Scotland 2045: fourth National Planning Framework - draft: society and equalities impact assessment

The Scottish Government is revising the National Planning Framework (NPF), a long term plan for Scotland that sets out where development and infrastructure is needed to support sustainable and inclusive growth.

The current National Planning Framework (NPF3^[116]) was published in 2014 and will remain in place until a fourth NPF (NPF4) is adopted. NPF4 will guide spatial development, set out Scotland's national planning policies, and will designate certain developments or classes of development as 'national developments^[117]' for which Ministers have established a need in principle.

NPF4 will have the status of the development plan for planning purposes. This means that its policies should inform day to day decision making in the planning system. It will also be important for communities as they develop their Local Place Plans, guide local development plans and will be relevant to regional spatial strategies.

In terms of policy, NPF4 is linked to the outcomes of the National Performance Framework^[118]. Planning and Architecture's role in delivering the 11 national outcomes has recently been published^[119]. It sets out that:

'Involvement of children and young people in planning is being strengthened through Scotland's new Planning Act, along with clear commitments to open space and opportunities for play. The Place Standard tool, including enhanced participation tools, will further support children and young people to have an influence over the future of their places, helping to address issues such as child poverty, social isolation and wellbeing.'

NPF4 will look to rebalance our planning system so that climate change and nature recovery are the primary guiding principles for all our plans and all our decisions. A place based approach is at the heart of creating a more sustainable and fair Scotland.

NPF4 will look to deliver on six high level outcomes which include:

Meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people;

Improving the health and wellbeing of people living in Scotland; and

Improving equality and eliminating discrimination.

It will also include land use planning policies supporting key issues supporting children and young people's lives, such as engagement, local living, housing, infrastructure (including education provision), spaces and places, access to play and recreation, health and wellbeing and connectivity.

The Scottish Government is revising the National Planning Framework (NPF), a long term plan for Scotland that sets out how the Scottish Government's approach to planning and development will help to achieve a net-zero, sustainable Scotland by 2045. Development of the fourth National Planning Framework (NPF4) began in late 2019. The participation of children and young people has been interwoven into the engagement strategy from the beginning, with an early engagement session with Members of the Scottish Youth Parliament and rural schools, to workshops on the NPF4 Position Statement with children and young people.

Children and Young People have particularly told us that:

They want to be involved in the decisions about the places they live. This includes children who are also Gypsy/Travellers;

Issues around housing are important, its affordability and associated infrastructure;

Access to employment opportunities are key;

Children want a return to play, more play and better play. With better quality spaces;

Connectivity is important, particularly access to public transport and its affordability but also digital connectivity;

They value places which are green and allow them to be physically active.

Through the statutory purpose of planning, NPF4 is linked to the national outcomes in the National Performance Framework and will contribute to delivery of:

The United Nations Sustainable Development Goals;

The SHANARRI wellbeing indicators; and

Relevant Articles set out in the United Nations Convention on the Rights of the Child (UNCRC).

To summarise, NPF4 has the potential to have a positive impact on the rights of all children as it will help to deliver a fairer and more inclusive Scotland, where every child and young person has the opportunity to fulfil their potential. NPF4 aims to ensure that the places that children and young people live, play, go to school and work are shaped with their participation and are accessible to all. Ultimately, we consider that NPF4 complies with UNCRC requirements.

The Child Rights and Wellbeing Impact Assessment (CRWIA) is used to identify, research, analyse and record the impact of a proposed policy on children's human rights and wellbeing. It is to be used on all new policy which impacts children, not just children's services. The impacts can be direct or indirect; short, medium or long-term; and positive, negative or neutral.

The Planning (Scotland) Act 2019 provides for a new style National Planning Framework to be prepared by the Scottish Government. The fourth National Planning Framework (NPF4) will:

Incorporate detailed national policy on a number of planning topics. For the first time, spatial and thematic planning policies will be addressed in one place;

Have the status of the development plan for planning purposes. Its policies will have a stronger role in informing day to day decision making; and

Address the following high level outcomes:

• Meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people
• Improving the health and wellbeing of people living in Scotland
• Increasing the population of rural areas of Scotland
• Improving equality and eliminating discrimination
• Meeting any targets relating to the reduction of emissions of greenhouse gases
• Securing positive effects for biodiversity.

Development of NPF4 began late in 2019 with a workshop session with the Scottish Youth Parliament. Through the period January to April 2020 we sought early views on NPF4, both in terms of the spatial strategy for Scotland and on the more detailed policies on specific topics, currently in the Scottish Planning Policy. Engagement included:

The publication of Scotland2050 Think Pieces, one of which reflected on the Scottish Youth Parliament workshop and online survey^[120]

A roadshow around Scotland which included visiting schools in Aberfeldy^[121] and Buckie^[122]; and

The publication of an NPF4 Integrated Impact Assessment Scoping Report^[123] setting out the initial evidence on the potential impact on children and young people.

We had anticipated laying a Draft NPF4 in the Scottish Parliament in September 2020, but given the impact of the Coronavirus (COVID-19) emergency and many people's and organisations' capacity at that time, delay was been inevitable and the timetable was amended.

To provide an overview of the Government's thinking, in November 2020 we published a Position Statement^[124] setting out what the likely policy changes might be in the Draft NPF4. This also saw the publication of an update to the NPF4 Integrated Impact Assessment Scoping Report. The Position Statement was supported by the commissioning of workshops from PAS with children and young people. The output was published in June 2021.

Draft NPF4 was laid in the Scottish Parliament on 10 November 2021. At the same time as Parliament is considering Draft NPF4, the Scottish Government will carry out a public consultation. We anticipate producing a final version of NPF4 for approval and adoption around summer 2022.

Any changes to the adopted NPF4 will be reflected in a finalised impact assessment.

The likely effects of the policies were informed by a range of evidence, including public consultation and stakeholder engagement. Scottish Government officials also examined evidence from a range of studies, reports and surveys, including:

Growing Up in Scotland^[125]

Beyond4Walls^[126] (2016)

YoungScot Survey^[127] (2017)

Hard to Reach, Easy to Ignore^[128] (2017)

Young Gypsy/Travellers Discuss the United Nations Convention on the Rights of the Child - Children and Young People's Evidence Bank^[129] (2018)

Girls in Scotland 2018^[130] (2018)

Every Child, Every Chance^[131] (2018)

Young People and the Highlands and Islands: Maximising Opportunities^[132] (2018)

Child Poverty Strategy documents^[133] (2019)

Scottish Household Survey: Annual Report 2018^[134] (2019)

National Transport Strategy Review Young Scot^[135] (2019)

Climate Ready Scotland: climate change adaptation programme 2019-2024^[136] (2019)

Children and parents: media use and attitudes report^[137] (2019)

Young people's participation in decision making: attitudes and perceptions^[138] (2020)

Population Projections for Scottish Areas 2018-based^[139] (2020)

Girls in Scotland 2020^[140] (2020)

Make Space for Girls^[141] (2020)

Health Inequalities: Peer research into the role of communities^[142] (2020)

Challenges from the frontline^[143] (2020)

Population Projections for Scottish Areas 2018-based^[144] (2020)

Democracy Matters to Children^[145] (2020)

Travel and Transport in Scotland 2019^[146] (2020)

Social Attitudes Survey 2019: Attitudes to Young People^[147] (2020)

NPF4 Call for ideas: Analysis of responses^[148] (2020)

If not now, when? - Social Renewal Advisory Board report^[149] (2021)

Progress Review of Scotland's Play Strategy^[150] (2021)

NPF4: Position Statement: Analysis of Responses^[151] (2021)

NPF4: Position Statement: Youth Engagement^[152] (2021)

Poverty in Scotland^[153] (2021)

Public Health Scotland^[154] (2021)

NPF4 has the potential to have a positive impact on the rights of all children as it will help to deliver a healthier, safer, fairer and more inclusive Scotland where every child and young person has the opportunity to fulfil their potential. NPF4 aims to ensure that the places that children and young people live, play, go to school and work are shaped with their participation and are accessible to all.

As a result of the policies in Draft NPF4, whilst there will be opportunities for communities to be involved not everyone will always agree with development proposed,

Ultimately, we consider that Draft NPF4 complies with UNCRC requirements.

Engaging with children and young people has been interwoven into the development of NPF4 policies at each step.

Engaging Members of the Scottish Youth Parliament (October 2019)

2050 Think Piece: #WhatsYourTake (Liam Fowley MYSP)

NPF4: Call for Ideas: direct engagement with schools in Aberfeldy and Buckie (early 2020)

NPF4: Position Statement: Youth Engagement (2021)

We have also been aware of a number of surveys, reports and research which have drawn out the lived experience of children and young people.

Key findings are set out under policy themes.

Demographics

Whilst the total population of Scotland has grown over the last 35 years, the proportion of children (0 to 15 year olds) in the population has decreased steadily from 22% in 1983 to 17% in 2019. It has been reported^[155] that in 2019, there were 867,345 children aged 15 and below in Scotland.

Data in Population Projections for Scottish Areas published in 2020 would indicate that the number of children is projected to increase in 3 councils out to 2028. These are Midlothian, East Dunbartonshire and East Renfrewshire.

Participation

A survey undertaken by YoungScot (2017) to accompany Places, People and Planning concluded that the majority of young people feel they should be involved in planning in their local area and that their local councils should look at ways to support children and young people to do this.

This view is supported in Young Gypsy/Travellers Discuss the United Nations Convention on the Rights of the Child - Children and Young People's Evidence Bank (2018) where recommendations include that there should be more opportunities for young Gypsy/Travellers to take part in decision making and have their voices heard.

This is also reflected in Health Inequalities: Peer research into the role of communities (2020) which noted that children and young people want to be involved in decisions about the places they live.

Democracy matters to Children (2020) also noted that 'children's paths to meaningful involvement in decision-making are currently limited and many children have limited or no experience of participation in democratic processes'. It identified a number of local issues as ones in which children wanted to have a say – this included planning and the built environment.

Responses to the Position Statement called for action to address inequality of opportunity to participate, with specific calls for a greater voice for children and young people and groups such as Gypsy/Travellers.

However, this desire may be frustrated. For example, Hard to Reach, Easy to Ignore (2017) noted that language barriers, lack of confidence and dominant characters can discriminate against some people during community engagement, specifically including young people.

The 2019 Social Attitudes Survey highlighted that a majority of adults felt that young people aged 16 to 18 should have 'a great deal' or 'quite a lot' of say in decisions that affect their lives. The proportion believing this for those aged 11 to 15 was much smaller.

However, 2021 National Performance Framework - disability perspective: analysis found that fewer disabled young people agreed that adults were good at taking their views into account than non-disabled young people in 2019 (54% vs 62%).

Housing

Beyond4Walls (2016) reported that the need for good quality housing was regarded as essential, with many of the young people believing that housing must be affordably heated, have space for them to study, have Wi-Fi and be a place they feel safe. Young people also identified the importance of having a voice in their own community and good transport links.

The PAS NPF4 Youth Engagement Report (2021) found that issues around housing are important, including its affordability and associated infrastructure.

The Position Statement analysis noted that the issue of affordable housing was highlighted in the context of rural supply, where it was suggested that the lack of affordable housing is a major contributory factor in young people and families relocating away from rural areas, and that addressing this issue will be key to reversing rural depopulation.

A review of key literature by Public Health Scotland (2021) noted that damp and cold homes can lead to and exacerbate respiratory conditions and diseases and can have a negative impact on people's mental health and wellbeing. The poor health outcomes are increased for certain groups of the population, such as young children.

Spaces and places

Children want a return to play, more play and better play. This was children and young people's overwhelming response to a consultation on play undertaken by Play Scotland in early 2021. It went on to note that children wish to play in parks and natural environments such as the beach and woods, and participate in a wide range of physical activities such as football, swimming, dancing and cycling.

The Understanding Society COVID-19 (2020) study reported that young people (aged 10 to 16 years) participating in a small number of workshops in Scotland identified lack of access to the outdoors as one of the main challenges they experienced during lockdown. These young people felt that the restriction on parks and limited opportunities to access the outdoors had affected their health and wellbeing.

Health Inequalities: Peer research into the role of communities (2020) reported that children wanted to:

Improve the quality of our green spaces;

Deal with vandalism and regenerate abandoned spaces; and

Use planning processes to get support for healthier shops and restaurants to set up in our communities.

Democracy Matters for Children (2020) noted the following:

one of the most prominent themes was the importance of the physical environment for children. Children frequently want 'lots of green spaces' and 'more places to play' 'protected wildlife' and provisions in place around personal safety.

on leisure and socialising, children were keen for spaces for people to spend time socialising.

the children valued places to be physically activity both in and outdoors.

With regard to facilities such as skate parks, etc, Making Space for Girls (2020) notes that such spaces are dominated by boys and that girls may not have been asked what they want.

The Girls in Scotland (2018) survey, undertaken by Girl Guides Scotland, showed that 23% of girls said that their area had few, or no community facilities. The follow up survey in 2020 noted personal safety as being a serious concern for girls.

Responses to consultations on the development of NPF4 included the following that planning should consider young people, including through providing youth clubs and other facilities for teenagers.

The NSPCC Report Challenges from the Frontline – Revisited (2020) noted that intensive family support should be community based: support must be explicitly connected to, or even housed in, locations that work for local families and the community, such as schools, health centres, village halls and sports centres. Communities must have a say in where support is located.

Connectivity

Around half of children (52%) walked to school, 19% travelled by bus and around a quarter (25%) travelled by car. This differed by age, with younger children more likely to walk to school than older ages, while older children were more likely to catch a bus.

Engagement undertaken with Young Scot to inform the National Transport Strategy revealed that key issues for young people include the availability and cost of public transport, particularly to further and higher education, and personal safety when using services.

This would appear to confirm the Girls in Scotland (2018) survey, undertaken by Girl Guides Scotland, which showed that 55% of girls said public transport could be better.

The Understanding Society COVID-19 (2020) study noted that across all age groups (primary, secondary and post-secondary), 9% of students whose parents/carers were unemployed did not have access to an electronic device, compared with 3% of students whose parents/carers were employed or employed and furloughed.

Inequalities

Every Child, Every Chance (2018) recognises that to tackle poverty overall it is necessary to focus on 'priority families' at high risk of poverty: lone parents, families with a disabled adult or child, young mothers, minority ethnic families, families with a child under 1, and larger families (with three or more children).

The Joseph Rowntree Foundation report Poverty in Scotland (2021) noted that 54% of people who are in families where no one is working are in poverty and full-time work plays an important role in reducing the risk of poverty in Scotland.

However, it is estimated that 24% of children (240,000 children each year) were living in relative poverty after housing costs in 2017-20. Before housing costs, it is estimated that 21% of children (210,000 children each year) were in relative poverty.

After a long fall between the late nineties and 2010-13, which slowed briefly just before the recession, child poverty rates have been gradually rising again.

Considering the drivers of child poverty, three key areas are identified: income from employment, costs of living and income from social security and benefits in kind. Planning has a particular role to play in the provision of:

Good quality work

Housing (including energy and food) costs are minimised

Accessible childcare

Accessible and affordable public transport

Access to the internet.

Health and Wellbeing

In 2019, the proportion of children (aged 2–15) who met the recommended physical activity level over the last seven days, was the lowest in the time series.

71% in 2008

76% in 2016

69% in 2019

A review of key literature by Public Health Scotland (2021) found that the benefits of high quality greenspace on physical and mental health appear to be most significant for certain groups within the population, including children.

The Scottish Government has identified very young children as a socially vulnerable group, being sensitive to climate impacts. Babies and young children face disproportionately high health effects as a result of climate change impacts. Extreme events can be traumatic and potentially lead to developmental impacts.

Increasing active travel can subsequently increase the level of physical activity in both children and adults. It also noted that it could mean less use of the car, which would reduce air and noise pollution and the number of incidents and accidents involving cars. Vulnerable people in the population such as children can be the most affected by poorer air quality.

We consider that of the eight wellbeing indicators (Safe, Healthy, Achieving, Nurtured, Active, Respected, Responsible, Included (known by the acronym SHANARRI)), policy in Draft NPF4 specifically relates to:

Safe: places designed for lifelong health and wellbeing: supporting safety and supporting safe, pleasant and welcoming natural and built spaces.

Healthy: Having support in learning to make healthy and safe choices.

Achieving: supporting an infrastructure first approach (including for education provision), informed by evidence on infrastructure capacity, condition, needs and deliverability.

Active: Having opportunities to take part in activities such as play, recreation and sport, which contribute to healthy growth and development.

Respected: Given a voice and involved in the decisions that affect their wellbeing.

Responsible: Taking an active role in their schools and community.

Included: Having help to overcome social, educational, physical and economic inequalities and being accepted as part of the community in which they live and learn.

Specific policy interventions include:

Updated policy on design, quality and place, requiring plans and proposals to reflect the six qualities of successful places.

Planning should respect, protect and fulfil human rights, seek to eliminate discrimination and promote equality. It contains a revised policy that parties have a responsibility to consult and engage others collaboratively, meaningfully and proportionately.

Updated policy on blue and green infrastructure, play and sport requiring assets to be safeguarded and seeking opportunities for enhancement. New policies also protect children's outdoor play provision and design-in new opportunities for play in the built environment.

A new policy on lifelong health and wellbeing which aims to create healthier places.

Articles of the UNCRC which may be particularly relevant include:

Article 12 – where every child has a right to express their views and have them given due weight in accordance with their age and maturity. Children should be provided with the opportunity to be heard, either directly or through a representative or appropriate body.

Draft NPF4 supports collaborative engagement which ensures that meaningful and proportionate steps are taken to engage. Provisions in the Planning (Scotland) Act 2019 provide a statutory framework for engaging with children and young people to the age of 25.

Article 24 – Health and health services. Governments must provide good quality health care, clean water, nutritious food and a clean environment so that children can stay healthy.

Improving the health and wellbeing of the people of Scotland is one of the six high level outcomes for NPF4.

The spatial strategy recognises that our future places, homes and neighbourhoods will be better, healthier and more vibrant places to live. This will help us to be healthy and active, creative and diverse, so that people grow up loved, safe and respected, and realise their full potential.

Places are important for physical and mental health and overall wellbeing. The places where children and young people grow up shape the opportunities that they have and influence the course of their lives. The planning system should support development that reduces health inequalities and creates an environment that promotes active and healthier lifestyles.

Article 27 (1-3) – an adequate standard of living, with specific reference to assistance and support with food, clothing and housing.

Draft NPF4 recognises the important role that planning can play in tackling some of the drivers of child poverty, including:

Access to good quality work

Housing (including energy and food) costs are minimised

Accessible childcare

Accessible and affordable public transport

Access to the internet.

Article 31 – a right to play, rest, leisure and access cultural life appropriate to their age.

Draft NPF4 recognises that opportunities for play can make a significant contribution towards creating more liveable and healthier places.

Outdoor spaces for play, sport and recreation can make a significant contribution towards creating more liveable and healthier places.

Children experience a range of health, wellbeing and educational benefits from outdoor play, and learning in, and connecting with, nature. Providing quality opportunities for children of all ages to play will benefit their physical and cognitive development, and uphold their right to engage in play and recreational activities.

The planning system should support development that expands opportunities for play in the public realm and in a range of different types of open and green spaces, and which addresses unequal access to play spaces and facilities.

We recognise that the data available does not allow a complete picture of the experiences and views of children and young people. However the CRWIA has provided the opportunity to consider the potential impact of the policies contained in Draft NPF4 on them.

The Scottish Government has found that the proposals do not impinge negatively upon articles of the UNCRC or the indicators of wellbeing (SHANARRI) and that we do not consider that there are issues that will impact negatively upon children and young people.

The Draft NPF4 will be subject to public consultation and scrutiny by the Scottish Parliament. In light of those consultations and any comments/additional information received, we will we revisit this assessment and publish the final assessment alongside the adopted NPF4.

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