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

5. Part 3 – Ways to support local living and 20 minute neighbourhoods

This chapter examines Part 3, Structuring the Approach, and the three key steps in delivering local living which comprise this approach: understand the context; collaborate, plan and design; and implement and review. It emphasises that the approach will be iterative and incremental as it responds to the lived reality of delivering 20 minute neighbourhoods to communities.

All but one organisation (99%) who answered Q4 felt the proposed structured approach was helpful. One third (33%) felt it was very helpful, and 66% somewhat helpful. There were marked differences by organisation type: While both retail organisations, 75% of other organisations and 71% of third sector organisations felt the structured approach was very helpful, only 20% of local authorities, 17% of transport organisations, 14% of housing/property organisations and 11% of place-based organisations viewed it as very helpful. Over four fifths (82%) of individuals felt the proposal was not at all helpful.

Around two thirds of respondents left a comment in Q4. As well as commenting on the structured approach, many commented on each of the three steps. These comments have been included below in the analysis of Q5, Q6 and Q7, which focus on each step.

Agreement with the structured approach

The most common theme in response to Q4 was agreement with the structured approach presented in Part 3. Many respondents either agreed or supported the approach while also noting areas for improvement as described below.

“This is all very clear and looks like a sensible approach.” – Individual

“The proposed structured approach to local living is concise and pragmatic - emphasising that the delivery of local living and 20 minute neighbourhoods is a continuous and repetitive process – and summarises a number of significant considerations to deliver local living. This is a useful tool to have when taking steps to develop and deliver local living.” - Environmental Protection Scotland

“The ‘structured approach’ is concise, easy to understand and easily explainable to various stakeholders.” – Dundee City Council

Some noted that they particularly liked the flexible and iterative nature of the structured approach, which would help take into account the changing characteristics of living spaces and the diversity of different places in Scotland.

“RTPI Scotland supports the iterative process proposed as part of this structured approach. This type of cyclical process recognises that Scotland’s places are living, breathing, vibrant, diverse and continuously subject to change. Town planning has a crucial role to play in the design and development of high-quality spaces that prioritise health, happiness and the wellbeing of individuals and communities.” - RTPI Scotland

“It highlights previous information with the document which states that local living will be adaptable to different areas throughout Scotland by ensuring the approach begins with understanding the context of a certain area.” - South Ayrshire Council Planning Strategy

“The structured approach is simple and not over-complicated, and the circular aspect of the approach will help ensure that the planning and development of places remains dynamic, adaptive to change and flexible.” – Landscape Institute

Calls for greater detail

Potential improvements to Part 3 were suggested by many respondents. Within this, some organisations asked for more information about the structured approach, requesting more specific detail on how the approach would work in practice such as:

• Who should be involved and their roles and responsibilities.
• Expected timescales.
• Details of the positive outcomes that could be expected to arise from using the approach.
• More examples of how the approach could, or has been, applied.
• Providing more depth to some references, for example, SURF asked for more information about the “additional data sources” referred to in the guidance.

“It is interesting how it takes on Placemaking Principles, particularly around understanding the context and the collaboration component with wider community engagement. This proves that the structured approach can be adapted or used with other tools if leaders or LAs wish to go further. The iteration loop aims for continuous improvement, which is crucial in cities and towns where there could be varying demographic and socioeconomic trends. One thing it doesn’t clarify is how often these iterations should be done, should they follow the LDP frequency, or maybe more often.” - Dumfries and Galloway Council

Changes, additions and deletions to Part 3 were also suggested. Several expressed a concern that the language currently used in the guidance did not accurately reflect the scale of the changes felt to be required to implement the structured approach effectively. For example, West Dunbartonshire Council recommended acknowledging the necessary 'fundamental shift' in planning.

Other specific changes included:

• Some respondents did not believe that Figure 7 in Section 3 worked well, and a few suggested it was overly simplistic. A few noted that while the depiction of the process was circular, it was linear in application and called for more feedback loops.
• A few mentioned the need to highlight the positive impact the approach would have on the environment, such as improved land and air quality, the latter of which will directly benefit health.
• Environmental Protection Scotland suggested the context of a place be expanded to include “proximity (the closeness of things); accessibility patterns (such as closed or non-adaptive developments); and the impact of choices and behaviours made by people on the viability and deliverability of local living.”

“The current review process needs to be more rigorous to identify, plan for and implement considered collaborative solutions which help to tackle the climate and biodiversity crises.” - Individual

Conversely, a few respondents felt the guidance was too prescriptive. For example, Scottish Borders Council suggested Part 3 could be streamlined further.

Funding and staffing concerns

As mentioned in Chapter 2, several respondents noted concerns about resourcing, staffing, and funding. These concerns were frequently raised around Part 3, with some arguing it could add to the already high workloads of local authority planning teams and other stakeholders. A few suggested that an incremental approach will require continued investment over extended periods of time. Concerns were particularly acute in relation to data collection and management, especially qualitative data, which a few noted would be more time consuming to gather than quantitative data.

“There is concern within the line on community engagement ‘the results of previous engagement exercise like these can form a valuable starting point for qualitative information’ (p31). Suggesting the existing community engagement work as only a ‘starting point’ for qualitative information gathering is unreasonable given the timescales for producing an evidence report.” - Aberdeenshire Council

“Understanding context is vital in understanding the unique characteristics of the area/community and ensure that interventions are relevant and successful. As noted above, the importance of gathering quantitative and qualitative information is fundamental to success of this step. However, it is the qualitative information gathering that may prove challenging.” – Moray Council

Virtually all organisations (99%) agreed that part 3 of the guidance was helpful in clearly communicating the importance of data in establishing a baseline for a place. One third (32%) felt it was very helpful, though again this varied by type of organisation from 13% of local authorities to 50% of health and social care and third sector organisations and both retail organisations. None of the seven housing/property organisations who answered found the categories very helpful, but all found them somewhat helpful. Among individuals, 79% felt it was not at all helpful.

Positive feedback

Just over three fifths of respondents provided an open-text response to Q5. The most common theme was support for the guidance’s clear communication of the importance of both qualitative and quantitative data. Many agreed with the importance of gathering and using data to understand the context of a place, and others supported the creating baseline measures which could be monitored over time. However, some caveated their agreement with suggestions and calls for more detail, which are explored below.

Qualitative data

Many respondents noted the importance of qualitative data, agreeing it was a good way to understand how people live in communities. A few others mentioned the importance of including qualitative insights when establishing a baseline for each community. Cycling UK in Scotland noted that qualitative data could help create a vision that was appealing to community members.

“The history of a place, the heritage and the interests, needs and skills of the inhabitants are primary in setting the context - not an academic exercise but storytelling with people’s research and contributions from the schools, the churches, the housing associations and (of course) the allotments. This brings people to gather, engages them, and from this, you can develop plans - bottom up, not top down.” – Individual

“Engagement should include both online and in-person events to hear from locals and fully take their views on board. GIS is a useful tool but understanding and appreciating community concerns is critical.” – Individual

A few emphasised how qualitative data would provide greater depth of understanding, especially about the resources available in communities, e.g., rather than the number of shops, qualitative data could explore the types of services provided by each shop and how useful these are to a community.

“This is particularly important in relation to ensuring shops and services adequately meet the needs of local people, identifying barriers to access or where improvements can be made. Qualitative data also provides an opportunity to give additional insight and draw out benefits of projects or services which may not be immediately apparent. This is particularly relevant to generative enterprise models such as community services or shops as these types of activities may have wider social and economic benefits for the community.” - North Ayrshire Council

Many respondents asked for more information about how to collect, analyse and use qualitative data. Some respondents suggested that guidance was needed in assessing qualitative data to ensure that information was up-to-date and representative of the community. A few others highlighted the benefit of using the Place Standard Tool to collect qualitative data. A small number stressed the need to ensure the language in the guidance gives equal weighting to qualitative and quantitative data.

“Overall, yes, although we would avoid referring to “hard data” to describe quantitative data as this suggests that it is somehow more real or concrete than qualitative data.” – Diabetes Scotland

The importance of engaging hard-to-reach communities and speaking to minority groups or audiences that are often not consulted was mentioned by several. A few individuals were concerned that “loud voices” or minority opinions would be considered more than harder to reach groups. A few supported the use of qualitative data collection as they believed it would allow greater engagement with minority groups. However, one individual cautioned that qualitative data collection could be considered intrusive into people’s lives.

“We are fully supportive of the principles of informed decision-making and collaboration set out in this section. This would be stronger if there was explicit reference to inequalities within this section and the need to ensure that a diverse range of voices are deliberately sought.” - NHS Fife Public Health Department

“A further key advantage however which has been omitted, is qualitative data ability to cover more intricate details missed by quantitative research methods. This is particularly valuable when considering the experiences of often ignored groups, such as ethnic minority women, disabled women or LGBTQ+ women. Ethnic minority women for example are less likely to engage with online materials and instead direct conversations can be more valuable and inclusive. We are aware that this has been touched on, however, it is vital that despite the difficulties in carrying out good quality qualitative research, the Scottish Government strive to improve methodologies. This could be done through collaboration with third sector organisations who already work with women and marginalised groups.” - Scottish Women's Convention

Quantitative data

Several respondents supported the use of quantitative data. A few specifically mentioned the value of GIS data and national spatial datasets, although they asked for further guidance on how to use different sources.

“Qualitative data helps capture the experiences, values, and aspirations of people, while quantitative data provides measurable indicators and trends. Together, they provide a more robust baseline for assessing the current state of a place, identifying challenges and opportunities, and informing future planning and decision-making processes.” – Moray Council

Several asked for more information about quantitative data collection, and others provided suggestions about what should be included, such as a mapping of:

• All facilities, including food outlets and the availability of affordable healthier food and hygiene registers.
• Access to green spaces.
• Places with natural and heritage designations.
• Topography of places.
• Disparities in access to recreational opportunities.
• Transportation, such as frequency and use of major routes and access to alternative transport modes.
• Variety in types of housing in specific areas.

A few respondents also asked for guidance about which data is or should be, compulsory for a planning application and where to find it. Others mentioned where some of this data could be accessed, such as existing council sensors or counters, Scottish Government Open Data portal, UK Data Service, OpenStreetMap, Scottish Index of Multiple Deprivation and Census data, Scottish Public Health Observatory (ScotPHO) Profiles Tool, Scottish Household Survey data explorer, National Records Scotland, Scottish Living Locally Data Portal, surveys gathered through the Scottish Health Survey, and registers held via Food Standards Scotland.

“The Council considers there are still some matters requiring further clarification, specifically how this information is gathered and the expectations in terms of where and how it is applied. For example, it would be useful if the guidance could set out a comparison between how the approach would apply to a master planned site versus the development of a Local Place Plan.” - City of Edinburgh Council

“Quantitative data should include measurable and quantifiable data about the relevant community and place, including large datasets detailing nuance and subdivision within community data” – Shetland Islands Council

Importance of detailed, high-quality data

The importance of detailed, high-quality data that is comprehensible to all was mentioned by several. Others highlighted the importance of data that is up-to-date and reflects all communities, especially those in rural and island locations. A few raised concerns that qualitative data, in particular, could be considered too subjective and may not stand up to criticism. Ensuring data is not biased was a concern for a few. For example, a small number of individuals were concerned that data could ignore specific perspectives and be used to support positions favourable to the Scottish Government or local authorities.

“SPT agrees that the assessment needs to make best use of quantitative and qualitative data. However, it is important that anecdote is not substituted for qualitative ‘data’.” - Strathclyde Partnership for Transport

Volunteer Scotland asked that the language be adjusted to say that quantitative and qualitative data should be “current, relevant and robust to ensure conclusions drawn are accurate and representative of the collective community experience.”

Methodological expectations and suggestions

Several respondents called for the guidance to set out expectations for a preferred methodology for data collection. This included requests for further guidance on gathering, analysing, and presenting data, which some noted would help with consistency.

“Part 3 identifies the kind of data that might be used to establish a baseline, but again the guidance is very general. The guidance might have been expected to provide a more detailed methodology as to how data might be assembled, analysed and presented, including the use of GIS/digital mapping. Real-life, illustrated examples of the application of the methodology and digital mapping tools to a particular area might have been useful.” – Falkirk Council

Though not necessarily expecting a full approach to be outlined in the guidance, several other respondents asked for clarification on who is responsible for conducting the data collection, the connection between data collection and the planning process, and information on the relationship between qualitative and quantitative data.

Others recommended certain methodologies they would use, such as participatory qualitative methods and local-level quantitative data collection. A few others also recommend clearly defining the boundaries of places to allow for a clearer understanding of the quantitative data presented.

“To do this successfully, it will be vital to have clear definitions and boundaries of a place or community that align to existing data categorisations, allowing the aggregation or disaggregation of quantitative information to better inform understanding.” - South of Scotland Enterprise

Some others emphasised the importance of accessible data. For example, this would include ensuring that data collected by public bodies is published for public use, and effective data sharing between public bodies and local authorities.

Other themes

Some respondents mentioned other types of data that should be considered, such as flood risk, access to work including a greater range of jobs, travel behaviours, impacts of climate change and population density.

A few others pointed out that existing community engagement could be used to understand context, and Aberdeenshire Council suggested that the perspectives of visitors also be considered as they are economically and socially important to different areas.

One quarter of organisations (24%) felt part 3 of the guidance was very helpful in supporting collaborative practices. A further 71% felt it was somewhat helpful, meaning 94% of organisations felt it was helpful to some extent. With the exception of the two retail organisations who both felt it was very helpful, third sector organisations were then next most likely to feel it was very helpful (50%). Local authorities were least likely to find it very helpful (8%). Four fifths of individuals (80%) found part 3 not at all helpful.

Importance of public engagement

Just over three fifths of respondents commented in Q6. The most prevalent theme was an emphasis on the importance of engaging with communities and listening and responding to public feedback. Several respondents suggested that while they approved of the structured approach, they wanted to ensure that the process started with communities and avoided a top-down approach.

Respondents noted that collaboration with communities was essential, but some individuals expressed concern that community opinions may not be taken seriously. A few organisations and individuals highlighted negative past experiences where community consultation has been used after decisions have been made. Similarly, a small number suggested that LDPs had not listened to communities previously and were therefore doubtful this would start happening now.

“Adoption of a suitable baseline from which to develop plans, and ongoing reviews and updates look like a sensible approach (to deliver almost any project), however, so far I have seen nothing to give me confidence that local people will be involved in decisions that affect them” – Individual

“Previous experience with collaborative co-design has felt like communities being asked to approve previously decided plans. There must be a solid commitment to properly engage with communities. To let them lead with the plans, from asking what services are needed but currently lacking, to how to transform transport options to ensure access to those services, and to implement as far as possible the community’s suggestions.” – Common Weal

“Language in the Case Studies section like “Council Led Regeneration” are not helpful, and throughout the document greater emphasis should be given to ensuring coproduction and community led regeneration is front and centre to the approach, if we are taking a place based approach around 20 minute neighbourhoods / local living this should be community led and co-produced. This would be supportive of the Community Empowerment legislation and duties too.” - NHS Lanarkshire Health Improvement Department

Other organisations stressed the importance of interacting with specific groups, including young people, and a small number emphasised using intersectional approaches.

Positive feedback

Many respondents provided positive statements about the collaborate, plan and design phase. While several provided general positive feedback, several others approved of the proposal’s inclusion of collaborative working. This included support for collaboration with communities, cross-sector private organisations, and the public sector. A few again emphasised the importance of moving away from silo working.

“Hallam agrees with this section, particularly as it emphasises the need for cross-sector commitment and acts to show Hallam that the Scottish Government does recognise that further collaboration across stakeholder groups is needed.” - Hallam Land Management

“This section presents a useful holistic view of the ways different sectors can collaborate to help achieve local living and 20 minute neighbourhoods. It outlines the key role planning authorities play, alongside a broad range of other stakeholders.” - The Highland Council

Calls for greater detail

Many respondents asked for more guidance and information about how to collaborate with communities. Respondents noted that while they liked the theory presented in the structured approach, they were unsure how it would work in practice. Others noted that there are existing models for collaboration and engagement but called for them to be more explicitly referenced in the guidance. Several respondents requested more examples and case studies to show how collaboration, planning and designing work in practice.

“It is too vague to be very helpful. Reference to NPF4 policy isn't enough. Just stating ‘Collaborative approaches’ without explaining the ‘how’ isn't really enough.” - Kintore and District Community Council

Calls for more information and guidance were made by several respondents, including requests for more specific details about:

• Distinguishing procedures for changing existing communities and developing new 20 minute neighbourhoods, which respondents note will be different processes.
• Investment plans and investment decisions that will help local authorities delivery local living goals.
• Guidance on agencies that will or should be involved.
• More information about a ‘town-centre first’ approach and how it relates to 20 minute neighbourhoods in urban areas with larger distances between the centre and outlying neighbourhoods.
• Details about what is meant by ‘affordable living’.
• Information on public service reform as it relates to this section.
• Guidance on new processes for land allocation.
• Chief Planning Officer Guidance, which should outline the role and how it is supported by local living guidance.
• More information about risk assessment will be carried out to assess the impact of the proposal on different businesses and infrastructures.

Several respondents provided suggestions to improve the ‘Collaborate, plan and design’ step of Part 3. These included:

• Placing greater emphasis on the quality of new builds and properly functioning places.
• Using Delivery Plans to clarify the approach.
• Emphasising the importance of strong local leadership, effective decision-making capacities, and providing further details on expectations and examples from other places implementing local living strategies.
• Considering links to active travel and public transport.

“It is easy to encourage more collaborative working, but how is this to be done in practice? How will structural impediments to collaboration within and between public sector organisations, between local and national government, and between the public and private sectors, be overcome? How should local government go about ‘eradicating silo working and aligning investment, development delivery capacity and resources’? How can resource-constrained local authorities engage those who do not typically participate in community engagement activities? What support will be available to communities so that they can work out how to implement 20 minute neighbourhood objectives in their own neighbourhoods? How do we shift the mindset and ways of working (across all development sectors not just planning) from merely consulting local communities to genuine co-production? And, in all of this, what is the role of the Scottish Government?” – Individual

Consider links with private and third sector

In response to both Q6 and Q7, several respondents stressed the importance of including third sector and private stakeholder in both the collaborate, plan and design and the implement and review phases of the approach. Churches, schools, shops, wider industrial companies, supermarkets, and healthcare facilities were some examples of stakeholders respondents were interested in involving. In particular, respondents frequently welcomed the recognition in the implement and review section that various key players have different skills and capabilities, though several respondents either called for more information on how this could be utilised or highlighted challenges to collaboration.

The role of the third sector was noted by some, although there were concerns about the assertion that they have capacity; it was noted that many currently face significant staffing and funding challenges and are unlikely to have capacity. A few welcomed the third sector and community development being treated on a par with other stakeholders, but CLD Standards Council asked to see the CLD profession and practice noted. The Scottish Churches committee called for recognition of the role of faith organisations.

Similarly, some welcomed the reference to engaging with the private sector, but called for more guidance into how to engage the private sector given their role in providing some services to communities. Two called for more information about how the private sector could be encouraged to invest in communities.

“As we note in our response to earlier questions there are a range of stakeholders involved in delivering local living. We welcome this section because it recognises this and the need for collaboration. The private sector should however be listed as one of the parties under the collaboration bullet point given that they are one of the partners in delivering the 20 minute neighbourhoods.” – Persimmon

More generally, several respondents highlighted broader challenges around coordinating multiple, varied stakeholders who could have conflicting or competing agendas. Respondents called for more guidance on how ‘each sector can support others to access resources and help share capacity and knowledge’, for national leadership and coordination, for clarity that delivery is not seen as solely the responsibility of the local authority, and for support for statutory bodies who are involved in implementation.

The implement and review section of part 3 was considered helpful by 94% of organisations who answered Q7; 29% felt it was very helpful, and 65% somewhat helpful. Among individuals, 81% considered this section not at all helpful.

Calls for greater detail

Just over half left an open-text comment in Q7. Most prevalent in comments were calls for more information on implementation and review. A few respondents, both individuals and organisations, described this section of the guidance as lighter than other sections, lacking practical detail or, in a few instances, not adding to existing knowledge or processes.

“Implementation and review are perhaps two of the most important aspects of realising 20 minute neighbourhoods, however, this section of part 3 of the report seems underdeveloped.” – RICS (Royal Institution of Chartered Surveyors)

Many argued that the guidance requires more information about review and monitoring in particular. This included greater clarity over who would be responsible for review and how accountability would be applied, what frequency and timescales were considered most appropriate for a review, and how any learnings or good practice would be identified and shared. For example, one organisation questioned if the review stage would be driven by the Action Programme of the LDP to demonstrate the effectiveness of delivery; another stated that ‘if the baseline data is collated at the Evidence Report stage of the LDP process, the guidance should set out a recommendation for a subsequent review period’. A few called for examples or case studies of monitoring processes to be included.

A small number of organisations noted the importance of a consistent approach to review being used across Scotland; one called for local authorities to develop a shared set of implementation processes and review criteria which are broadly similar across Scotland to avoid data being presented differently.

While slightly less frequently mentioned, several others called for similar information about responsibility and timescales for implementation. A few individuals argued that their local authorities had a poor track record of implementation generally.

“However it is not clear who is carrying out implementation, who is conducting the review, or where these findings are communicated to. More information on this would result in greater transparency, accountability and further confidence in delivery.” – National Trust for Scotland

“It is very basic information on implementing and reviewing. It would have been useful to know the key steps of implementation, number of tiers, at what level what organisation would be involved. Time frames and cost involved in doing this. How the implementation would be reviewed - approaches used, who to be involved.” – NHS Lanarkshire Health Improvement Department

Implement and review section is helpful

Several respondents, mostly organisations, agreed with the importance of considering implementation and review and considered the section helpful. In particular, they supported the mentions of other policies, strategies and investments in the guidance and the emphasis on the importance of collaborative and cross-departmental working.

“This section is a really helpful contribution to the guidance, and we welcome the explicitly iterative nature of the process and the commitment to review and learning lessons.” – Living Streets Scotland

“Overall, "implement and review" is critical in supporting the delivery of collaborative approaches by promoting accountability, learning, and the long-term success of local living initiatives.” – Moray Council

Relationship with LDPs and NPF4 Policy 15

Several organisations welcomed the inclusion of guidance on how development managers and planning authorities should judge applications against Policy 15. Often this guidance was welcomed because, while there was recognition that this process would become part of new LDPs, these would take some time to be widely embedded and used. For the same reason, a few, including Angus Council, The Highland Council and RTPI Scotland, called for further guidance to assist in implementing NPF4 in planning decisions. A few called for guidance about planning applications to be included earlier in the document.

“This guidance document acknowledges that the relevance and assessment against Policy 15 “will vary between applications and contexts” and that LDPs will provide “a further steer on expectations for applications”. While local authorities are awaiting this “further steer”, more clarity should be provided to local authorities on how their DM officers should apply these guidelines when assessing planning applications.” – RTPI Scotland

“For the guidance to carry weight, it must give planning authorities the confidence to reject applications where community engagement and collaboration is insufficient. SURF stakeholders often point to the reality that more than 95% of planning applications are approved annually, and regularly cite specific proposals, including out-of-town mixed use developments and isolated new-build housing, which receive approval despite apparently running counter to policy intentions for more 20 minute neighbourhoods.” - SURF

Comments on Figures 11 and 12

Mixed views were expressed on the trip chain diagrams used in this section. Some felt they were useful, while some respondents criticised the simplicity of the diagrams, calling for greater explanation of what they were trying to show, or suggesting they did not add anything to the guidance. A few specifically criticised Figure 11 for presenting life as linear when people’s needs vary.

Resource and funding implications

While some noted or welcomed the acknowledgement that there are ‘limited resources and capacity for delivery’, several reiterated the additional workload and cost to local authorities of implementing effective and high-quality review and monitoring processes. A few called for the guidance to set out other sources of funding opportunities which could help implementation, such as City Deal funding, the Scottish Government’s Edinburgh Process Fund, or grants or loans available to third sector or community organisations.

Other comments

Scottish Community Development Centre, East Dunbartonshire Council and Dundee Civic Trust suggested that implement and review should be treated as two separate stages to ensure each gets adequate attention and to create a more complete learning cycle.

“The proposed three stage structured approach conflates ‘Implementation’ with ‘Review’ and it misses out ‘Revise implementation’ as another step. It should be a five-stage process as follows: 1. Understand context; 2. Collaborate, plan, design; 3. Implement; 4. Review; and 5. Revise Implementation.” - Dundee Civic Trust