NPF4 call for ideas: analysis of responses

Health

Key objective of NPF4: To ensure that planning policies and decisions take account of the health needs of local communities and have regard to the need to improve the diet, health and wellbeing of people living in Scotland.

Comments under this theme were sometimes extensive and/or far reaching. Key issues raised are summarised below and the relevant Scottish Government policy team has access to all responses.

In terms of the wider reach and significance of the planning and health theme, it was suggested that planning can affect quality of life and wellbeing in many ways, including as part of Scotland's whole system approach to health improvement. Connections were made to the health and wellbeing impact of other planning themes, including green infrastructure and having access to greenspaces and nature, sustainable transport and promoting and enabling active travel, and housing.

In terms of other aspects of health capable of being influenced by the planning system, suggestions included:

• Accessibility to buildings and spaces for those with physical/cognitive disabilities.
• The extent to which health and social care services, and decisions over how and where they are delivered, have a major impact on women.

Placemaking and tackling inequalities

It was also noted that place, in particular, can play an important role in public health and is recognised in the first of Scotland's six public health priorities: "A Scotland where we live in vibrant, healthy and safe places and Communities". It was suggested that the Scottish Planning system has been progressive in its acknowledgement of place's influence on the health outcomes of society in recent years. NPF4 was seen as providing an opportunity for the planning system to define and support further the attainment of desirable social and health outcomes within planning policy and applications, and to align the development process with wider aspirations for better wellbeing outcomes.

A range of aspects of a place that can nurture health and wellbeing were identified, including the availability of services and amenities, feelings of safety, a sense of belonging and a sense of control, and thriving communities with an abundance of local businesses and good access to job opportunities. Negative aspects identified included high traffic volumes, poor air and noise quality and poorly maintained streets and public space. It was suggested that these positive and negative aspects of places vary in impact depending on the specific setting, socio-economic status and the characteristics of population groups, including ethnicity, disability, gender, sexual orientation, age and sex.

Recommendations made in relation to NPF4's role in influencing place to nurture health and wellbeing included that it should:

• Include a national statement on place, its impact on public health and its role in whole system reduction of inequalities.
• Define the connections between place and health and require all planning policy to explicitly describe how it contributes to improving health and wellbeing, based on evidence available.
• Set out the relationship between planning decisions, the processes that shape these decisions and their impact on place, health and inequalities. In particular, encourage decision makers to be fully informed of the implications that planning decisions have on health and health inequalities in the short, medium and long term and how decisions affect the achievement of Scotland's public health priorities.
• Establish a set of health and place themes that define a Scotland-wide approach to what needs to happen for every place to play its part in keeping Scotland's people healthy. These themes should be based on those in the Place Standard and embedding them into NPF4 will strengthen links between community-identified needs and the strategic approach to planning decision-making. The suggested themes were: Community engagement and empowerment; Equity and sustainability; and Improved efficiency.
• Articulate, define and give national policy support to a range of health and place themes constructed around: movement (moving around, public transport, traffic and parking); spaces (streets and spaces, natural spaces, play and recreation); resources (services and support, work and economy, housing and community, social interactions); civic (identify and belonging, feeling safe); stewardship (care and maintenance, influence and control); and underpinning (equitable outcomes for all, climate change, sustainability and biodiversity).

Other suggestions included that NPF4 should:

• Support HIAs by giving guidance on the general parameters of an HIA and what should be included, in the same way that guidance is provided by key agencies with respect to Environmental Impact Assessments. This guidance should be co-designed with Planning Authorities.
• A planning development should only be approved if it passes a future generations health and wellbeing test (this could be part of a public interest test). An example public interest test is set out in the Wellbeing of Future Generations Act (Wales) 2015.

Other issues about placemaking are covered further at that theme.

Strategic links and evidence

It was suggested that NPF4 could encourage closer collaboration between national and local planning processes, and there was an associated recommendation that NPF4 includes a stand-alone planning, health and inequalities section to clearly explain the concepts and links to the range of national strategies and plans.

The other national policies and strategies identified as relevant, and which NPF4 could have a role in achieving included: the National Transport Strategy; the Active Scotland Delivery Plan; the 2030 Vision for Active Travel; the Cycling Action Plan for Scotland; the National Walking Strategy; the Active Travel Framework; the Play Strategy for Scotland: Action Plan; Early learning and childcare expansion; A healthier future: Scotland's diet and healthy weight delivery plan; Scotland's Mental Health Strategy 2017-2027; the Health and Social Care Delivery Plan; and A Culture Strategy for Scotland. There were also references to:

• Local outcomes improvement plans and locality plans.
• LPPs.
• Annual delivery planning across NHS boards and HSCPs.

Overall, it was suggested that consideration of health, equity and sustainability should be mandatory rather than optional and that NPF4 should require decisions to be based on the best available evidence, including community health profiles developed using tools such as the Scottish Public Health observatory on-line profile tools, and community engagement.

In addition to the importance of engaging with communities, it was suggested that consideration be given to making Public Health Scotland a statutory consultee on LDPs and a consultation authority on SEAs.

Developments and sufficiency of health care services

Ensuring access to key local services, including health services, was reported to be a fundamental principle of planning for health. In terms of approach/factors to be taken into consideration, comments or suggestions included that:

• The use of good evidence about current and future demographics and existing and predicted health and social care need (such as that available from National Records for Scotland and the Scottish Public Health Observatory) is essential.
• The characteristics of new and/or existing communities are important, especially when developments will be targeted at specific demographics such as older people, families, or people in a particular income bracket.
• An intergenerational approach to planning should be taken.
• NPF4 should help with enabling the planning of services and infrastructure that ensure inclusion in terms of access to services across whole regions.
• Local Health Boards should be consultees during the SEA process for housing proposal sites and should be able to give advice on whether there are sufficient health care facilities in the area or if more are required as a result of the development. Where a major housing development application is received which was not identified as a proposal site within the LDP then the health board should be a consultee for the planning application so advice on healthcare facilities can be provided.
• NPF4 should consider how new technology may impact on the nature and delivery of health services.

It was also noted that the issue is not only about new developments and that access to health services, as well as social care, must be considered in the context of planning for community amenities in general.

In support of coherent spatial and service planning, and to allow provision to be planned to avoid increasing the strain on existing services, it was suggested NPF4 establishes closer collaboration between national and local planning processes, Health Facilities Scotland, Estates Management in each of the NHS Boards, private contractors (GPs, dentists and opticians) and private health providers.

Mental health and wellbeing

The connection was sometimes made to good places supporting good mental health and wellbeing. It was suggested that, if good spatial planning processes are not delivered, there is a risk of resultant poor social, physical and economic environments, leading to increased risk of poor mental health and widening health inequalities. Other comments included that:

• There is good evidence that, independent of physical activity, high quality green space contributes to mental wellbeing at both individual and community level.
• It will be important to ensure that communities can make a difference on their own terms, which requires devolving more power to them. This means that rather than having a complex system in which communities must be 'educated' to participate, planning processes should be agile and responsive enough to work with diverse and complex communities with different circumstances and priorities to help and support them to flourish. This should include rural communities.

Diet and obesity

A number of respondents commented on the importance of creating environments that enable healthy food and physical activity behaviours for everyone.

It was reported that addressing the obesity crisis is complex and requires a multi-faceted approach that makes connections between policy areas, different levels of government, and the public, private and third sectors. The important role planning plays in helping to shape neighbourhoods, towns and cities to increase the opportunities for physical activity as well as tackling the availability of foods and drinks that are high in fat, sugar and salt was highlighted. It was suggested that NPF4 provides a unique opportunity to create healthy weight environments that can have a positive impact on the health of the nation.

It was noted that the planning system can have a huge influence on how we access food and what type of food we access. The many ways planning can influence the food system were highlighted, for example by determining the location of food growing or manufacturing areas, supporting distribution and transport systems or influencing the location of retail and out-of-home food sources. It was also noted that planning can support access to healthy, nutritious food (as opposed to foods high in fat, sugar and salt) in easily accessible retail and out-of-home premises in or near local communities.

Further comments or suggestions included that:

• NPF4 needs to acknowledge the need for fewer fast-food outlets and more investment in affordable healthy food, support for families for easy home cooking and that new permissions should have accredited levels of 'green' operations.
• NPF4 should require local authorities to consider health impacts when considering fast food takeaway applications. Planning decisions over changes of use of commercial premises or establishment of new ones have a role to play in promoting healthy food environments and NPF4 could consider how national policy can support planning authorities in implementing this role.
• NPF4 should support a healthy, safe and accessible food retail and catering environment, particularly in the vicinity of schools and in deprived areas. This should include preventing over-provision and clustering of hot food outlets and could involve exclusion zones for particularly sensitive areas such as around schools.
• Planning policy should consider how it might improve accessibility to healthy food and enhance opportunities for food growing in communities, for example through the incorporation of food growing spaces into plans for new and existing building developments.
• Better guidance is needed to help both planners and communities to identify the sorts of development that could damage health, including food outlets, licensed premises and off-licenses, betting shops, etc.

One perspective was that embedding the themes in the Place Standard into NPF4 will strengthen links between community-identified needs and the strategic approach to planning decision-making. It was suggested that embedding the themes into national policy will also inform a consistent approach for local placemaking policy and implementation and would generate a more informed picture for communities and organisations to jointly identify and prioritise local actions and investments.

Noting their understanding that the Place Standard tool is currently being considered as the most useful mechanism for integrating health and place issues within NPF4, one respondent cautioned against the wholesale transference of the themes alone, including because at the time of development of the Place Standard understanding of the complexity of the food system and the concept of "food environment" were not fully developed. They went on to report that the Town and Country Planning Association in England has completed a significant amount of work in linking planning and health and suggested their document "Planning Healthy-Weight Environments"^[10] should be used as a source of material for NPF4 content.

Physical activity and sport

Issues were raised about the physical infrastructure of community sport and recreation in Scotland, combined with the societal arrangements in place for their usage.

It was reported that, while policies to protect playing fields have largely worked, it is important not just to protect facilities but to widen access and usage as well, and to ensure the facilities that exist match the health and wellbeing needs of the communities they serve. One respondent reported research they had commissioned to have revealed a growing 'divided sporting nation' with those in lower socio-economic groups becoming more estranged from regular activity and those in higher groups taking part in more activity.^[11] The increasing costs of accessing facilities, both in terms of travel and usage, was identified as a key barrier to participation. It was suggested that there are past examples of national planning covering sport as a subject, and that there are sustainability and health-related justifications for taking such an approach.

Other suggestions included:

• Providing realistic options for active travel as a first choice can lead to higher levels of physical activity and improvements in health.
• For sport and physical activity, having an evidence base of what an area currently has as part of the LDP process. This could then link to the aim of better planning generally for infrastructure needs.
• For new development, there are many good examples of where new places for sport and physical activity have co-located with other facilities. Taking a place-based approach to planning enables the needs of an area to be considered in an integrated way, and strengthening this requirement makes sense given the ongoing challenges for public spending.

Climate change and air quality

It was suggested that climate change is a major threat to health and is also a threat multiplier in that existing social, environmental and economic stresses are likely to be exacerbated, particularly for the most vulnerable in society with fewer resources to cope. This issue is covered in greater depth at the Climate change theme, but some of the further health-related points made included that:

• Planners can help by reducing levels of harmful transport and industrial emissions through encouraging the switch to cleaner energy sources and providing infrastructure that enables active travel.
• The linkages between clean forms of energy generation and the health benefits of cleaner air should be explicitly stated in NPF4.
• Natural materials and biophilic design^[12] have been proven to provide greater wellbeing and natural materials give off less or no volatile organic compounds. It was suggested that poor air quality and poor ventilation in modern houses is one of the reasons for increases in asthma and allergies.
• NPF4 should support Air Quality policies around Low Emission Zones.

Mine gases

In relation to how the planning system should ensure that health issues around mine gases are taken into account and addressed, comments included that local authority decision-makers and communities need to be assured that issues covered by relevant regulatory regimes can and will be adequately addressed.

Suggestions included that:

• Thorough health impact assessments should identify risks to health posed by any development, including former mine workings.
• The planning system should ensure full consultation with Contaminated Land Officers on mine gas matters. Where more specialist knowledge is required consultations should extend to the Coal Authority, SEPA and other local authorities.
• Evaluation of the risk at a site should include a wider area review and be supported with detailed conceptual site models. Adequate environmental monitoring should be carried out in line with the available guidance and development should not proceed until a suitable remediation scheme has been agreed.

COVID-19

It was suggested that the pandemic has highlighted the importance of place to support safe physical distancing and the need to develop healthy, sustainable places that support longer term recovery. NPF4 was seen as offering an opportunity to strengthen national and local planning policies to support such mitigation measures and to create places and communities that are more resilient to any future, similar events. Related recommendations included that:

• NPF4 should clearly articulate the future roles of planning legislation, policy and delivery for improved pandemic preparedness. These considerations should be designed around the global lessons learned from the current situation.
• The Scottish Government should convene a Place and Wellbeing Stakeholder Group to enable an ongoing collaborative approach to embedding support for health and wellbeing outcomes within planning policy and link up the role of NPF4 in whole system recovery from COVID-19.

Other issues

Other issues or suggestions raised included that NPF4 should give full consideration of the extent to which noise generated by any strategic enhancement works at Scotland's airports will affect the health and wellbeing of communities, including when considering possible National Developments.