NPF4 call for ideas: analysis of responses

Introduction

Context

The National Planning Framework (NPF) is a long-term plan for Scotland that sets out where development and infrastructure is needed to support sustainable and inclusive growth. The current framework - NPF3 - was published in 2014 and the Scottish Government has now begun a process of review and preparation of a new framework - NPF4.

NPF4 is expected to look very different to NPF3, with a longer time horizon to 2050, fuller regional coverage and improved alignment with wider programmes and strategies, including on infrastructure and economic investment. NPF4 will also incorporate Scottish Planning Policy so that, for the first time, spatial and thematic planning policies will be addressed in one place. It will have the status of the development plan for planning purposes. This is a change to the current position and will mean that its policies will have a stronger role in informing day-to-day decision making.

The Call for Ideas

The Scottish Government is committed to encouraging interest and wide public involvement in the preparation of NPF4 and is engaging with the public, community, voluntary and private sectors, as well as academics, experts and professional bodies. To this end, a Call for Ideas on NPF4 was launched on 9 January 2020, including a roadshow with workshop sessions in locations across Scotland. Individuals and stakeholders were invited to participate in workshop sessions and/or make a written submission. Workshops had to be curtailed as a result of the COVID-19 outbreak, by which point 13 locations around Scotland had been visited. Also in response to COVID-19, the deadline for submission of written responses was extended from 31 March to 30 April 2020.

The Scottish Government's Transforming Planning website^[1] provides a wide range of resources to support the NPF4 development process, including the early engagement stage. These resources include:

• 2050 Think Pieces - a collection of 35 think piece contributions on Scotland 2050 provided by planning stakeholders that are designed to stimulate discussion and debate during the early engagement period and to help stakeholders to think about priorities for NPF4.
• Scottish Planning Policy materials, including background information notes on the 32 policy topics that will need to be addressed when preparing the draft NPF4. These notes set out the existing planning policies, what has changed since they were introduced, a proposed key objective of NPF4 and a series of questions for consultees. The 32 policy topics are grouped under one of three themes. People covers how planning can support wellbeing ensuring communities have access to services and facilities; Work covers effective and efficient planning to support inclusive growth; and Place covers how planning can maintain and enhance the unique character and identity of our natural and built environment.
• Housing Technical Discussion Paper setting out the Scottish Government's current thinking on the methodology that could be used for setting 'targets for the use of land for housing in different areas of Scotland' as required in NPF4 by the Planning (Scotland) Act 2019.
• National Development factsheet, invitation and response form, with information covering the assessment criteria for assessing potential National Developments and how to make a suggestion.
• Regional Spatial Strategies factsheet covering the role and development of Regional Spatial Strategies and their relationship to NPF4.
• Integrated Impact Assessment Scoping Report to inform the data-gathering and early engagement stages of the NPF4 preparation process. The report sets out the various assessments to be undertaken to assess the impacts of NPF4 on the environment, society and equalities, and businesses.

While any ideas could be submitted, the Scottish Government noted that they were particularly interested to hear thoughts on five key issues namely:

• What development will we need to address climate change?
• How can planning best support our quality of life, health and wellbeing in the future?
• What does planning need to do to enable development and investment in our economy so that it benefits everyone?
• What policies are needed to improve, protect and strengthen the special character of our places?
• What infrastructure do we need to build to realise our long-term aspirations?

A number of further issues to think about accompanied each of the five questions.

Number and profile of respondents

In total, 328 respondents made a submission to the Call for Ideas that could be included within the analysis.^[2] The majority of respondents were organisations (259 respondents) with 69 individual members of the public also making a submission.

Organisational respondents have been allocated to one of eighteen categories by the analysis team and the Scottish Government.^[3] A breakdown of the number of responses received by respondent type is set out in Table 1 below and a full list of organisational respondents who agreed that their response should be published by name is provided at Annex 1.

Table 1

Respondents by type	Total
Active Travel-related Third Sector Organisation or Campaign Group	7
City Region or Strategic Development Planning Authority	3
Community Council or Residents Association	20
Culture or Heritage Company, Association or Representative Body	8
Development, Property or Land Management Company or Representative Body	30
Energy-related Supplier, Developer, Association or Body	49
Environment or Natural Heritage Third Sector Organisation or Campaign Group	20
Greenbelt Campaign Group	3
Local Authority	33
Planning, Architecture or Housing Representative Body or Campaign Organisation	7
Planning, Development, Architectural or Environmental Consultancy	8
Public Body, Commission or Taskforce	15
Third Sector, Community or Campaign Organisation	18
Transport Partnership	4
Transport-related Body, Association or Provider	15
Other Infrastructure-related Company or Representative Body	4
Other Private Sector	7
Other Representative Body, Faculty, Network or Academic Group	8
Total organisations	259
Individuals*	69
All respondents (for main analysis)	328

*Some responses were anonymised before being passed to the study team. This figure assumes all those responses were from individuals and no individual submitted more than one response.

All responses to be published are available from the Scottish Government's website.^[4] A small number of the responses submitted by organisations have been published anonymously. In these cases, organisations have been assigned an organisation type (and therefore are included in the figures set out in Table 1), but they are not listed at Annex 1.

Nature of submissions and analysis

The submissions received were very diverse, with variation based on focus, structure and length. They ranged from relatively brief statements primarily addressing one issue, through to very extensive submissions covering some or all of the following elements:

• Answers to some or all of the five key issues questions, sometimes including comments on some or all of the further issues to think about.
• Comments on one or more of the 32 policy topics for Scottish Planning Policy, sometimes including comments on the proposed objective of NPF4 and some or all of the questions for consultees.
• Detailed comments on the Housing Technical Discussion Paper, which often followed the structure of the Paper and addressed the particular questions set out within it. The submissions, and the resultant analysis, is somewhat different in style and level of detail to other sections of the report and is more along the lines of a standard consultation than other parts of the Call for Ideas.
• National Development suggestions. These were sometimes submitted on the relevant form, but were also submitted in other formats, including through the submission of business plan style documents. Some of these suggestions were also accompanied by other material, for example addressing the key issues questions, which focused on how the suggested National Development could contribute to meeting NPF4 objectives.

There were also statement style responses of varying length and complexity, addressing one or more issue but which did not refer directly to any of the elements described above.

• Some had been prepared and/or were submitted on behalf of a client by a third party, such as a planning consultant. These responses tended to be National Development suggestions or relate to electricity generation.
• A small number of responses took the form of feedback from workshop style events and were sometimes in annotated diagram form.

After an initial review of the submissions and following discussions between the Scottish Government and the analysis team, all materials were entered into a spreadsheet in preparation for the main analysis phase. If it was not possible to include any material, for example because of the use of diagrams or maps, a cross reference to the original submission was added.

The spreadsheet was structured primarily around the 32 policy topics with any materials relevant to one of those policy topics extracted from the submission and recorded under that topic. In addition, where respondents had addressed one or more of the five key issues questions, their answers were also recorded under those questions. The spreadsheet also recorded where National Development suggestions had been made, and any comments on the Housing Technical Discussion Paper, the Integrated Impact Assessment Scoping Report or on Regional Spatial Strategies.

Report structure

Given the volume and complexity of materials submitted, this report aims to give an overview rather than representing all issues covered. It seeks to avoid repetition where possible, although the comments made at the key issues questions often reflected themes covered by one or more of the policy topics.

It is not expected that all readers will read the full report in sequence and it is structured to allow any section to be read as a stand-alone analysis, but with cross references to related material in other sections where appropriate.

The remainder of this report is structured as follows:

• Summary of key issues - This part of the report gives a brief, summary overview of themes raised at the five key issues questions.
• People - This part of the report covers 10 policy topics: Community facilities; Culture and the arts; Digital connectivity; Green infrastructure; Gypsy Travellers; Health; Housing - Affordable; Housing - General; Housing - Specialist; and Waste.
• Work - This part of the report covers 8 policy topics: Aquaculture; Business and employment; Energy - Electricity; Energy - Heat; Mineral extraction; Rural development; Tourism; and Town Centres.
• Place - This part of the report covers 14 policy topics: Air quality; Climate change; Coastal planning; Flooding; Green belts; Historic environment; Infrastructure; Land assembly and compulsory purchase; Natural environment; Peatland; Placemaking; Sustainability; Transport; and Vacant and derelict land.
• Housing Technical Discussion Paper - This part of the report covers issues raised by respondents about the paper.
• National Developments - This part of the report gives a brief overview of the number and range of National Development suggestions made.
• Integrated Impact Assessment - This part of the report provides a summary analysis of comments made about the Integrated Impact Assessment report.

As noted above, it is not expected that all readers will wish to read the full report in sequence. Given this, please note that The Planning (Scotland) Act 2019 is referenced throughout as 'the 2019 Act' and that the abbreviations used throughout the report are presented in Table 2 below but have not been given in full at first use.

Table 2 - Abbreviations used

Abbreviation: Definition

CCS: Carbon Capture and Storage
CHMA: Centre for Housing Market Analysis
EFW: Energy from Waste
EIA: Environmental Impact Assessment
IIA: Integrated Impact Assessment
ISP: Internet Service Provider
HIA: Health Impact Assessment
HLA: Housing Land Audit
HMA: Housing Market Area
HMP: Housing Market Partnership
HNDA: Housing Need and Demand Assessment
HSCP: Health and Social Care Partnership
LDP: Local Development Plan
LHEES: Local Heat and Energy Efficiency Strategy
LHS: Local Housing Strategy
LPA: Local Planning Authority
LPP: Local Place Plan
NPF: National Planning Framework
NTS2: National Transport Strategy 2
NRS: National Records of Scotland
PAN: Planning Advice Note
PAS: Publicly Available Specification
PSED: Public Sector Equality Duty
PV: Photovoltaic
RSL: Registered Social Landlord
RSS: Regional Spatial Strategy
RTIF: Rural Tourism Infrastructure Fund
SDP: Strategic Development Plan
SEA: Strategic Environmental Assessment
SEPA: Scottish Environment Protection Agency
SNH: Scottish Natural Heritage
SPP: Scottish Planning Policy
STPR2: Strategic Transport Projects Review 2
SuDS: Sustainable Drainage System
VDL: Vacant and Derelict Land