National Planning Framework 4: integrated impact assessment post adoption statement

8. Appendix A – Fairer Scotland Duty Assessment Template

8.1. Template details

8.1.1 Title of policy: National Planning Framework 4

8.1.2 Lead Minister: Minister for Public Finance, Planning and Community Wealth

8.1.3 Lead official: Cara Davidson

8.1.4 Directorate: Local Government and Communities

8.1.5 Division: Planning, Architecture and Regeneration

8.1.6 Team: Planning Transformation

8.2. Stage 1 - Planning

8.2.1 NPF4 will guide the development and use of land to 2045. Forming part of the development plan, it will inform day-to-day planning decision making. It will guide local development plans, will be important for communities as they develop their Local Place Plans, and provide a framework for the development of regional spatial strategies.

8.2.2 NPF4 is linked to the outcomes of the National Performance Framework^[39]. In keeping with our national outcomes and with the United Nations (UN) Sustainable Development Goals (SDGs), NPF4 sets out the following overarching spatial principles to guide our future places:

• Just transition. We will empower people to shape their places and ensure the transition to net zero is fair and inclusive.
• Conserving and recycling assets. We will make productive use of existing buildings, places, infrastructure and services, locking in carbon, minimising waste, and building a circular economy.
• Local living. We will support local liveability and improve community health and wellbeing by ensuring people can easily access services, greenspace, learning, work and leisure locally.
• Compact urban growth. We will limit urban expansion so we can optimise the use of land to provide services and resources, including carbon storage, flood risk management, blue and green infrastructure and biodiversity.
• Rebalanced development. We will target development to create opportunities for communities and investment in areas of past decline, and manage development sustainably in areas of high demand.
• Rural revitalisation. We will encourage sustainable development in rural areas, recognising the need to grow and support urban and rural communities together.

8.2.3 By applying these spatial principles, NPF4 will support the planning and delivery of: Sustainable places, where we reduce emissions, restore and better connect biodiversity; liveable places, where we can all live better, healthier lives; and productive places, where we have a greener, fairer and more inclusive wellbeing economy.

8.2.4 NPF4 is required by law to contribute to 6 outcomes, including:

• Meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people;
• improving the health and wellbeing of people living in Scotland;
• increasing the population of rural areas of Scotland;
• improving equality and eliminating discrimination;
• meeting any targets relating to the reduction of emissions of greenhouse gases, within the meaning of the Climate Change (Scotland) Act 2009, contained in or set by virtue of that Act; and,
• securing positive effects for biodiversity.

8.2.5 NPF4 includes planning policies on key issues supporting people's lives such as: engagement, local living, housing, spaces and places, work and inequalities, health and wellbeing and connectivity. It therefore has the potential to impact all people and businesses across Scotland.

8.2.6 Having considered that NPF4 is a strategic document, a Fairer Scotland Duty assessment was undertaken alongside the development of NPF4 and a draft written assessment published^[40] to accompany the November 2021 Draft NPF4. This document sets out a final written assessment to accompany the adopted NPF4.

8.3. Stage 2 - Evidence

8.3.1 In January 2020 we published our NPF4 Integrated Impact Assessment Screening/ Scoping Report^[41] setting out an initial evidence base and inviting comments. A draft Fairer Scotland Duty assessment was published alongside the November 2021 Draft NPF4^[42] and sets out the detailed evidence base used in the assessment.

8.3.2 Responses to engagement and consultation of the Draft Fairer Scotland Duty Assessment: Particular aspects of the Impact Assessment that were welcomed included the recognition that income is a strong determinant for people's ability to respond to, and recover from, climate change impacts and that our future places and spaces need to contribute to improving equality and eliminating discrimination. It was also noted that the assessment identified a number of key policies which will help tackle inequalities and poverty, including NPF4's spatial strategy, thematic policies and proposed national developments.

8.3.3 There was a concern from some that the draft NPF4 had an urban bias, or specifically that it was biased towards the Lothians. It was considered that there was an associated need for equality of access to services across Scotland, including through necessary and timely investment, for example in digital and transport infrastructure. A full independent analysis of responses to the draft NPF4 consultation is available on the Scottish Government website^[43].

8.3.4 Updated evidence base reflecting the Resource Spending Review Equality and Fairer Scotland Statement: In addition to the evidence set out in the draft assessment, the Resource Spending Review (May 2022) was accompanied by an Equalities and Fairer Scotland statement^[44] setting out how the Scottish Government will address the key challenges and realise the opportunities to tackle inequality, promote human rights, and build a fairer Scotland through the Resource Spending Review. It set out nine medium term challenges and opportunities and considered the nine strategic opportunities and challenges flowing from previous Equality and Fairer Scotland Budget Statements, and explained how the Scottish Government will address these.

8.4. Stage 3 – Assessment and Improvement

8.4.1 The purpose of this section is to set out how the policy changes in the NPF4 as adopted have the potential to impact on inequality caused by socio-economic deprivation.

8.4.2 People living in the most deprived areas and neighbourhoods are more exposed to environmental conditions and other factors that negatively affect health and access to opportunities – including those relating to transport, access to green space, pollution effects, housing quality, fuel poverty, community participation, and social isolation. To achieve a net zero, nature-positive Scotland, NPF4 rebalances our planning system so that climate change and nature recovery are the primary guiding principles for all our plans and all our decisions.

8.4.3 For people on low incomes, this is a strong determinant for people's ability to respond to and recover from climate change impacts.

8.4.4 Our future places and spaces need to contribute to improving equality and eliminating discrimination by addressing the environmental conditions and other factors that negatively affect health and access to employment opportunities. Connectivity is also an important factor (both digital and transport) as well as access to green space, pollution effects, housing quality, fuel poverty and community participation. The planning system should support decisions that improve equality and help to eliminate discrimination, with a fairer, more inclusive and equalities based approach. NPF4 as adopted has the potential to impact upon people across the whole of Scotland irrespective of their socio-economic status. NPF4 can help tackle inequalities in this broadest sense by:

8.4.5 Actively planning future development in a way that helps us to reduce emissions and minimises the need to travel by unsustainable modes: NPF4 supports developments that prioritise walking, wheeling, cycling and public transport for everyday travel and reduces the need to travel unsustainably. NPF4 sets out that local development plans should aim to reduce the need to travel unsustainably by prioritising locations for future development that can be accessed by sustainable modes. Proposals to improve, enhance or provide active travel infrastructure, public transport infrastructure or multimodal hubs will be supported.

8.4.6 Promoting innovative place-based solutions to reflect a new approach to localism, including 20 minute neighbourhoods: Local living provides the opportunity to reduce the need to travel unsustainably, promote and facilitate walking, wheeling and cycling, improve access to services, decentralise energy networks and build local circular economies. As an integral part of this, cleaner, safer and greener places and improved open spaces will build resilience and provide wider benefits for people, health and biodiversity, in a balanced way. Virtual connectivity and active travel links will also be important.

8.4.7 New policies to improve air quality alongside reducing climate change emissions: Development proposals that would result in a significant adverse effect on air quality will not be supported.Development proposals will consider opportunities to improve air quality and reduce exposure to poor air quality.

8.4.8 Ensuring that the full range of policies and proposals included in NPF4 will work together to support a fairer, more inclusive and equalities-based approach to planning in the future: Human rights and equality considerations are embedded in decision making. Support is provided for development that will help to ensure human rights are maintained, for example: Policy 16 on quality homes which addresses the need for accommodation for Gypsy/Travellers and Travelling Showpeople yards, as well as homes for older people and disabled people; More broadly the cross-cutting outcome for 'A Fair and Inclusive Planning System' is clear that throughout the planning system, opportunities are available to engage in development planning and decisions about future development and that we expect everyone involved in planning to take steps to ensure that a wide range of people are involved in shaping their future places.

8.4.9 Refocusing our planning for housing policies on quality and place, so that the needs of everyone, including older people and disabled people, can be met. We have strengthened requirements for affordable housing provision and have included policies that help to diversify delivery and reflect the future needs and aspirations of communities: NPF4, including the changes introduced by Policy 16, supports the delivery of more high quality, affordable and sustainable homes, in the right locations, providing choice across tenures that meet the diverse housing needs of people and communities across Scotland.

8.4.10 Supporting quality homes in places that would benefit from them, including town centres, rural and island communities, brownfield and vacant and derelict land, and adaptation and re-use of disused properties: NPF4 policies encourage, promote and facilitate the reuse of brownfield, vacant and derelict land and empty buildings, helping to reduce the need for greenfield development.

8.4.11 Ensuring our communities benefit from accessible, high quality blue, green and civic spaces: NPF4 supports protection and enhancement of blue and green infrastructure and their networks, as well as providing good quality local opportunities for play, recreation and sport to ensure our places are greener, healthier, attractive, nature positive and more resilient to the effects of climate change. Development proposals for space or facilities for local community food growing and allotments will be supported.

8.4.12 Reducing the need to travel unsustainably by embedding the Sustainable Travel and Investment Hierarchies into decisions: The spatial principles which shape NPF4 aim to support more compact growth and the reuse of land within settlements, thereby supporting the use of existing infrastructure such as public transport networks. The Infrastructure First policy is consistent with, and effectively applies the sustainable travel and investment hierarchies into planning and decision making. NPF4 also states that local development plans should aim to reduce the need to travel unsustainably by prioritising locations for future development that can be accessed by sustainable modes. The spatial strategy should reflect the sustainable travel hierarchy and sustainable investment hierarchy by making best use of existing infrastructure and services. NPF4 promotes the value of good design in creating great places and reflecting the six qualities of successful places. Local development plans are required to be underpinned by the six qualities of successful places. The Place Standard is also highlighted as a tool to facilitate engagement in planning.

8.4.13 Promoting and facilitating a new strategic approach to economic development that also provides a practical model for building a wellbeing economy at local, regional and national levels: Policies support community wealth building and economic development that will help to deliver employment and supply chains, and support community ownership and management of buildings and land. NPF4 states that local development plans should allocate sufficient land for business and industry. This should take account of local economic strategies and support broader objectives of delivering a low carbon and net zero economic recovery, fairer and more inclusive wellbeing economy.

8.4.14 Encourage, promote and facilitate the rollout of digital infrastructure across Scotland to unlock the potential of all our places and the economy: NPF4 sets out that local development plans should support the delivery of digital infrastructure, including fixed line and mobile connectivity, particularly in areas with gaps in connectivity and barriers to digital access.

8.4.15 Actions to tackle child poverty: NPF4 recognises that disadvantage, child poverty and poor health outcomes are concentrated in parts of Scotland where life expectancy is significantly lower than in more advantaged areas. It recognises the spatial implications of child poverty and responds to spatial analysis showing areas where child poverty is concentrated. As well as giving spatial prioritisation, the NPF4 policies are designed to support a well-being economy and can therefore help to tackle child poverty.

8.5. National Developments

8.5.1 National developments are those that strongly support the delivery of the spatial strategy, i.e. are 'needed'. Their identification is helpful to those delivering and hosting them including: public, commercial, and third sector bodies; and communities.

8.5.2 The national developments contained in NPF4 are aligned to wider Scottish Government policy objectives as well as the aims of the spatial strategy.

8.5.3 Over 250 national development suggestions were received and were considered against four criteria.

• Climate change: The development will help to reduce emissions, contributing to Scotland's target of net zero emissions by 2045, will be emissions neutral, or emissions negative.
• People: The development will support the health, wellbeing, sustainability, and quality of life of our current and future population.
• Inclusive Growth: The development will contribute to sustainable economic growth that helps to reduce poverty and inequality across Scotland.
• Place: The development will protect or enhance the quality of a place or improve biodiversity.

8.5.4 NPF4 identifies 18 national developments, further information on relevant national developments is included in stage 4 below.

8.6. Stage 4 - Decision

8.6.1 The Scottish Government made a number of changes in light of the feedback received on the Draft NPF4. Key changes relevant to this assessment are set out below.

8.6.2 Confirmation that the purpose of planning is to manage the development and use of land in the long term public interest: The adopted NPF4 is consistent with the statutory purpose of planning and makes more explicit the planning system's contribution to the delivery of the National Performance Framework and its outcomes and indicators.

8.6.3 Confirmation that planning should respect, protect and fulfil human rights, seek to eliminate discrimination and promote equality: To respond to stakeholder views, universal policies have been removed to focus on climate emergency/nature crisis. Human Rights and Equality now cited as a cross-cutting outcome under 'A Fair and Inclusive Planning System'.

8.6.4 A policy on community wealth building which provides opportunities that deliver local growth and wellbeing, within an economy that is inclusive and that promotes sustainability, prosperity and resilience: This policy has been updated to provide criteria to assess proposals against and to improve definition. Spatial strategies should support community wealth building; address economic disadvantage and inequality; and provide added social value. Local development plans should address community wealth building priorities by reflecting a people-centred approach to local economic development.

8.6.5 An updated and simplified policy on design, quality and place requiring plans to reflect the six qualities of successful places: The policy on design, quality and place now sits in 'Liveable Places' and is more closely aligned with the set of policies that support liveability and improve the quality of life for everyone. The six qualities of successful places have been reviewed to more clearly reflect the key elements that constitute good design, ensuring places are consistently designed to be healthy, pleasant, distinctive, connected, sustainable and adaptable.

8.6.6 Updated policy on local living and 20 minute neighbourhoods: This policy has been revised to be more flexible by referring to the principles of local living more broadly, as well as the specific solution of delivering 20 minute neighbourhoods. This will allow the policy to be more readily applied to all parts of Scotland, providing benefits for communities in a wide range of contexts, including rural areas.

8.6.7 An updated approach to providing quality homes: Housing creates and supports jobs and drives inclusive economic growth and social benefits. Housing's unique place at the heart of thriving communities means that investment in housing, and all the indirect effects that flow from that, can contribute to community wealth and social renewal. Living in poverty, or on a low income and with little or no wealth restricts housing choices, presents affordability challenges and increases the likelihood of experiencing fuel poverty and the risks of homelessness. Affordable housing policy has been strengthened to require at least 25% of market sites to be delivered as affordable housing.

8.6.8 An updated policy on sustainable transport and active travel: Poor service coverage, reliability, and or affordability of public transport discourage people in low income to commute to employment sites, reinforcing socio-economic disparities. This is compounded by the fact that poor service coverage is more likely in deprived communities. The policy has been reframed to focus on positive changes to support sustainable modes, rather than focusing solely on a reduction of unsustainable travel. The policy has been supplemented to make reference to including equalities groups in the earliest stages of decision making. Further consideration has been given to the applicability of the policy in rural areas. Related national developments include: a National Walking, Cycling and Wheeling Network; and Urban Mass/Rapid Transit Networks.

8.6.9 An updated and expanded policy on heat and cooling: We recognise that addressing fuel poverty will require greater energy efficiency and affordable, low carbon, distributed heat and electricity networks. Policies encourage, promote and facilitate development that supports decarbonised solutions to heat and cooling demand and adaptation to more extreme temperatures.

8.6.10 Revised NPF4 policies 'Blue and green infrastructure', and 'Play, recreation and sport': For adults in the 20% most deprived areas, the proportion who are within a five minute walk of a green or blue space had increased from 55% in 2016 to 62% in 2019. People living in the most deprived areas are less likely to live within a 5 minute walk of their nearest greenspace than people in less deprived areas. For adults, 26% of adults in the most deprived areas were at a healthy weight, compared to 38% of those in the least deprived areas. For children, the trend was similar, with 62% of children in the most deprived areas at a healthy weight, compared to 76% of children living in the least deprived areas. Blue and green infrastructure can support lifelong health and wellbeing, climate resilience, flood risk management, temperature regulation in urban areas, reduction of air and noise pollution, biodiversity and nature networks, while also supporting good, green jobs. Accessible, high quality natural and civic spaces can be used by communities for many activities: exercise and recreation, play, sport and connecting with nature. Outdoor spaces for play, recreation and sport can make a significant contribution towards creating more liveable and healthier places. Children experience a range of health, wellbeing and educational benefits from outdoor play, and learning in, and connecting with nature. We have separated blue and green infrastructure (BGI) policy from play and sport in recognition of their different roles and to better reflect their respective importance in ensuring wellbeing for the environment, place and people. The separate policy on play, recreation and sport reflects the importance of outdoor leisure opportunities for people of all ages. Related National development: NPF4 contains a national development for a Central Scotland Green Network.

8.6.11 A revised NPF4 Policy 'Health and safety': Places are important for physical and mental health and overall wellbeing. The provision of health and social care facilities and infrastructure to meet the needs of the community should be a key consideration. This policy has been reviewed to clarify the role of the development plan and development management. Links are made to exercise and food growing. Suicide risk is a new element included in the policy. Makes clear the cross-cutting nature of health and makes explicit links to a wide range of policies such as natural environment, housing, transport, blue and green infrastructure and play.

8.6.12 Revised NPF4 Policy 'Business and industry': Having paid work is an effective way out of poverty, and those families where all adults are in full-time work have a low poverty risk. One of the three main drivers of child poverty reduction is to increase household incomes through work. Fair Work is also crucial to eradicating child poverty by providing flexible job opportunities that respect caring responsibilities and other commitments workers may have. This policy has been restructured and the policy intent contributes to wider goals such as the wellbeing economy and community wealth building.

8.6.13 Supporting the provision of appropriate, universal and future proofed digital infrastructure: Being older or disabled, living in a deprived area or living in social housing are risk factors for exclusion from access to digital services. Digital policy has been updated, supporting the provision of appropriate, universal and future proofed digital infrastructure so that all parts of Scotland have access to suitable digital infrastructure to eliminate the digital divide; a sharp focus is given to delivery of digital infrastructure in remote and rural areas and areas with no or low connectivity. Related National Development: NPF4 contains a national development for a Digital Fibre Network.

8.6.14 Encouraging the reuse of land and buildings: 55% of people living in the most deprived decile in Scotland are estimated to live within 500 metres of derelict land, compared to 11% of people in the least deprived decile. There are numerous indicators that indicate that living in proximity to vacant and derelict land is associated with negative impacts on health and wellbeing. An updated and expanded policy on brownfield, vacant and derelict land and empty buildings which encourages re-use of land and buildings and limits the support for greenfield locations, unless they are specifically supported by the local development plan.

8.6.15 Areas with limited action being undertaken are set out below.

8.6.16 Public Toilets: Public toilets are particularly important for older people and disabled people, women and those with caring responsibilities, where a lack of toilets can prevent people from playing an active role in life. Requirements in the 2019 Planning Act set out that the LDP is to include a statement of the planning authority's policies and proposals as to the provision of public conveniences. NPF4 Policy 15 (Local Living and 20 minute neighbourhoods) states that consideration will be given to local access to publicly accessible toilets as part of the contribution of development proposals to local living. We consider this is best dealt with at a local level aligned with wider policies relating to local living and town centres.

8.6.17 Digital Connectivity: There are two aspects to inequality in digital access: inequality of digital skills and confidence, and inequality of digital resources. Whilst the planning system can support the roll-out of digital infrastructure, including through the Digital Fibre Network national development, without also addressing digital skills this may not lead to those in disadvantaged communities having greater access to digital services. Digital skills development lies beyond the scope of the planning system.

8.6.18 Public Transport and Connectivity: The Fairer Scotland Duty assessment^[45] accompanying National Transport Strategy 2 noted research from the Joseph Rowntree Foundation which found that access and affordability of public transport can be a concern for people on low income. This compounded by the fact that poor service coverage is more likely in deprived communities. The planning system cannot directly influence the affordability of public transport services. However, local living, the 20 minute neighbourhoods concept and support for active travel can support an alternative for some journeys. The spatial strategy aims to achieve balanced development and this includes supporting new development in areas where the market has previously shown less interest but where regeneration would help to overcome disadvantage. This, together with the broader policy approach, suggests that more mixed use development could help to better connect communities with employment, education and local facilities. Support is also provided through the NPF4 national development for: Urban Mass/Rapid Transit Networks. The finalised policy on transport was also updated to recognise the importance of involving a wide range of users in establishing accessibility issues, as well as the importance of a development's context in establishing transport requirements.

8.6.19 This Fairer Scotland Assessment template was signed off by Fiona Simpson, Chief Planner