NPF4 call for ideas: analysis of responses

Placemaking

Key objective of NPF4: To deliver sustainable, well-designed places and homes that meet the needs of people living in Scotland including, in particular, the housing needs for older people and disabled people. This will be done through a design-led approach which demonstrates the six qualities of successful places

Importance of placemaking

Either as a statement of support for the proposed objective, or as part of wider comments, a number of respondents highlighted the key role of placemaking, including as central to the purpose of planning and integral to achieving many of the NPF Outcomes. There was a consensus that placemaking should remain central to NPF4, which should continue to identify the qualities of successful places in Scotland, particularly in terms of:

• Promoting multifunctional landscapes, with greenspaces, active travel options, renewable energy systems and thriving public spaces.
• Safeguarding and growing locally resilient and self-supporting communities which have local access to quality and appropriate facilities and services.
• Creating communities that can provide the context to encourage healthy lifestyles and which promote wellbeing. It was reported that the different functions of urban and natural environments all contribute towards quality of life and physical and mental health and are all components of the overall quality of place.
• Protecting and enhancing the unique character of our special places.
• Mitigating against climate change and improving biodiversity.
• Enabling alignment of economic development, land use planning, and transport and infrastructure investment.

General points around how the placemaking approach brings value included that:

• Placemaking connects many planning policy themes.
• Designing for people and place rather than engineering environments is key, and planning needs must be based on the needs of local communities.
• Placemaking is key to both delivering new development as well as regenerating existing communities.
• The Place Principle provides a shared understanding of place, it helps overcome organisational and sectoral boundaries, encourages better collaboration and community involvement, and improves the impact of combined resources and investment.
• The approach allows for greater cohesion and co-ordination across local authority areas. This should include at city region or RSS area level, through consideration of any cross-boundary issues.

Broader changes

In terms of how NPF or SPP may need to refocus or change in relation to placemaking, comments included that:

• NPF4 should focus on place outcomes and ensure these cannot be outweighed by other discrete policy outcomes.
• The emphasis/language used could sometimes be stronger. For example, with reference to directing the right development to the right place, the references to 'considering' the reuse or redevelopment of brownfield land or the contribution of green and open space networks, should instead refer to 'prioritising'.
• The emphasis should be on ensuring policy and planning is co-ordinated, consistent, and coherent across sectors. NPF4, the Land Use Strategy, Regional Land Use Frameworks, and the Forestry Strategy need to be better integrated.
• There should be a greater emphasis and alignment with health and wellbeing policies and outcomes. In particular, the articulation of the six qualities of a successful place^[29] would be a good starting point for ensuring the consideration of health and wellbeing is integral to planning decisions but may benefit from a more specific focus on health and wellbeing, including around another of the public health priorities concerning healthy weight and the 'food environment'.
• Planners and designers need to go further to harness and utilise the knowledge of communities and encourage active participation. Community engagement and participation is covered in more detail under the Sustainability theme.
• Policy needs to consider existing communities and how they can be supported. The current policy is more appropriate for new development.
• Equity is important, so it is misleading to focus on specific groups in the objectives (like older or disabled people, for example).

It was also suggested that the current policy seems more suited to cities, towns or large-scale development and that it is currently difficult to apply all of the six principles of a successful place in a rural context. It was also suggested that the different elements and the language used presently in Scottish Government design policies and guidance documents does not translate well to a rural/open countryside location.

There was a call for some flexibility for rural areas and islands without watering the policy down for urban areas. Specifically, it was suggested that the Scottish Government should consider supporting or creating design tools for more rural locations. Other suggestions included:

• Adding biodiversity as a seventh principle of quality places.
• Being more prescriptive in the language used relating to design. The pressure to deliver new development should not compromise the ability to deliver high quality design.
• While SPP states that proposals may be refused on placemaking grounds only, this is still relatively rare. Tying in placemaking with public health objectives, biodiversity and climate change mitigation could help emphasise its importance and tackle the perception that placemaking and design is about aesthetics.
• Strengthening the policy wording and providing more clarity on some criteria would be useful - for example how to interpret and enforce the 'distinctiveness' principle where development is dominated by mass house building.

Plan-led, integrated approach

There was a view that NPF4 provides an opportunity to lay the foundations for a more plan-led approach to development in which community wellbeing takes centre stage. To that end, it was suggested that:

• NPF4 should consider encouraging and promoting the need for planning to collaborate with other parties within local government and beyond to enable the delivery of high-quality development.
• There must be a strong relationship between NPF4 and spatial and healthcare planning. Moray Council's Policy PP1 Placemaking was cited as offering a good example of such an approach.
• The public sector will have a key role to play in ensuring objectives and policies are carried forward into day to day decision-making. Proactive partnership working will be crucial to deliver great places in the right locations - as opposed to letting the market decide where development happens.

Specifically, it was proposed that NPF4's placemaking policies and document structure should support other policies by first ensuring appropriate cross-references to them. Thereafter the six qualities of place could be utilised, and examples provided of what could/should be considered under each - this could then help link to other national policy documents and/or other NPF policies.

There was also reference to the relationship between placemaking and LDPs. It was suggested that LDPs should take account of existing data on socio-economic performance and wellbeing, to support the development of place-based policies. Other suggestions included that:

• SPP could require LDPs to reflect all local spatial strategies across climate resilience, energy generation, housing, healthcare, connectivity etc. so as to support a place-based approach.
• Guidance should be provided on how to include placemaking in LDPs.

It was also suggested that a National Landscape Advisor should be appointed to the Scottish Government to help shape the development of Scotland's Landscape, Land Use and Infrastructure Plan and to work across Directorates to achieve consistent and joined-up thinking and inform Local Planning Authority decision-making. This change was seen as demonstrating the Scottish Government's commitment to the Place Principle by working holistically between its own Directorates and with other stakeholders and that this approach would also permeate down to LPA decision making.

Local Place Plans and the Place Standard tool

A number of respondents commented on LPPs, including suggesting that a clear statement on how LPPs fit into the plan-making process would both support a co-ordinated approach to placemaking and ensure consistency between plans.

It was reported that research has found that the majority of the public think they have no influence on the planning system, but that NPF4 offers an opportunity to turnaround these perceptions and more fully engage citizens with how Scotland's physical environment is changing. To this end, it was suggested that the LPP provisions in the 2019 Act can form the foundation of better community engagement.

There was a call for LPPs to be written into NPF4 narrative and policy as a key vehicle for meeting its aims, and that there should be references to the provisions of the 2019 Act, giving them appropriate status within relevant LDPs and in subsequent decision making. There were also calls for resources to be made available to support communities in developing and delivering their plans, including a suggestion that NPF4 should recommend those resources be made available. Other suggestions included that:

• It will be important to be clear about how LPPs fit into the current hierarchy of plans, in particular how they fit with the NPF with its current timetabling.
• LPPs need to tie in with Community Planning Locality Plans.
• There should be a clear policy direction and status for LPPs, which should incorporate deliberative public involvement mechanisms into the participation statement of NPF4 and provide clear statement of how and where LPPs will be able to influence a ten-year NPF plan.
• Clear guidance on their role needs to be developed.
• NPF4 should also set out the design tools needed to ensure key places are protected and enhanced, in particular in LPP areas, and any community growth areas and major developments.

There was also support for the use of the Place Standard and it was recommended that NPF4 embeds and champions the Place Standard themes. It was suggested that the Place Standard tool^[30] is a useful way to engage communities on place. In terms of how the Place Standard should be used, suggestions included that:

• NPF4 should encourage use of the Place Standard tool in the early stages of preparing LDPs, masterplans and major pre-application consultations.
• The need for developers to use the tool should also be emphasised, including that they should be able to demonstrate how the principles set out in Creating Places and Designing Streets have been incorporated into development proposals.

Inclusive places

Some comments addressed the creation of inclusive, intergenerational communities, including delivering places and homes that meet the needs of older people and disabled people.

There was a call for NPF4 to consider how planning can create places which meet the needs of different generations, especially younger and older people. In support, it was suggested that planning is fundamental to designing and developing high-quality places that serve the needs of everyone, and regenerating communities fit for the future. There was specific reference to Scotland's planners having a pivotal role to play in upholding the rights and improving the livelihoods of our children and young people who grow up in these places now and inherit them in the future.

It was reported that there is a lot of discussion and best practice being developed which could be highlighted and encouraged. There was reference to a Mobility, Mood, Place project carried out by The University of Edinburgh, and to the potential for NPF4 to encourage intergenerational housing, play streets and integrate the 'caring place' principles developed by Architecture and Design Scotland. The experience of PAS in facilitating a post asset transfer engagement process to create an intergenerational centre in a primary school building was highlighted as an approach which could be replicated around Scotland and would help create more inclusive places and resilient communities.

Other comments or suggestions around how NPF4 should address this issue included that:

• NPF4 should set an aim of creating intergenerational places which include homes of different sizes (studios to large family homes) and tenures, homes offering design flexibility, and facilities to meet the needs of all generations.
• Self-build, co-housing, live/work homes, homes aimed at young people and 'whole-life' homes (the design of which can change flexibly over the lifetime of an inhabitant) should be encouraged and made easier to deliver. Private rental sector and middle-market rental accommodation also need to be included in this debate.
• The social infrastructure of places is important, and it is essential that Scotland's new and existing places are developed to create intergenerational communities and enhance sociability. Often, local projects to create this sort of social infrastructure will be led by communities, potentially around the reuse of existing but unused buildings.

It was also suggested that the meaning of adaptable should be expanded, and that the focus should be on design that meets the needs of older people or the disabled, for example with wide paths around houses, and buildings that work well in hot weather.

Well-designed places and density of development

Other comments focused on design, with one perspective being that the current approach can be too focused on design rather than outcomes for communities. It was reported that it is rare for planning applications to be refused based on poor design and the current SPP does not provide the clarity that would be necessary to do so.

It was suggested that design and performance must be pushed up the agenda so poor layout, design or response to the landscape context of a proposal become primary reasons for refusing applications, and that the same should be true in terms of measures to address future climate.

Specific suggestions included that:

• Designing Streets^[31] provides a good starting point for considering what standards and approaches statutory policy should prescribe. It should be reviewed, and the next iteration should become part of NPF4.
• Any national policy focus on design should be supported by other initiatives to promote good design. There may be opportunities to extend the remit of the Improvement Service for example.
• Design panels may be beneficial and related guidance would be welcomed.

Other comments focused on the urban or suburban form, and the density of development. Some of these comments identified benefits that flow from increased urban densities, including that:

• The compactness of the urban form plays a critical role in determining carbon emissions and the carbon intensity of a given population. They also support a range of placemaking objectives which can influence less carbon intensive lifestyles.
• Dense, compact settlements require less infrastructure than sprawling development patterns. They also promote a number of mutually reinforcing co-benefits for climate resilience and health and wellbeing, such as walkability and public spaces in close proximity.

Other comments included that, while increased urban density has a clear link with reducing carbon emissions, a policy framework is required that achieves this without compromising on quality of place. In terms of how this could be taken forward through planning policy, it was suggested that NPF4 supports explicitly the compact urban model across Scotland but also focuses on the delivery constraints associated with this policy. A specific suggestion was the introduction of a minimum homes per hectare density of 65 homes per hectare, with provision for a minimum of 100 per hectare to be specified in some areas, proposed.

It was noted, however, that these proposed densities may not suit many smaller settlements and it was suggested that national policy needs to consider appropriate densities for settlement types and scales, while supporting higher density in appropriate locations to promote placemaking, public and active travel use and climate change adaptation. Although recognising that increasing density must be a key objective to reduce the loss of agricultural land, it was stressed that density must be set within its local context.

Other aspects that respondents identified as requiring consideration included that:

• Density alone is not the answer for urban areas and requirements for mixed use, local neighbourhoods with commercial and community facilities need to have a more significant emphasis in national policy and be interspersed with green spaces and wild areas.
• Stronger guidance on plot densities in terms of building heights is required, including on the spatial relationship between neighbouring buildings and how to identify the limitations that places on the development of a site.

Development management, including housing development

In terms of how national planning policies can best support the delivery of existing core placemaking policies in development management whilst recognising the need for local flexibility, suggestions included:

• Developing a clear set of standards that can be used to refuse development, including for major and small-scale developments and single buildings.
• Using a traffic light score, and only supporting proposals that achieve a green score. An amber score would identify where there are issues that can be fixed and a red score would mean it conflicts with policy, or the issue cannot be mitigated against.
• Taking a continued stance to refuse developments with poor design using design tools referred to in SPP paragraph 57 and Creating Places^[32] page 10 'What is good design'.

It was also suggested that NPF4 provides an opportunity to guide greater alignment of planning and roads consenting services, ensuring each works to a shared set of goals and principles. NPF3's articulation of the relationship between the LDP and the LHS was cited as a good example of a helpful approach.

With specific reference to managing the development of housing, comments included that placemaking should be a key focus for all involved in development delivery, with a focus on quality not quantity. A concern was raised that, if local authorities are more pressed to meet housing targets than community wellbeing, they can be forced to ignore other important outcomes, for example in terms of community connectedness, community voice, combatting isolation, supporting healthy lifestyles and reducing carbon emissions. There was also a concern that the approach set out in the Housing Technical Discussion Paper (and covered under the relevant section of this report), would continue to result in conflict, with a very numbers-driven approach, minimal local influence, and no focus on placemaking.

It was suggested that the use of the Place Principle and the NPF will help ensure that decisions are made 'in the round' and all the trade-offs are thoroughly considered. Other comments included that:

• Community buy-in will be greater where there is confidence essential infrastructure will be provided and where the benefits of development to quality of life, health and wellbeing are clear.
• It will be important to ensure that all new major developments are mixed use and are designed to include, or be connected to, amenities. Large housing developments should incorporate commercial use and, likewise, large commercial proposals should incorporate residential use, planned within the wider urban design.
• NPF4 may wish to consider how sustainable rural settlement patterns can be created and to whether whole new settlements are needed, perhaps on the edge of cities. These could be created with a new development model based on the new town approach and aimed at addressing Scotland's need for affordable homes.
• Building on paragraph 187 of SPP, NPF4 should require planning authorities to work collaboratively with home builders when previously agreed masterplans need to be updated to reflect changes in circumstance - ensuring they function as an enabler of high-quality development, not a barrier to its delivery.
• NPF4 should identify that masterplans should only be used where they can add greatest value. NPF4 could also articulate a simple, common, non-legislative process for agreeing and reviewing masterplans.