NPF4 call for ideas: analysis of responses
Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.
Rural development
Proposed key objective of NPF4: To promote rural development that supports prosperous and sustainable communities and businesses whilst protecting and enhancing environmental quality.
With respect to rural development there were calls for:
- Clear direction regarding the objectives of rural planning policy, linked with national land use policy to support objectives around inclusive economic growth and depopulation of remote rural areas.
- Planning authorities with rural areas to be required to develop specific rural development and rural planning policies that take account of the needs and nature of rural areas.
- 'Island proofing' of NPF4 to ensure that the new framework takes account of island circumstances.
- Guidance on major industrial developments in remote rural areas. The current debate around remote rural locations for a space hub was suggested as an example of where a national planning framework should be the key determining factor in planning casework.
- Thinking about development in the broadest sense as including green and blue infrastructure and including 'ecological restoration' as a category for development in NPF4.
- Identification of how nature-based solutions can underpin and support rural development in RSSs and LDPs.
- Additional training on rural planning and development for officers and officials.
Some Local Authority respondents commented on individual recommendations made in 'Rural Planning Policy to 2050', a research study carried out in 2019 for the Scottish Government.
NPF4 and the Land Use Strategy
It was noted that the character of Scotland's rural landscapes is only partly influenced by built developments and significant change can be caused by land uses such as agriculture and forestry that are not controlled by the statutory planning system. Therefore, it was argued NPF4 should sit explicitly within the overall framework provided by the Land Use Strategy, and that a clear explanation of the relationships between the Land Use Strategy, NPF4 and their respective regional implementation mechanisms must be provided.
There were also calls for:
- NPF4 to seek to coordinate closely with the Land Use Strategy and forthcoming Regional Land Use Frameworks.
- Landscape-scale restoration as a model for development plans that could help to co-ordinate policies across planning, land use and land reform agendas through Regional Land Use Frameworks.
Increasing the population in rural areas
There was support for using the planning system to stem depopulation in sparsely populated areas, although it was also argued NPF4 should be clear that encouraging people to live in rural areas relates to remote areas where population decline is an issue, while accessible areas close to towns and cities require continued protection from unsustainable development. It was proposed NPF4 should identify and promote depopulated areas in which repopulation is an objective. Having accurate, up-to-date information on population changes in individual areas was thought to be important.
Among requirements highlighted as necessary for rural populations to be maintained or increased were:
- A balanced population profile, with economically active people encouraged to live in the area.
- Sufficient housing, particularly in areas where there is under supply.
- Employment and educational opportunities, with an associated requirement for good digital connectivity.
- Other infrastructure, including with respect to transport, schools, shops, access to healthcare services and community facilities.
The need for a strong emphasis on how to bring multiple benefits to depopulated areas was suggested as was a rural infrastructure first approach, with longer term strategic planning to address issues such as transportation, health and education. Stronger links between planning, housing, infrastructure and economic policies were argued to be necessary if ambitions for rural areas are to be successful.
The availability of land was argued to be critical to securing long-term renewal of remote rural populations and it was suggested NPF4 must have regard for any Land Rights and Responsibilities Statement or strategy for land ownership or use prepared by Ministers.
The need to balance a desire for rural development against potential impacts on the countryside and on wildlife was also highlighted, and it was noted a reduced population in areas that are heavily dependent on private car use can have a positive impact in lowering carbon emissions. Greater emphasis on the sustainable element of the key objective was suggested, and an indication of how important the goal of populating rural areas is in relation to the impacts on the environment needed to achieve it.
It was also argued rural development should not be considered unsustainable because car journeys are required and that making private car journeys carbon neutral is an achievable goal for Scottish Government. A rural-first approach to roll-out of electric vehicle charging infrastructure was suggested.
Classifying rural areas
It was suggested important to continue to differentiate between different types of rural areas, and to recognise that rural areas close to towns and cities may experience very different pressures, including concerns of an increase in ad hoc residential development, or creating commuter housing in attractive areas of countryside.
It was recommended that:
- Different types of rural area should be clearly defined in NPF4, and related policy should be more prescriptive about the types and scales of development that should be permitted.
- NPF4 should provide a broad policy framework for each rural typology, within which planning authorities should have the freedom to set down detailed, locally sensitive criteria in LDPs.
- If the intermediate area is to be retained, then guidance is required to allow planning authorities to identify this area within their plans.
- Island and Sparsely Populated Areas should be represented as distinct types of rural area.
- Classification could be improved by being evidence-based, allowing development of place-specific policies which would provide appropriate support and guidance for each of the rural areas.
- Classifications that indicate the dominant/primary income streams or industries/sectors supporting different rural communities would be useful. These classifications could be used in Regional Land Use Frameworks and could help incentivise the right developments in the right locations.
A clear methodology for helping authorities to characterise the different parts of their area was also suggested to be useful and there was a call for better protection and management of rural landscapes - not only those designated as protected landscapes but also the wider countryside.
More permissive policies to support sustainable development
It was suggested care is needed if considering a more permissive approach and that a 'one-size-fits-all' national approach will not be appropriate. Policies that are too permissive were argued to risk eroding the character of the countryside and harming the environment.
It was also argued that the planning system should include a presumption in favour of sustaining rural populations and should be more flexible and less demanding in rural areas. Planning should recognise challenges of development in the rural context and take flexible approaches to allow challenges to be overcome. In particular, it was argued development should be enabled in some areas which have not previously been considered suitable, giving much more weight to impact assessments in the decision-making process.
Other suggestions included:
- Mechanisms encouraging mixed use proposals in rural areas should be promoted.
- A more permissive policy approach is required for settled rural areas in order to support and facilitate development, balanced with more management in the remoter areas, out-with settlement and offshore unhabituated islands.
- A move away from a policy position of preventing the expansion of those settlements with an identified settlement boundary towards a more individual place-based approach.
Supporting local businesses to develop and diversify
There was a call for planning to support the viability of land-based industries wherever possible including to help businesses, land managers and farmers expand or start new enterprises. It was argued that traditional land-based industries continue to play an important role, especially in remote and sparsely populated areas and their development should be supported.
It was also suggested that rural and island areas should be promoted as centres of excellence and innovation for 'non-traditional' rural sectors that champion environmental sustainability.
As in other contexts there were calls for improved digital connectivity as a means of supporting local businesses in rural areas and as providing the capacity to work from home.
There were calls for a focus on food production, integration of food into the planning system and for greater protection for agricultural land. Specifically, it was suggested that:
- Wording in current SPP which allows development on prime agricultural land 'where it is essential as a component of the settlement strategy' should be removed in NPF4.
- Wording should be changed to include good agricultural land (class 3.2) specifically, instead of just prime agricultural land (classes 1 - 3.1).
- A soils framework could identify areas that can contribute the most to sustainable food production and ensure the planning system recognises their value.
It was also argued that SPP goes too far in protection of agricultural land, especially with respect to land that is not of prime quality.
The need for adoption of more sustainable farming practices was also argued, with suggestions including.
- Government support to enable farmers to access local markets.
- A network of research and demonstration sites for sustainable farming.
Application of a Natural Capital Protocol for land-based businesses was reported to have encouraged land managers to consider natural capital enhancing and low-carbon alternatives in decision making.
Proving funding mechanisms for a new Scottish Rural Development Programme that aims to deliver landscape quality outcomes, and increase partnership working and community-led innovation in relation to agricultural landscapes was also suggested.
Diversification
It was argued rural planning should be more permissive where there is a need for diversification as part of a pro-active, plan-led process that identifies key types and examples of development that will support diversification.
Clearer policy direction and initiatives aimed at removing barriers to diversifying the rural economy were also suggested. In crofting communities, it was thought there could be scope for diversification including farm shops, tourism accommodation or running rural skills workshops.
There should also be investment in nature-based solutions that should actively support land management sectors to diversify businesses so that they can benefit from enhancing nature and tackling climate change.
Supporting sustainable rural growth
It was argued rural development:
- Should continue to be sustainable, with a focus on how people access services and move about the area.
- Should focus on existing settlements where possible, sustaining town centres, and minimising the need for new infrastructure. A clear presumption that any new rural development will be located where it can help to sustain existing communities most effectively, with development focused on the use of existing buildings was proposed.
It was suggested NPF4 should support economic activity in and around locally designated areas considered suitable for employment-related developments, close to settlements which are accessible by walking/wheeling, cycling and public transport, or can be made so by planning conditions, or where redundant or underused buildings can be used.
Creation of sites for new micro-settlements which engender social and environmental benefits, foster mutuality and sharing (cars, energy production, food production, workspace) were also suggested to create affordable opportunities for people to remain, return and move to rural Scotland.
LPPs were suggested to have a potential role in allowing communities to instigate positive developments which help to sustain rural areas, such as growing local produce and supporting community businesses.
The benefits of giving communities more responsibility for the management of land was also suggested to be a key factor in encouraging people to stay in rural areas. A Public Body, Commission or Taskforce respondent noted their own project trialling an approach to devolving management and providing opportunities for the local authority or community groups to lead on the management of assets.
Supporting sustainable growth in the tourism sector
The importance of providing appropriate infrastructure to support increased tourism was noted and creation of the RTIF was welcomed. The need for infrastructure to support tourism involving motorhomes/campervans while also protecting and enhancing natural assets and providing opportunities for business development in rural areas was suggested.
It was argued that NPF4 should enable LDPs to create potential visitor development areas, which are guided by local need and viable opportunities. In particular, it was proposed there should be flexibility to utilise the landscape to provide increased opportunities for outdoor recreation in areas where there is no high-level protection, particularly in remote areas where there could be spin off benefits to support local communities.
Other suggestions included that there could be:
- Greater opportunities for sport and physical activity.
- Multiuse of windfarm land to connect with outdoor opportunities such as walkways and tourism centres focusing on wildlife and outdoor experiences.
- Opportunities around creative-tourism aspects of replenishment and sustainable utilisation of remote-rural native woodland. The more positive factors an enterprise can embody, the more it should be facilitated and encouraged by planning.
Policy on hutting and other recreational accommodation in rural areas
It was suggested that NPF4 should provide policies on hutting and other holiday accommodation in rural areas. Although the benefits of recreational huts were noted, it was suggested inconsistencies in the application of existing SPP policies have caused approval of hut developments to be very varied across the country. There were calls for:
- Explicit support for appropriate hut developments, with applications considered on their own merits, and irrespective of the contents of LDPs.
- More huts in rural areas, including to help reduce the amount of rural housing being converted into tourist accommodation.
While it was suggested that possible sites for hut developments might be identified within LDPs, it was also noted that this may be challenging given the higher returns likely to be achieved through other forms of leisure accommodation such as chalets.
The importance of assessing potential environmental impacts of any tourist-related developments and leisure accommodation were also highlighted, and that even developments appearing to have relatively insignificant impacts may carry a risk of disturbance to sensitive and protected species.
Balancing tourist accommodation and the need for rural housing
It was noted both that demand for tourist accommodation is not seen as a problem in all areas and that, in some places, second and holiday homes may also create housing shortages. It was suggested that:
- Area-specific problems caused by the short-term letting sector could be addressed through LDPs with strong support from NPF4.
- Clarity on use of occupancy restrictions would be welcome, as these could benefit rural populations having to compete for accommodation.
- Social housing provision needs to be considered where tourism makes house prices/rent levels unaffordable to the local population.
Role of housing
Broader issues relating to housing and to affordable housing in particular are covered elsewhere under the relevant themes. Points included below are more specific to rural or depopulated areas.
As a general point it was suggested national policy should support local authorities to have more prescriptive policies on the type of housing provided to ensure it meets what the local population needs and supports the rural economy. It was also argued that most local authorities have strict policies controlling or preventing rural development and that by making it easier and quicker to obtain planning permission for rural housing plots, NPF4 can help to bring more land to the market.
Shortages of suitable and affordable homes in rural communities were noted and a Local Authority respondent suggested that relaxation of housing in the countryside policy at LDP level would probably be the most effective way to increase housing numbers in rural areas. However, they also observed that, since some communities do not want additional growth, LPPs could identify where more housing would be welcome, with an LDP policy context that allows for this.
Where an area is depopulated to the extent that a community body is not in a position to prepare a LPP, it was suggested resources should be made available to the LPA to prepare a plan to be taken forward as part of the LDP.
It was suggested the process of identification of land for new homes can also be successfully initiated by a local community body, and housing delivered by collaboration between communities, landowners, local authorities, statutory agencies, funders and local housing providers.
A demand for housing outside settlements was suggested to be changing the character of some rural locations and it was argued NPF4 should address this issue in terms of landscape implications, habitat fragmentation and sustainable development. Strong discouragement of housing development in countryside areas was suggested and it was noted that dispersed development will be car dependent.
Contact
Email: scotplan@gov.scot
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