National Planning Framework 4: explanatory report

Purpose of Explanatory Report

This Explanatory Report fulfils the requirement in Section 3CA of the Town and Country Planning (Scotland) Act 1997 for Scottish Ministers to lay before the Scottish Parliament an explanatory document which sets out:

• the consultation undertaken;
• a summary of representations received; and
• the changes made to the Draft as a result of the consultation.

This report sets out an overview of the three rounds of engagement undertaken since 2020: the Call for Ideas (2020), the Position Statement (2020) and the Draft NPF4 (2021). Further detailed resources on each of these engagement stages are available at www.transformingplanning.scot.

The main focus of this Explanatory Report is to set out the changes made between the Draft NPF4 and the Revised Draft NPF4 which has now been laid in the Scottish Parliament.

The sections in this report correlate to the structure, layout and policy numbering contained within the Draft NPF4. This allows easier read across to the Analysis of Responses Report which provides an overview of the responses received from stakeholders from the consultation.

Each section covers a summary of the responses received (from the Analysis of Responses Report), a high level overview of the key changes, and then a table outlining further detail on specific changes, and the reasoning for those.

These tables include comments from stakeholders, as well as those made through responses from Parliamentary Committees and from the UK Climate Change Committee.

Consultation responses contained a very large volume of evidence and information. This report does not seek to answer every individual point that has been considered in the drafting of the Revised Draft NPF4. It also does not record where support was given for elements of the Draft. Instead it focuses on setting out the reasoning for the main areas of change, and justification for areas where change was not considered necessary.

NPF4 has a lot of cross cutting issues. Some points are made in more than one section of the Analysis of Responses Report. We have not repeated points more than once in the Explanatory Report but have put them in the most logical themed section. We have also set out commentary on many of the more general and cross cutting issues in the General Changes section to reduce repetition.

Process

Consultation undertaken

The Scottish Government has been committed to a co-production approach to developing NPF4, listening carefully to the needs of all stakeholders throughout the process. That included following up and addressing many issues raised by the Scottish Parliament during the course of the Planning Bill.

Consultation to inform Draft NPF4

Tworounds of extensive engagement were carried out to inform the Draft NPF4:

• Call for Ideas
  • The Scottish Government sought early views on NPF4 through a 'Call for Ideas', which ran from January to April 2020. Stakeholders were invited to consider Scotland in 2045 and reflect on planning policy changes and National Developments needed to get us there.
  • The Call for Ideas was backed up with extensive stakeholder engagement and a roadshow around Scotland to hear what people had to say, with provisions of supporting resources and policy information notes:
    • 180 people participated at our roadshow workshops.
    • We also spoke to around 100 people at our drop in sessions across the country.
    • nearly 350 written responses were received.
  • '2050 Think Pieces' - we asked planning stakeholders to provide 'think piece' contributions on Scotland 2050 to stimulate discussion and think about priorities for NPF4.
  • There was strong support for NPF4 to be radical with many seeing it as a key opportunity for change.
• Position Statement
  • In November 2020, we published a Position Statement which set out an overview of likely key challenges, opportunities and potential policy changes, having reflected on the wealth of information and views we had received already. It also reflected on the impacts of COVID-19 and what NPF4 can do to help societal and economic recovery.
  • We also commissioned PAS to support communities plus children and young people to engage in the development of NPF4. The outputs are available online.
  • During the Position Statement consultation period, the Royal Town Planning Institute held 4 roundtable sessions to discuss some key themes:
    • Post Covid Recovery
    • 20 Minute neighbourhoods
    • Achieving net zero
    • Delivering good quality development
  • We consulted on the Position Statement and received over 250 responses.
  • There was broad support for the general direction of NPF4, the ambition on climate change, the focus on the place principle and the focus on 4 key outcomes.
• Regional Spatial Strategies
  • We also undertook extensive collaborative work with local authorities, working in regional groupings, to share ideas and prepare indicative Regional Spatial Strategies which formed the basis of the spatial strategy in the Draft NPF4.

Consultation and Engagement on Draft NPF4

Legislation requires a period of Parliamentary scrutiny of up to 120 days from the date that it is laid before Parliament. The Draft NPF4 was published for consultation between 10 November 2021 and 31 March 2022.

• Engagement during the Consultation

Alongside Parliament's scrutiny – and in accordance with our Participation Statement we carried out a further period of public consultation and extensive stakeholder engagement, encouraging everyone to get involved. The Programme for Engagement included:

• Community Grant Scheme – £250 grants were offered to community groups to help them engage – 5 grants have been issued.
• Open invitation events gave stakeholders the opportunity to discuss NPF4 and encourage participation in the formal consultation. Nine events in total were held (one on each of the 4 policy themes and one on each of the 5 Action Areas), attended by over 100 people.
• Equalities roundtable aimed at promoting responses to the consultation, discussion was held in March with a range of organisations, around 12 organisations attended.
• Roundtable discussions were hosted by the Royal Town Planning Institute on business, energy, environment and housebuilding during February.
• Scottish Youth Parliament workshop was held at the Gathering in February.
• Worked with PlayScotland to support responses from children and young people's perspectives, two workshops hosted.
• Discussions with community groups – including 2 events hosted by PAS at the end of the consultation period, with over 50 participants.
• Resource information online to help people digest – included presentations, policy background notes, digital narratives, and all the evidence received through Call for Ideas and Position Statement.
• Publication/Notification of the consultation – we:
  • advertised through our e-alert and twitter accounts and sent emails to over 300 organisations alerting them and asking them to publicise through their networks.
  • asked the Improvement Service to forward information on the consultation to their Community Council Liaison Network. They also published an article on their website.
  • wrote to the lead partners of the NPF3 National Developments that were not being re-proposed, and to community councils where they could be identified.
• Public consultation
  • The written public consultation was launched on 10 November 2021 and closed on 31 March 2022.
  • The consultation asked 70 open questions.
  • The consultation responses are available online, where consent has been given to publish the response.
  • Following the consultation and the end of the Parliamentary scrutiny process, we commissioned independent consultants to analyse the responses.
  • In total 761 responses were analysed, with 539 responses from organisations and 222 from individual members of the public. Late responses were considered but not covered within the Analysis Report.
  • The Analysis Report is also available online. The report provides an executive summary and sets out some general themes raised by respondents, followed by a question-by-question analysis of the comments made to the main consultation. Summaries of Representations from the Analysis Report are provided within this Report.
  • There are a wide range of views on NPF4. However, the vast majority of people who have engaged in the draft NPF4 welcome its aims and ambition. Their comments focus on how we can best achieve those outcomes, rather than asking for a change of direction.
  • The Analysis Report notes that as with any public consultation exercise, it should be noted that those responding generally have a particular interest in the subject area and the views they express cannot be seen as representative of wider public opinion.
• Climate Change Committee (CCC)
• A letter from the Climate Change Committee Chief Executive was also received, sent to the Minister for Public Finance, Planning and Community Wealth on Draft NPF4. Key messages from the CCC "The broad vision of NPF4 is generally compatible with advice from the Climate Change Committee. The plan also shows welcome progress on recommendations that the CCC has made over the past two years.
  • Infrastructure decisions made today will substantially determine the achievement of the statutory climate goals in years to come. The CCC welcomes, therefore, the alignment between NPF4 and the Infrastructure Investment Plan.
  • NPF4 focuses more on the vision for Scotland than on the types of planning applications that should or should not be supported. Much will rest on local implementation, so local policies and development plans must be well-aligned with the new Framework. It is unclear how the Scottish Government will ensure compliance with NPF4."

Parliamentary scrutiny

The Draft NPF4 was laid in Parliament on 10 November 2021 for the Parliamentary scrutiny period of 120 days.

Timeline overview, further details below

Local Government, Housing and Planning Committee (LGHP)

This was the lead Committee in the consideration of Draft NPF4. Evidence Sessions held by the Committee provided further insights on views on key issues these covered:

• 1. Planning (RTPI Scotland, Built Environment Forum Scotland, Planning Democracy, Royal Incorporation of Architects in Scotland, Planning Aid for Scotland) at the session held on 25 January 2022
• 2. Housing (Association of Local Government Chief Housing Officers, Scottish Land Commission, Homes for Scotland, Scottish Property Federation, Scottish Housing with Care Task Force) at the session held on 1 February 2022
• 3. Local Government issues (Heads of Planning Scotland, RTPI Scottish Young Planners' Network, Glasgow City Council, Convention of Scottish Local Authorities, South Ayrshire Council, Aberdeen City Council, Shetland Islands Council) at the session held on 8 February 2022

The Local Government, Housing and Planning Committee's Report on the draft National Planning Framework 4 (March 2022)

The Committee welcomed NPF4 and its ambition for Scotland. To best deliver on these ambitions the Committee highlighted a number of key areas, noting an overarching issue is resourcing and the capacity of the current planning system to deliver on the aims of NPF4.

• Comments on use of language, detailed wording and the priority or weight to be given to different policies in NPF4.
• Support was expressed by the Committee for the prominence given to the climate emergency in NPF4, and that it would also welcome the Scottish Government's reflections on the concerns expressed by the Climate Change Committee and in particular, how NPF4 will match ambition with action.
• The Committee raised important points around key policy areas, including 20 minute neighbourhoods, renewable energy, town centres and housing numbers.
• The Committee also commented on the importance of monitoring and evaluation. This is an important part of the planning system, reflected in the changes we are making to Local Development Plans (LDPs) to be informed by thorough 'evidence reports'. And it is also in how we are moving to a more outcomes-focused performance management system for planning.

Net Zero, Energy and Transport Committee (NZET)

The Net Zero, Energy and Transport Committee also considered the Draft NPF4, taking into account responses to the call for written views, led by the LGHP Committee and also took evidence at two meetings in February 2022.

It took evidence on the following issues:

• Energy, and in particular renewables and heat in buildings and homes;
• Transport and active travel;
• The environment and biodiversity; and
• Waste management and the circular economy.

On 4 March 2022 the Convener, Dean Lockhart MSP, sent a letter to the Convener, Local Government, Housing and Planning Committee, setting out the NZET Committee's views and suggestions.

Rural Affairs, Islands and Natural Environment Committee (RAINE)

Evidence Sessions held by the Committee on 9 February 2022 with Mairi Gougeon MSP, Cabinet Secretary for Rural Affairs and Islands, and Tom Arthur MSP, Minister for Public Finance, Planning and Community Wealth, they were accompanied by Scottish Government officials: the Chief Planner, the Head of Planning Transformation, the Branch Head of Environment and Natural Resources, the Head of Aquaculture Development and the Head of Rural Economy and Communities Division.

The evidence session raised a number of rural issues:

• Rural engagement to develop the draft, opportunities to engage in the consultation and 20 minute neighbourhoods/rural and island context;
• Rural housing;
• Accessibility of rural areas/transport;
• Infrastructure – using existing infrastructure;
• Growth of rural populations;
• Homeworking (digital infrastructure)/learning from the pandemic;
• How the islands fit with Action Areas;
• Fuel poverty; and
• Just transition.

On 23 February 2022 the Convener Finlay Carson MSP sent a letter to the Convener of the Local Government, Housing and Planning Committee, setting out the RAINE Committee's scrutiny of Draft NPF4.

Health, Social Care and Sport Committee

Evidence was also taken at the Health and Social Care Committee meeting on 25 January 2022 from the Improvement Service, University of Edinburgh and Public Health Scotland. The Committee noted the significant impacts of planning on health and wellbeing, both positive and negative, and recommended that this is highlighted in both NPF4 and its associated guidance on local development planning. Local elected member training was also recommended.

On 24 February the Convener, Gillian Martin MSP sent a letter to the Convener of the Local Government, Housing and Planning Committee, setting out the Committee's scrutiny of Draft NPF4.

Cross Party Group on Sport, 22 February 2022

Attended by the Minister for Public Finance, Planning and Community Wealth, who presented on the Draft NPF4, heard views of the Group and answered questions.

Debate

On 19 April 2022, MSPs debated and agreed motion S6M-03985, in the name of Ariane Burgess:

"That the Parliament agrees that the Local Government, Housing and Planning Committee's 4th Report, 2022 (Session 6), National Planning Framework 4 (SP Paper 149), on the Scottish Government document, Scotland 2045: Our Fourth National Planning Framework, the letters from the Health, Social Care and Sport Committee, Net Zero, Energy and Transport Committee and Rural Affairs, Islands and Natural Environment Committee included within that report and the Official Report of the Parliament's debate on the report and letters, should form the Parliament's response to the Scottish Government on the proposed framework."

Impact Assessments

A number of statutory and non-statutory assessments informed the preparation and finalisation of NPF4 and we invited comments on our Integrated Impact Assessment (IIA) Reports alongside the Draft NPF4.

Representations on the IIA are also considered in the Analysis Report.

A Post-Adoption Statement that sets out how the assessment findings, as well as the consultation responses received, have informed the development of the final Framework, will also be published.