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.
Vacant and derelict land
Key objective of NPF4: To prioritise the use of vacant and derelict land so that viable development takes place on appropriate sites ahead of greenfield land as part of priorities to deliver inclusive growth and sustainable places and responding to the climate emergency.
The 2019 Act and NPF4 were seen as presenting a major opportunity to fundamentally rethink views and approaches to VDL, and to challenge the implicit assumption within public policy that if a site is too difficult or too challenging then it is acceptable to simply walk away.
In terms of the benefits that could flow from reusing brownfield sites, there was often a specific focus on tackling climate change, or more generally contributing to the Scottish Government's National Outcomes. Possible uses identified included:
- For renewable energy generation.
- Creating new parks or greenspaces or full naturalisation.
- For community growing, as new allotments or as city farms.
- Providing employment opportunities and attracting new investment.
- As sites for house building. It was also noted that increased urban densification can help with reducing transport-related carbon emissions.
In line with comments made in relation to housing supply, the value of bringing empty homes back into use was also highlighted, as was the potential for stimulating large-scale community renewal in some of Scotland's most deprived neighbourhoods, providing a catalyst for addressing long-standing health inequalities and a stimulus for inclusive growth. It was reported that the Vacant and Derelict Land Taskforce has clearly identified the persistent and problematic sites that are most harmful to surrounding local areas, but which have productive potential. There was also reference to the register compiled by the Scottish Land Commission.
There were calls for a stronger commitment to, or a national policy on, unlocking the potential of VDL. Looking ahead to 2050 it was argued that, in order to manage the development and use of land in the long-term public interest, a commitment to socially responsible land reuse needs to be embedded in the planning system so that it becomes unacceptable for surplus land to become derelict and prevent more sites from being used indefinitely.
There were also suggestions that tackling VDL should become a National Priority or that a programme of major scale is required to tackle the issue. Adopting a brownfield first policy and strengthening the level of presumption in favour of brownfield development was proposed along with suggestions that:
- Spatial strategies should consider a circular economy approach to site allocation or Land Use Strategies should encourage the use of brownfield before greenfield sites.
- There should be a national effort to co-ordinate and deliver priority sites and that this effort should be taken forward as a National Development.
- There should be a focus on supporting community groups, such as co-housing groups, to become developers of smaller sites.
- NPF4 should have a linked capital investment programme that supports the delivery of its ambitions and the national developments. This should include enhanced resources for VDL remediation for future development and green infrastructure. Encouraging a 'whole-life' approach, which considers factors such as the cost of enforcement and the long-term economic impact of failing to resolve issues, as well as the cost of resolving them, was proposed.
- Requiring planning authorities to prioritise the reuse of land based on the harm caused to communities and to work with communities to develop place-based plans to bring them back into use. It was reported that the Land Commission has produced a framework to help local authorities engage with communities and assess the harm caused by neglected land and buildings.
Specific suggestions in relation to taking any priority or policy forward included:
- Establishing clear national targets for the reuse of derelict land and include an outcome measuring the impact of land reuse.
- Introducing policy and mechanisms, such as Compulsory Sales Orders, or Community Right to Buy that would enable regeneration and prevent sites from being abandoned.
- Strengthening SPP to prioritise stuck sites, including by mitigating the risk to planning authorities that prioritise brownfield development of losing much needed investment to neighbouring areas. It was suggested that care will be required to design policy that supports rather than deters investment, but that overseas experience suggests this is an achievable aspiration.
- Repositioning the VDL Register, for example by differentiating between recently vacant, deeply challenging and slowly naturalising sites and by including VDL data on a digital mapping tool.
Along with whole system comments and suggestions, a number of the National Development proposals involved the re-use of brownfield sites or other VDL, including large sites connected with the decommissioning of power stations or the closure of large industrial facilities. They also included proposals that current National Developments (under NPF3) which involve the use of VDL, such as Ravenscraig and the Grangemouth Investment Zone, should continue.
National Development proposals often involved the use of VDL to create new business and employment opportunities, often connected to the green economy and sustainable energy, for housing development, for the creation of active travel and green infrastructure and for the creation of greenspaces.
Contact
Email: scotplan@gov.scot
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