health Scotland suggested more emphasis could be given to how interventions increase access to healthy foods, whilst greater recognition of the contributory role of food growing was suggested by another.

Other factors suggested for consideration included the height of buildings, whether indoor and outdoor spaces should be included in the same section, emphasising orientation and wayfinding tools to help people navigate their surroundings, expanding the description to account for exercise and leisure space, and recognising active travel, for instance, how well-kept streets can encourage movement and how well-designed spaces support changes in transport use.

Comments on the Resources section

Several made varied comments on the Resources section, often supporting specific aspects.

“The “Housing & Community” theme within the “Resources” category lists considerations including “accessibility”, “adaptability”, “relationship with local area”, and “range of tenures, types & sizes”. Collectively, these considerations provide a solid basis for planning and developing housing that meets people’s needs and fits well with the surrounding services and communities.” - Health and Social Care Alliance Scotland

Comments on the structure of this section were received. One felt Resources and Civic were unclear terms and could be combined under Society instead. Another suggested Support and Services is too broad and differs from the term used in the Place Standard Tool. They recommended that it be split into local shopping, health facilities and schools instead. Other comments included that the category could include a Social Action theme or list the key considerations of Social Interaction in the Civic category.

Some welcomed the inclusion of healthy food. Comments included: the need for greater emphasis on affordable healthy eating or amending the term to ‘healthy local produce’; no link being made between healthy food and community assets which are currently in different sub-categories; the need to mention access to affordable healthier foods when discussing shops, cafes etc.; adding allotments as an example of community assets and; ensuring new developments and regeneration initiatives include land for growing.

Specific additions to this section recommended by respondents included cost, purchaser/provider roles, resource distribution, and the circularity of resources. Places of worship, access to arts and culture, libraries, retail and community development, informal social spaces, tourists and visitors and storage and parking were suggested additions or areas to strengthen. The Shetland Islands Council felt the section could mention the potential for resources and public space to futureproof against obsolescence and changes to community needs over time. Other factors respondents felt should be considered included quality and a holistic focus on creating places and supporting healthy, sustainable lifestyles. Increased emphasis on community wealth-building was suggested. For instance, one recommended further integration of community wealth-building principles into the policy context, emphasising opportunities to engage in public-interest led development under NPF4.

Comments on the Civic section

Views on the Civic section, particularly aspects regarding the concept itself, safety and belonging, attracted comments from several. The Civic term and concept were felt too high-level and abstract to be useful by some, with calls to use a revised term. For instance, the meaning of ‘gateways’ in the Identity and Belonging category was queried. Suggested additional wedges were Spirituality, to capture faith, and History and Culture. One suggested combining the Civic and Stewardship themes.

The Feeling Safe section could be strengthened by recognising the role planning professionals and landscapers can play in contributing to safety, prioritising improved street lighting, acknowledging the multi-dimensional nature of feeling safe for a range of community groups and referring to feminist approaches to planning. The Landscape Institute, for instance, highlighted Glasgow City Council’s adoption of a feminist approach to planning to ensure public spaces are inclusive and accessible. Maintenance could usefully be added after ‘care’, given care suggested informal upkeep and repair measures, whilst maintenance indicated more formal input.

“It is encouraging that feeling safe is a stand-alone subgroup. We want to request that this be defined further as something which is far more than physical safety in a community and that it links back into social interaction to support services and community. It is about having people and places around you, in the community, which are easily accessible when you find yourself in a vulnerable position at any point in your lifetime.” - CLD Standards Council

Comments on promoting Identity and Belonging highlighted aspects that facilitated this, such as horticulture, historic buildings, community ownership and youth work. A few called for more focus on community action such as what constitutes meaningful community participation, how communities can source funding, and ways to sustain community dialogue. A few also highlighted the need to incorporate accessibility in the section, including recognition of the diverse needs and preferences of community members.

Comments on the Stewardship section

Several respondents made specific comments on the Stewardship section, with some arguing that the term should be replaced as it was not commonly understood at a community level. A few also highlighted it could be too vague to operationalise, for instance, difficult to apply spatially or due to the lack of reference to accountability and redress as considerations under Care and Maintenance. Greater definition of roles and responsibilities for place maintenance, re-use and improvement was sought, with more recognition of the roles communities could play in this.

A greater focus on community resilience and empowerment was recommended, such as highlighting initiatives which have successfully stimulated appetite for public involvement. For instance, examples of communities working together to deliver valued services, share ownership and maintain areas could be highlighted. Further, the roles of Community Councils, access panels and CLD in enabling public participation should be emphasised. It was felt important to tighten the guidance in this area, not least to ensure communities had the capacity to participate and that difficult decisions or challenges were not offloaded to communities to deal with.

“The guidance needs to be clearer about the role of planning in the long-term stewardship of places, for example in Fife, we currently only condition that developers must maintain landscaping for up to five years but stewardship goes beyond planning controls and policies and implies greater citizen, community, and public body care and maintenance outwith the control of planning.” – Fife Council

Focus on accessibility

Several respondents in Q3 felt more attention should be paid to accessibility, including digital and physical accessibility features of place.

It was felt that digital accessibility could focus on the range, type and quality of digital services that are accessible, with practical guidance given on how to achieve this. However, Fife Council argued digital access to facilities could only be included as a consideration in development management processes if more work were done to implement this in practice. A few mentioned the need for digital infrastructure to be strengthened to help access, for instance, health services or employment opportunities.

“As it is, the draft guidance does not propose any methods for assessing accessibility via digital services, including the key considerations. The draft guidance also does not provide any considerations or advice for achieving the right balance of physical and digital access for different groups or communities.” - Strathclyde Partnership for Transport

The need to ensure access to places for all members of communities, including those with disabilities, was emphasised, as was the need to involve them in place decision-making. East Dunbartonshire Council expected to see prioritisation of each need or facility based on direct accessibility. Practical accessibility solutions for outdoor spaces were given, including reducing hazards on pavements, the importance of signal-controlled pedestrian crossings and detectable kerbs, avoiding moving vehicles, public and adaptable toilets, accessible play areas, spaces for rest and segregated walking infrastructure.

“Research has shown that a kerb height of at least 60mm is the only reliable marker for blind and partially sighted people to identify when a footway changes to a road or other surface. Long cane users and guide dog owners are reliant on this feature as a means of orientation and guiding.” – RNIB Scotland

“Simply referring to “accessibility” without reference to whom spaces need to be accessible for may lead to some people being forgotten or missed in planning. Indeed, there are no explicit references at all to disabled people and only very limited references to older people in the guidance document.” – Health and Social Care Alliance Scotland

One felt care should be taken in town centres to ensure accommodation was not exclusively located on first and upper levels above shops with no lift access. MACS (Mobility Access Committee for Scotland) argued for transport to healthcare to become an integral part of care pathways and to include access to healthcare as a consideration when designing 20 minute neighbourhoods.