National Planning Framework 4 - Key Agencies Group position statement consultation

Response by Scottish Enterprise

Scottish Enterprise welcomes the opportunity to comment on the NPF4 Position statement. We consider that the Position Statement will have a significant impact on the future sustainable development of Scotland and reflects a more integrated response to the development of land, environment, community and economy which reflects our own Strategic Framework and developing response to the climate emergency and economic recovery post-COVID. In response to the specific consultation questions raised in the Position Statement the following sets out our comments within the context of our support of the direction of travel established through the position statement. 

1. Do you agree with our current thinking on planning for net-zero emissions?

SE strongly agrees with the thinking on planning for net-zero emissions particularly the commitment to direct development in locations which reduce the need to travel and are well served by sustainable transport options (p8) and support for significant further investment to support new technologies (p9).  

In respect to the potential policy changes (p10) we suggest that it would help to qualify that where offsetting emissions are being considered they should be ‘a last resort’ rather than an alternative.

There are already projects underway through City Deals and which will emerge through regional spatial strategies and other partnership vehicles that should guide and be guided through the NPF4 process. Partnership working across the public sector and with the private sector is a critical component in delivering the net-zero agenda.

The provision of infrastructure has capital expenditure implications for public sector bodies but also revenue issues that need to be recognised if the infrastructure first approach is to be realised effectively.

2. Do you agree with our current thinking on planning for resilient communities?

SE agrees with the current thinking on planning for resilient communities. We note in particular the application of the 20 Minute neighbourhood strategy and will consider how we can contribute to this through our operations and investment strategies. We will also consider how the commitment to an infrastructure-first approach and the application of Sustainable Travel and Investment Hierarchies will impact on investment locations. It will be helpful that the Scottish Government will align the Capital Investment Plan in terms of the role of private capital in developing sites of strategic importance to Scotland.

Placemaking is a key enabler of planning for resilient communities and Scottish Enterprises recognises our role in working with local authorities and others to create the high quality environments required as part of our own placemaking agenda as currently set out in the Place Principle.                          

3. Do you agree with our current thinking on planning for a wellbeing economy?

Scottish Enterprise is already supporting the process of planning for a wellbeing economy through our focus on inclusive and sustainable development. We work with other agencies through our regional engagement process and support fully the policy changes proposed in the Position Statement.

There is a specific need to address the spatial and other enabling factors required to address the Scottish Government Manufacturing Recovery Plan. This could perhaps be included in the eventual NPF4 or through some other vehicle.

4. Do you agree with our current thinking on planning for better, greener places?

Scottish Enterprise supports the thinking set out in the Position Statement. There are a number of policy changes that will increase developer confidence that are very welcome. SE is also engaged in supporting vacant and derelict land and building use and will continue to do so. The focus on town and city centres is noted and will clearly have an impact on office as well as retail development investment and SE, where appropriate will work with partners to respond to.

5. Do you have any further suggestions on how we can deliver our strategy?

Scottish Enterprise note the ongoing review of developer contributions and would like to reinforce the recognition that ’any new approach is grounded in an understanding of development economics and deliver’ which will be an important issue in terms of post-COVID recovery. (p38) In particular SE strongly supports the alignment of NPF4 with the Infrastructure Investment Plan as this will provide more certainty for key developments. In particular, Scottish Enterprise would ask that consideration be given to identifying opportunities for international sub-sea fibre connectivity (for regional and rural participation in the wellbeing economy). We would highlight the importance of identifying growth clusters and the focus required in terms of infrastructure provision and delivery considerations. Also, we note that clusters can be a significant contributor to developing opportunities for foreign direct investment.

Scottish Enterprise would suggest that NPF4 should very clearly include definitive guidance in terms of timescales, delivery partners and lead agencies for national development and policy proposals. This is not required at this stage but will be a key area of discussion as NPF4 progresses.

6. Do you have any comment on the Integrated Impact Assessment Update Report published alongside this position statement?

No comment.

7. Do you have any other comments on the content of the Position Statement?

NPF4 will be substantially different from NPF3 and will be of even more importance to Scottish Enterprise. The scale of integrated working will build on increasingly collaborative partnership approaches and Scottish Enterprise is keen to be involved in the both the development of NPF4 and the subsequent changes in policy.