Fourth National Planning Framework - position statement: consultation analysis

A Plan for Resilient Communities

The second key outcome is Resilient Communities. The Position Statement highlighted intentions to: focus on people and the quality of areas where we live; apply concepts such as 20 minute neighbourhoods; set out a long term view of the number of homes required and focus on their location, quality and type; and introduce an infrastructure-first approach to neighbourhood planning. This will be underpinned with policies to support public health priorities, promote inclusion and equality, and help adaptation to the long term impacts of climate change.

Further detail on the Plan for Resilient Communities was provided under eight headings:

1. Apply the concept of 20 minute neighbourhoods.

2. Strengthen community resilience.

3. Promote inclusion and equality and eliminate discrimination.

4. Improve our health and wellbeing.

5. Actively plan and support the delivery of good quality homes.

6. Promote an infrastructure-first approach to community development.

7. Enhance and expand natural infrastructure.

8. Achieve more sustainable travel.

Question 2: Do you agree with our current thinking on planning for resilient communities?

General comments

A number of respondents offered broad support for the Scottish Government's current thinking on planning for resilient communities.

Further general comments in relation to Question 2 included that an explanation of what is meant by the vision for a resilient community would be helpful, and that NPF4 should recognise that Scotland's communities are diverse, will have diverse needs and that 'one size does not fit all'. It will be essential that the creation of resilient communities applies equally across the whole of Scotland, regardless of location.

Respondents also identified certain themes which they thought should be considered in relation to resilient communities, including that this section of the Position Statement makes very little reference to the topic of climate change and net zero targets.

Other issues which respondents thought should be taken into account, or which required greater emphasis included:

• Place Leadership, recognising that a 'people' and 'place' approach is the underpinning reform which can be central to achieving economic recovery and the alignment of spatial and community planning.
• Links to Community Wealth Building strategies, given the symbiotic focus on localism and resilience.
• How resilient community planning can work for women, including innovative solutions to barriers such as multiple caring responsibilities and the gender pay gap.
• The role of Scotland's city centres and workplaces as key drivers of the economy.
• Encouraging critical energy infrastructure to be embedded into the community.
• The key role of the college sector in terms of the link between colleges and the communities they serve, as well as a shared vision of the positive outcomes that can be delivered through community partnership.

Apply the concept of 20 minute neighbourhoods

Our spatial strategy and policies will reflect the needs and aspirations of people living throughout Scotland by building quality places that work for everyone. 20 minute neighbourhoods have the potential to reduce emissions and improve our health and wellbeing. We will explore how a new emphasis on living locally could work in different parts of Scotland, from remote rural communities to our towns and cities, taking into account the needs of everyone in society so that equality is built in from the start.

The 20 minute neighbourhood concept doesn't exist in isolation but scales up to include larger geographies and networked areas providing access and opportunities for the wide range of facilities and services that communities require. The ability to access goods and services through high quality walkable and accessible environments is increasingly recognised as providing strategic competitive advantage to attract and retain people and investment.

This vision will be supported by new and improved planning policies that bring together services and homes, giving life to the Place Principle and supporting public health and wellbeing and reducing inequality.

Around 100 respondents commented on the concept of 20 minute neighbourhoods, with many offering their support for this approach, or the principle that underpins it. It was described as an exciting and challenging opportunity to make local places the focus of people's lives.

Many of the comments noted the connections between the 20 minute neighbourhood approach and other themes set out within the Position Statement, including in relation to the application of the Place Principle; 20 minute neighbourhoods were seen as offering the opportunity for LPAs, developers and communities to articulate what the place principle means on the ground.

Other comments included that:

• The emphasis on resilience is positive, and it speaks well to the focus on community and health and wellbeing.
• The approach has a role to play in reducing carbon emissions, including by reducing the need for unsustainable travel.
• It has a clear connection to the emphasis on infrastructure first and needs to be underpinned by that approach.
• It will help to create a focus on reuse of brownfield sites and vacant and derelict land. This too will be connected with helping support thriving town centres.

However, it was also noted that it is an approach that will need to be given very careful consideration, since it raises fundamental questions about the nature of places and their role now and in the future.

There was reference to Improvement Service work overseeing a set of three pilot rapid scoping assessments. These are using the Place and Wellbeing Outcomes as a basis to assess the contribution of place to delivering wellbeing and exploring a 20-minute neighbourhood ambition that is specific to Scotland.

Delivering 20 minute neighbourhoods

Wider observations included that NPF4, and associated planning documents, must provide for flexibility in the application and evaluation of a placemaking approach such as 20 minute neighbourhoods. Working alongside local service delivery design and the provision of assets was seen as key, and there was a call for NPF4 to guide national financial resource allocations accordingly to enable local authorities and communities to appropriately assess and integrate future growth requirements, not only within neighbourhoods but also across wider localities.

In terms of how the 20 minute neighbourhood approach fits with, or could support work already happening across Scotland, comments included that it is very much in line with the approach already supported or being taken by many local authorities. There were particular references to:

• Investment programmes for communities and town centres, underpinned by a clear focus on infrastructure first.
• LDPs advocating new developments being centred around the needs of people first.
• Community Wealth Building - a people-centred approach to local economic development which redirects wealth back into the local economy, and places control and benefits into the hands of local people. There was suggested to be great potential to link and consider the 20 minute neighbourhood concept in the context of Community Wealth Building.

Respondents also identified conditions that will need to be in place, or support that will be required, to ensure the 20 minute neighbourhood approach can become a widespread reality. These included that input from outwith the planning system will need to be harnessed. Specific groups, organisations or services identified as central included:

• The NHS.
• Waste management services.
• The Post Office and banks.
• Business.
• Community stakeholders.

It was noted that some of these key groups or agencies may have been directed down the route of centralising services as an efficiency measure and it will be important to recognise that retaining local facilities, particularly with lowering demand, requires funding. The difficult and complex decision making around rural/village schools faced with falling pupil numbers was cited as an example.

Rural context

A number of comments addressed how the 20 minute neighbourhood would apply, or not, in a rural or island context. The Position Statement's reference to the concept scaling up "across larger geographies" was taken to mean that in rural areas, the 20 minute threshold should not be applied literally. Nevertheless, respondents identified a number of challenges around delivering 20 minute neighbourhoods in a rural context:

• Many settlements have no facilities or services at all and have limited access to settlements that have facilities. People need to travel extended distances to the services they need.
• If the 20 minute timeframe became justification to embargo development in areas outwith a 20 minute radius, the concept would be counter-productive and would do nothing to help deliver the increased population of rural Scotland that NPF4 is also required to help achieve.

In terms of how some of these challenges can be tackled, suggestions or comments included that:

• Transport solutions will be key. It will be essential that people have access to responsive, affordable and regular public transport connected to the jobs and services they need to get to.
• The development of fully functioning local hubs, either for a community or a cluster of communities, will be key and guidance how this is to be applied in rural localities will be important.

As noted more generally above, it was reported that community and resilience focused work is already underway in rural areas; for example, work in relation to the delivery of local jobs and services, minimising the need for unsustainable travel through the expanded use of digital services and resilient public transport networks, and reducing social exclusion. A connected suggestion was that a re-badging of the concept as '20 minute communities' would better encapsulate the wider aim of building resilience into communities and avoid any perception that it only applies to urban settings.

Applying the approach to existing settlements or communities

The difference between creating a new 20 minute neighbourhood and achieving 20 minute neighbourhoods within existing communities and developments was highlighted. It was noted that the majority of existing built infrastructure will still be in use by 2050, so the retrofitting of existing neighbourhoods to achieve a more liveable and less car-dominated environment is a priority.

Comments included that it will be important for policy to provide a steer on how to identify what needs to be addressed and what the solutions might be. This will need to include guidance around how the approach can be achieved in communities which were created by, and have evolved based on, traditional and long-established patterns of development. In particular:

• It would be helpful to get a steer in relation to how the approach would blend with other initiatives, such as the Town Centre First Principle.
• Consideration should also be given to applying the 20 minute concept to existing places by affording greater planning protection to features such as local employment areas and essential shops and services; Local Place Plans (LPPs) could have an important role in this.

It was suggested that identifying the levers and mechanisms to remediate existing poorly served communities and neighbourhoods will be challenging but will also offer opportunities, including alignment with the focus on vacant and derelict land.

Finally, it was stressed that the focus on placemaking should not deflect from the importance of ensuring new development is also well delivered. Associated points included that the construction and development industry needs to be steered towards building compact forms that prioritise people over cars, and that it will be crucial for the government to balance the need for housing delivery against the long term sustainability agenda which 20 minute neighbourhoods supports.

Key features of a 20 minute neighbourhood

In terms of what a well-functioning or flourishing 20 minute neighbourhood would look like, comments included that:

• A diverse range of services will be needed; this should take account of challenges such as tackling poverty and social exclusion.
• Local environmental quality will need to be considered; if we want neighbourhoods across Scotland to be places in which people are willing to spend the majority of their time locally, then it is crucial that all neighbourhoods are of an environmental condition that we can take pride in.
• Accessible open spaces, thriving natural assets and nature networks will all be essential components.
• Well-planned active travel routes will be key.
• Local heritage plays an important part in the scoping of what a neighbourhood is and provides opportunities for leisure and belonging.
• The right range of retail offerings will be required. As the retail landscape evolves through a highly challenging period, some care is needed around how 20-minute neighbourhoods will function alongside existing networks (and boundaries) of town centres.

It was also suggested that particular attention should be given to the needs of a range of different members of the community, including vulnerable groups, and specifically:

• Children and young people. It was suggested that 20 minute neighbourhoods need to be child-friendly to be sustainable and resilient. There was also reference to the UNICEF Child friendly Cities Model.
• The growing elderly population.

To ensure diverse needs are taken into account, it was suggested that it will be important not just to focus on people living and working in a particular place but to connect to wider organisations – for instance those representing the LGBT community, disabled people, or Gypsy/Travellers. A connected point was that plans around reducing the need to travel will need to take into account that some equalities groups will need to travel to access suitable support and social activities.

Further information or guidance required

It was suggested that a move to developing proper 20 minute neighbourhoods will need NPF4 to drive clear and robust change, alongside leadership from the Scottish Government, to influence local strategic plans and local authority decision making. This framework, giving a clear vision of what a 20-minute neighbourhood actually is, would be crucial to avoiding the phrase being co-opted and used to describe something that is less than what it should be.

In terms of the vison of what a 20 minute neighbourhood is, it would be helpful to have a short description of the concept and some clearer recognition about how the application of this may differ across different areas of Scotland.

Other suggestions included that clear criteria to help support decisions being made would be welcome, including around shifts towards sustainable transport, access to work, amenities and more inclusive housing provision. Other issues needing to be addressed, or about which clarity would be helpful, included:

• How 20 minute neighbourhoods can be delivered in rural areas. The principles are clear - in relation to reduced travel and access to local services - but how can this be delivered outwith the main urban centres?
• What services and employment opportunities should be expected within 20 minutes?
• Where settlement expansion is proposed, how this supports the concept of 20 minute neighbourhoods? How will it influence development management decisions for individual development sites?

There was also a call for national guidance in relation to density and levels of green space.

Strengthen community resilience

A focus on neighbourhoods and local living will help our places to adapt to the impacts of climate change. Our climate is getting warmer and wetter, and more frequent extreme weather events will affect people and places. In summer, more intense rainfall could increase surface water flooding. In winter, more frequent rainfall could bring increased flooding from rivers. Sea level rise could affect the viability of some coastal communities through flooding and erosion. Scotland's Climate Change Adaptation Programme promotes a joined-up approach to place-making that reflects local diversity.

Some places will be more vulnerable to the impacts of climate change than others: flood risk may be particularly acute in parts of our cities, whilst the liveability and accessibility of our smaller towns could be significantly affected by flooding events in the future. By future-proofing the design of our streets and buildings and investing in natural infrastructure, including creating and restoring habitats upstream in catchments, we can substantially reduce our communities' exposure to flooding and the risks from changing temperatures. This also has the potential to provide equality, health, economic and wellbeing benefits for communities.

Around 25 respondents made a comment specifically about strengthening community resilience. Some of these comments addressed aspects of resilience - for example in relation to health and wellbeing or the role of heritage and culture - that are covered under other themes.

Other comments welcomed the focus on the climate emergency and its impact on community resilience. Future-proofing the built environment was described as crucial to responding to the threat of climate change. The connection was also made between addressing surface water flooding and drainage and other themes covered in the Position Statement, for example in relation to blue/green infrastructure solutions and tackling vacant and derelict land. It was also suggested that NPF4 should reflect the Scottish Government's Policy Framework on Water-Resilient Places.

Particular reasons given for supporting NPF4 having a focus on flood risk included that:

• By addressing these issues proactively, the Scottish Government can save money in the long-term.
• It will improve social outcomes for those most vulnerable to the effects of climate change.
• The impact of rising sea levels on existing communities needs to be a national priority. There was a concern that the Position Statement is light on policy measures to adapt our places to rising sea levels.

In terms of overall approach, it was suggested that:

• Resilience will need to cover all communities; urban, rural and coastal.
• There will be a need to expand natural infrastructure, which in addition to building resilience against flooding will also bring many co-benefits, such as improved air quality and biodiversity.

There were calls for a whole-catchment approach to be taken to tackling flooding issues, with other suggestions including:

• Future proofing the design of our streets and buildings.
• Investing in natural infrastructure, including creating and restoring habitats in upstream catchment areas.
• Restricting development in flood risk areas that generate the need for additional flood risk management measures and which put pressure on drainage systems.

Connected to development, and the Scottish Environment Protection Agency (SEPA) Flooding Services Strategy (December 2020), there was a concern that future planning policy could severely restrict the current viability and future development of town centres in coastal locations, including in relation to residential development, and opportunities related to business and industry. This was connected particularly to how future brownfield development and the redevelopment of sites and buildings will be assessed.

In terms of the impact on particular sectors, or the role that particular sectors can play in promoting resilience against flooding, comments included that:

• Ports and harbours have a role to play in protecting communities from flooding, including by addressing flood prevention measures. It was suggested that local authorities should enter into early discussion with port operators and port authorities to ensure that flood protection requirements can be addressed whilst ensuring the requirements for strategic port infrastructure are fully addressed.
• Hydro schemes can sometimes provide the potential for water storage and can enhance natural flood prevention mechanisms.

In terms of specific changes that may be required to deliver against the range of policies and actions required, suggestions included:

• A review of the Flood Risk Management (Scotland) Act 2009, land ownership and agricultural support mechanisms.
• Clearer guidance to help define climate vulnerable communities.
• For some natural flood management schemes land ownership and gaining the agreement of landowner can be an issue and this needs to be considered and addressed in NPF4 and SPP.

Issues relating to resources were also highlighted, including that local authorities will need both revenue for staff and capital for projects. With regards to natural flood management, it was reported that, at present, the majority of projects undertaken in Scotland have been large scale and there was a call for much greater focus on the role that smaller developments have to play, including in their cumulative effects. This focus should be supported by national and local funding, including for retrofit projects.

Finally, in addition to flooding, it was suggested that other related themes should be covered within NPF4 including:

• Managing extreme storm water events.
• Temperature increases, risk of drought and drier summers, and the impact of increasing temperatures, including heat related mortality in older people. Improved water efficiency measures and infrastructure should be considered.

Promote inclusion and equality and eliminate discrimination

The Scottish Government is committed to promoting equality, tackling discrimination and fostering good relations between people in all of our communities. We want to ensure that every person and every community in our country is able to achieve their full potential. The changes we are making to the planning system aim to strengthen public trust and encourage engagement in decisions about the future of our places. The Planning (Scotland) Act 2019 introduces local place plans. Linked to the NPF and local development plans they will provide the opportunity for communities to influence the development of their neighbourhoods in a way which builds on community empowerment across Scotland. These and wider changes also underline the importance of engaging with a wider range of people to develop our places, including children and young people.

We will consider how our future policies can learn from the experience of COVID-19 including by responding to the Social Renewal Advisory Board's recommendations and learning from their work to capture our shared experience of delivering equality and social justice.

The spatial strategy will be supported by new policies to encourage more people to get involved in planning, to improve equality and eliminate discrimination. The 2016 National Standards for Community Engagement, together with the Place Standard Tool, provide a framework for involving people in planning their places. The Place Principle also recognises the need for a more joined-up and collaborative approach to decisions so that the combined impacts on places are understood and actively managed. We will look at how this can support techniques which encompass collaborative approaches to community engagement.

NPF4 is required to explain how our spatial strategy will contribute to improving equality and eliminating discrimination. People living in the most deprived areas and neighbourhoods are more exposed to environmental conditions and other factors that negatively affect health and access to opportunities – including those relating to transport, access to green space, pollution effects, housing quality, fuel poverty, community participation, and social isolation. Our future places and spaces need to be considered through the lens of gender, ethnicity, age and disability to ensure they are inclusive.

Many different planning policies have potential to directly and indirectly contribute to this, including those which aim to meet housing need, policies promoting community facilities and green space, and those relating to accessibility and design of the public realm. The development of the strategy is being supported by a range of impact assessments which will provide evidence on the impacts of policies on different people in society, and help to inform an approach which is fair for everyone

Around 80 respondents made a comment, with a number of these comments offering broad support for the focus on promoting inclusion and equality and eliminating discrimination.

There was support for efforts to strengthen public trust and involvement in the planning process, but also some concerns about whether or how this can be delivered. It was suggested that there is a lack of narrative about how the community involvement goals will be achieved.

Perspectives on the current situation

A number of respondents gave their own experiences or current impression of planning-related community engagement. These included that:

• Transparency is a key issue, including how decisions have been arrived at, who has been consulted and when. It was suggested that the 'nebulous' nature of the current planning system is both disheartening to the public and highly disempowering.
• 'Consultation' is often simply a public relations exercise and a presentation of what is going to happen. The current system can generate cynicism and a 'why bother' attitude when the active involvement of a community results in outcomes not supported by the community or their locally-elected representatives.
• Communities are regularly ignored by decision makers, both in policy formulation and in policy application and interpretation for individual planning applications.
• The current system enables decisions made locally to be overturned through the appeals system; this needs to be modified to ensure that the community view is a material consideration in planning decisions.

With specific reference to housing development, there were reports that communities have been concerned about the impacts of large-scale housing developments for a long time but have often been cast as the problem. It was also reported that many communities are exhausted from having to repeatedly respond to LDP consultations and modifications, planning applications, appeals and court challenges, sometimes for decades and that their huge voluntary effort is rarely recognised.

It was noted that the stated intention is that "the changes we are making to the planning system aim to strengthen public trust and encourage engagement in decisions about the future of our places". The behaviour of some developers, and particularly volume house builders, was described as "unreasonable and aggressive" and it was suggested that the planning system needs to protect communities from such behaviours and should identify and seek to proactively encourage positive 'developer' behaviours.

Others reported work that is already underway in their area around creating more inclusive approaches. Examples given included:

• The development of a Community Empowerment Strategy, currently being embedded within a Council and their Community Planning Partners, focused on fundamental change in how the planning authority interacts and delivers for their communities, based on the needs of their places/neighbourhoods.
• Foundation Scotland's work to support over 60 local decision panels linked to over 300 communities across Scotland involved in planning and distributing community benefit funds.
• Provision of a voluntary annual payment from an asset owner to a local community is a direct mechanism for supporting community-led development opportunities and should be encouraged.

Encouraging wider participation

One theme was in relation to encouraging and enabling a much wider range of people to get involved in planning-related issues. In terms of translating this aspiration into reality, comments included that consideration needs to be given to why current policy and rhetoric around participation does not appear to be translating into changes on the ground; what are the obstacles and how can they be overcome?

It was noted that the National Standards for Community Engagement and the Place Standard have now been in place for some time without significant change in how communities are involved in decision making processes. The associated concern was that continuing to draw on these might continue to be ineffective and there was a call for more explicit guidance on what 'collaborative approaches to community engagement' means.

It was also suggested that rather than referring to 'encouraging' more people to get involved in planning, stronger wording could send a clear signal about moving away from traditional consultation methods where people self-select to get involved; a more active 'involve more people in planning' or 'fully engaging to co-create plans' would be better. Other suggestions included:

• Making far more commitment to transparency in the planning system.
• Ensuring planners have the necessary skills to promote participation, possibly by having experts in participation in planning departments.
• Giving communities an equal seat at the table alongside developers and the public sector.
• Changing the targets for development and economic regeneration to focus on the processes - and more participatory processes - rather than the inputs.

It was suggested that the timing of engagement should also be considered, and that it should be undertaken early in the planning and design process where it can have the most influence. Further comments included that It should be prioritised during the local plan-making process and could be directly funded through planning application fees or planning obligations. Site-specific engagement and co-design should start very early in the planning process, beginning during or before pre-application discussions with housebuilders and other developers.

In terms of particular communities or groups of people, it was suggested that there needs to be a focus on:

• Harder to reach groups.
• Those who are digitally excluded.
• Older people, including by recognising that digital-only engagement can exclude many older people.
• Children and young people. It was noted that the Planning (Scotland) Act 2019 places a duty on planning authorities to ensure that children and young people are involved in the development of LPPs and that this is particularly important as progress continues towards incorporation of the UN Convention on the Rights of the Child (UNCRC) into Scots Law.

It was suggested that multi-generational planning must be given greater emphasis and that planning policy should recognise and respect that resilient communities will cater for all ages and not sectional or generational interests.

It was also suggested that the views of Community Councils should be given more weight, or that they should be given more powers.

Local Place Plans

Comments relating to LPPs included that they are a welcome, community-driven approach to support place-based solutions. It was suggested that they have the potential to be truly transformative, but that the current priorities and hierarchical structure of the planning system will make it impossible for them to become an integral part of that system. Other challenges or concerns associated with LPPs, included that:

• The financial implications may be prohibitive to the communities that need them most.
• It will be important to acknowledge the unconscious biases and privilege involved in implementing LPPs; the process is not accessible for all communities due to lack of diversity, social deprivation and poverty.
• They are often perceived as housing development documents, with established community groups often reluctant to take on the assumed bureaucracy of planning.
• They may undermine the efforts highlighted in A Plan for Better, Greener Places to prioritise regeneration to tackle geographic disadvantage.

In terms of taking LPPs forward effectively and meaningfully, it was suggested that:

• Framing LPPs in terms of planning for climate change adaption and land use could generate more interest from the wider public.
• The ambition should be for LPPs to be seen as setting a framework for development within local areas in keeping with the broad aims of NPF4.
• It will be important to ensure LPPs sit within each planning authority's spatial strategy, which in turn must reflect the necessary priorities to tackle the climate emergency.
• NPF4 should highlight the importance of developers responding appropriately to LPPs.
• Heritage Impact Assessments would help define and inform public engagement for production of LPPs.

Along with concerns that LPPs will not have the powers they need to drive transformation, there was a suggestion that the resources will not be in place to ensure that all communities will be able to engage with them equally.

Resourcing community involvement and consultation

Community resources

As noted above, resources were often at the heart of concerns about increased community involvement in planning, including in relation to LPPs.

A number of respondents raised concerns about the resource implications for communities. This was sometimes connected to issues discussed further under the delivery of good homes theme, regarding the balance of financial power between communities and developers.

It was suggested that there will be many areas and neighbourhoods in which communities will not have the necessary resources to take a lead in local place planning. The connection between planning authority and community resources was sometimes made, including that if the planning authority is insufficiently resourced to support the local community, they will not be enabled or empowered to participate in any meaningful way.

There was a call for additional resources and help to ensure that community engagement and involvement in the planning system is shared equitably. A specific suggestion was that constituted community groups and community councils should be given the skills training to help support and empower communities to help address inequalities and reflect community aspirations using LPPs.

Planning authority resources

From a planning authority perspective, concerns often centred around integrating additional duties, such as LPPs into already stretched planning resources.

There were reports that some areas are already seeing interest in LPPs from local communities. However, there was a concern that communities may have unrealistic expectations about the type of support that local authorities will be able to provide, and that the net outcome could actually be to further undermine, rather than boost, relationships between communities and planning authorities.

Promoting equality and tackling discrimination

Other comments addressed the focus on tackling discrimination. There was support for a much stronger ambition to use the planning system to address inequalities, particularly given what is known about environmental determinants of health and wellbeing.

It was suggested that one of the impacts of COVID-19 has been to highlight the importance of both a high quality home and local environment, and links were made to the development of 20 minute neighbourhoods and themes related to the need for high quality private and public outdoor space. These issues are returned to under themes covered below (including in relation to health and wellbeing, housing, place-based outcomes and achieving higher quality design), but in relation to inequality there was particular reference to the disadvantages stemming from inequitable access to high quality greenspace. The intention to introduce new policies for planning green spaces and to address play and playability was welcomed and there was specific reference to data at neighbourhood level enabling targeted interventions to be made where there is real inequity of access to greenspace.

In terms of how the planning system can be used or refocused to address inequity and inequalities, suggestions included:

• Using public interest tests, with outcome-based measures of the social impact of development.
• Ensuring equal rights between different interests in the planning system and planning processes, including an Equal Right of Appeal.

Improve our health and wellbeing

NPF4 will be redesigned to support the population's health and wellbeing and address longstanding health inequalities. We know that planning and place can compound problems such as poor diet and obesity, noise or air pollution, or it can be part of a solution. We will help to deliver a wide range of policies and strategies, including Scotland's six Public Health Priorities, the Active Scotland Delivery Plan and associated commitments to increasing active travel; the new air quality strategy which will replace the current Cleaner Air for Scotland strategy in 2021; Scotland's Diet and Healthy Weight Delivery Plan; Scotland's alcohol and drug harm prevention and reduction strategies; Scotland's Mental Health Strategy; Scotland's Social Isolation Strategy, and the National Health and Social Care Delivery Plan. The Place Standard also underlines the importance of better health outcomes from joined-up, targeted action in our places.

Tackling health inequalities, as well as supporting the everyday healthcare needs of communities, require a long term plan. The quality of places has impacts on our health and wellbeing, from early years to later life. Planning can do more to directly support positive health outcomes and improve childhood experiences. More people living in Scotland in the future will be older, and we will also need to factor this in to ensure NPF4 properly anticipates our future needs.

Our approach will look at how the built environment can help prevent the need for healthcare spend in the first place, and increase our healthy life expectancy, by improving public health. Inclusive and accessible design, access to infrastructure, including healthy travel choices, and other measures to improve health should no longer be regarded as optional or a discretionary benefit, but a firm requirement for development to address. We will look to promote high quality design and development in sustainably accessible locations that attract investment, create opportunities and alleviate fuel and transport poverty. Natural (blue and green) infrastructure helps build community resilience, and in turn supports our health and wellbeing. Access to quality green space also has direct benefits for both mental and physical health and can help to tackle the impacts of inequalities.

Around 30 respondents made a comment directly related to improving health and wellbeing. General comments included support for putting the needs of people and their health and wellbeing at the heart of the planning system, and for the focus on the six Public Health Priorities. A number of respondents commented on the extent to which the COVID-19 pandemic has both shone a light on the importance of locality as a foundation of resilient communities and introduced additional pressures on the health and wellbeing of those communities.

In terms of delivering improved health and wellbeing, respondents often highlighted the types of conditions or approaches that would be required, including supporting placed-based initiatives and solutions. In terms of particular groups that need to be considered when developing those solutions, there was reference to thinking carefully about the ageing population, and how we plan for the needs of older people in a way that is inclusive and sustainable, including maximising opportunities for independent living.

Other themes included:

• Delivering affordable housing in the right places. Creating settlements built to high densities, with mixed use development; offering a range of house types, employment types and activities within close walking distance of each other.
• The need for more localised access to facilities and amenities, including through the regeneration of deprived areas and town centres.
• Maintaining or creating access to open spaces or green networks.
• Prioritising active travel solutions. Creating settlements that are more walkable and where adequate public transport is readily available.
• Building resilience into local economies, including resilience to the impact of Brexit. There was particular reference to the impact of COVID-19 and Brexit on rural and island communities and Scotland's food and drink sector.
• The promotion of digital technology.

It was also suggested that NPF4 needs to introduce a human right to a healthy environment.

With specific reference to planning, health and food, points made included:

• Making a link between planning and place and diet and obesity, with reference to improving access to local healthier food outlets in order to improve health. However, it was suggested more could be achieved through the planning system to better manage the availability of hot food takeaways particular in the vicinity of schools and in deprived areas.
• That while the role of food growing in terms of health and wellbeing is recognised, there is a lack of clear reference to the benefits of food growing on the environment and tackling climate change.

However, it was also suggested that some of the issues referred to – such as alcohol and drug use reduction - go beyond the remit of planning. Conversely, there were issues which respondents thought had not, but should have been referenced. For example:

• It was noted that culture is not mentioned; a missing priority might have read "We have opportunities to express ourselves and feel a sense of connection and belonging in our communities".
• The role of NPF4 in helping to meet the objectives of the Road Safety Framework and its targets for cutting road deaths, and making roads safer for cycling, should be acknowledged.

In terms of how the various health and wellbeing-related polices and priorities can be delivered, suggestions included that:

• Public Health Scotland will have a role to play as a consultation authority.
• Close working with Health and Social Care Partnerships (HSCPs) might be required and this will have resource implications for both planning authorities and HSCPs.
• Greater cohesion and co-ordination across local authority areas will help ensure that employment, transport, housing, and living opportunities are developed in parallel and greater social division is not inadvertently built into the system.

Actively plan and support the delivery of good quality homes

Our homes make an essential contribution to our health and quality of life and we recognise that good housing is the cornerstone of strong communities. Our future homes will be at the heart of a spatial strategy that puts people first. We expect that our spatial strategy will focus on delivering a wider range of homes to meet the needs of our changing population, in the right places. Our Housing to 2040 route map will be a plan for a well-functioning housing system to deliver good quality, energy efficient, zero carbon housing and housing-related services. The vision will set out how, by 2040, we want our homes to be accessible, affordable, well designed and energy-efficient with the right homes in the right places to support both urban and rural communities. As a first step, we have already committed to review the current housing adaptations system and make recommendations on how best to improve and streamline the system and maximise the impact of investment. This will help to make best use of existing and planned housing stock to provide homes for as many people as possible and enable people to stay in their homes for longer. We will explore how planning can support this, including through an emphasis on type, accessibility, affordable living, quality, choice and energy efficient homes.

Our strategy will do more to guide housing to sustainable locations in a way which still allows for a local approach to be taken to address local issues and opportunities. We will encourage development planning to help shape this in different parts of Scotland. To significantly simplify the system as a whole, we will set out the land required in each local authority area to support local development plans over the life of the plan, informed by national analysis with local input. This will ensure a nationally agreed approach to housing land is used as a starting point for local development plans, and is aligned with local housing strategies and wider strategic investment priorities.

Our spatial strategy will also consider the long term changes that we can expect, including: sustainable rural living, prioritising sustainable and accessible locations; prioritising new homes on brownfield land where appropriate; redevelopment of existing buildings; city and town centre regeneration; and more people working remotely or more locally in the future. Policies will work with these challenges and assets to create great places to live now and in the future. Energy efficiency, in both new homes and the existing stock, is a key objective that will help address fuel poverty and contribute to meeting our climate change targets.

We want to see design at the heart of any new housing development. Details that may seem insignificant in isolation – such as – orientation; colours; shapes; heights; materials and access to public and play spaces – collectively create better development that supports our wellbeing. Our aim is to plan and facilitate the delivery of new places that anyone would be proud to call home.

To build the right types of homes that we want and the amount that we need, we need everyone to work together. Planning can do more to enable development, but it cannot do this on its own. We are considering how our policies can actively support delivery and provide certainty to house builders and communities by providing good, shovel ready land that can be developed in the short term whilst also maintaining a steady pipeline of land that will come forward in the future. We are looking at how we can incentivise house builders to build on sites that have already been deemed suitable for housing by providing a mechanism for more land to be released from the longer term supply, once building begins on sites that already have planning permission. In line with the recommendations of the Infrastructure Commission for Scotland, an infrastructure-first approach will play an essential role in ensuring allocated sites are a viable proposition to be built out in line with the plan's delivery programme.

Gypsy/Travellers require a positive planning approach so that not just their future, but their current accommodation needs are met. Guidance has previously been published on this, and we have taken steps to raise this with planning authorities. NPF4 is a real opportunity to expand on our current planning policy to support Gypsy/Travellers in their human rights to travel and in their aspirations to invest in their own homes, taking into account research on the distribution of existing sites across Scotland, as well as the provisions of the Planning (Scotland) Act 2019.

Around 80 respondents made a comment about planning and supporting the delivery of good quality homes. Overall, comments included broad support for NPF4 setting out a long term view of the homes required to meet Scotland's future needs. The references and connections to Housing to 2040 were also noted and welcomed. It was described as essential that NPF4 and Housing to 2040 complement each other. There was also occasional reference to the 2020 consultation on Scottish Planning Policy and Housing;^[8] and the issues raised by some respondents very much reflected those from the SPP and Housing consultation.^[9]

There were two broad but interconnected themes running though many responses. One of these reflected the focus on the SPP and Housing consultation, and the specific policy proposals set out within the Position Statement in relation to housing land supply and Housing Land Audits (HLAs). There was also a considerable focus on the ambition set out in the Position Statement that homes should be 'accessible, affordable, well designed and energy-efficient with the right homes in the right places to support both urban and rural communities'.

Longer term focus on housing land supply

Turning first to the specific proposals around housing land supply, a number of comments addressed the plan to replace the current focus on maintaining a 5-year supply of effective housing land with a longer term perspective.

Some respondents offered broad support for this refocusing. It was suggested that a strategic method of maintaining a sufficient supply of land for new housing would support the plan-led system more positively than the current arrangements. In terms of how the approach fits with other strategic and policy developments and priorities, comments included that:

• Emerging RSSs will help to focus housing priorities beyond local authority boundaries.
• The infrastructure-first approach (discussed further below) will be integral to the process of appropriate site selection.

Specific comments about how the approach could be taken forward and/or refined included that:

• A mechanism to enable the release of additional land, already strategically assessed through the plan-making process, would be supported, provided that the process is robust, and that delivery of existing priority sites has been exhausted.
• There should be a mechanism that allows local authorities to bring forward the 'next best option' when a housing land shortfall arises. This would require the planning authority and local community to work together, with input from potential developers, to identify the most appropriate sites.

However, others disagreed with the proposed changes, including querying why such a change is required given that the need for a 5-year effective supply does not mitigate against a longer term approach overall. It was reported that Development Plans are required to look ahead to year 20 currently and there is no reason for this to change.

It was also suggested that the longer term approach would work against the wider aims for resilient, inclusive new places and could be damaging to the timely delivery of homes. Specific concerns included that:

• It could create a constraint to the delivery of new private and affordable homes in the early part of the plan period (i.e. the first 5 years) and an over-reliance of non-effective sites that may never become effective/deliverable within the LDP period (10 years).
• This could create a requirement for public funding intervention to support delivery of non-effective land in a less co-ordinated manner. This approach will not only burden the public sector with debt but also reduce the number of all tenure homes delivered.

Rather than shifting to a longer term approach, it was suggested that the policy should be changed back to the requirement for at least a 5-year supply of housing land at all times. The compound method should be used to look at past delivery against the housing land requirement to ensure the housing needs and demands are being met and that the plan is meeting its housing land requirement.

If the Scottish Government proceeds with taking a longer term perspective on effective land supply, it was suggested that there must be appropriate checks and balances in the planning system. For example, the Gatecheck process should be used to critically assess the established housing land supply, not only in terms of site effectiveness but also site programming.

Housing Land requirement – a national approach?

When respondents commented, they generally supported there being a nationally agreed approach to setting the housing land requirement for each local authority. Reasons given for supporting this approach included that it would or could help streamline the preparation of LDPs and should facilitate a move away from endlessly debating housing figures and targets.

Further comments included that in setting targets for the scale of housing to be allocated in LDPs, it will be important to consider the ways in which local housing markets function across local authority boundaries and cognisance must be given to the spatial priorities in RSSs. It was also noted that the approach to establishing housing supply requirements must be appropriate to rural as well as urban areas, and there was a call for local input to ensure local needs are met.

However, others disagreed or noted concerns about taking a national approach to setting land requirements. Their comments included that it is beyond the remit of NPF4 to identify the 'land required' for housing in each local authority area. Associated points were that:

• NPF4 should be the place where the housing numbers required to meet need and demand are identified, by local authority area.
• The amount of land required to fulfil this need and demand will then be determined by a range of other LDP policies, such as housing types and densities, and these will vary spatially as appropriate.
• The planning system should not seek to micromanage housing land release but should retain some measure of appropriate housing land supply that allows for effective forward planning and monitoring.

Sustainable, balanced communities

In connection to policy related to identifying housing land and new housing development, a number of comments addressed the impact on existing communities. These comments generally referred to communities seeking to prevent large scale residential development. It was reported that local communities can feel powerless and defenceless, including when faced with the financial resources that major developers can deploy.

Location and number of homes

A number of the comments addressed the type, mix and location of housing development required going forward, with many considering the appropriate location for new homes and offering support for an approach based on delivering quality development to appropriate locations. The infrastructure-first approach is discussed in greater detail below but, in summary, and in specific relation to housing development, comments included that a proactive approach to providing land for homes and jobs with an appropriately assessed understanding of need and demand for housing provision is essential.

Respondents sometimes made the connection to the 20 minute neighbourhood approach, and that housing development plans should support the delivery of those 20 minute neighbourhoods.

Further, and returning to the effective land supply issue discussed above, it was suggested that local authorities should allocate a wide range and mix of housing sites in their local plans, at different sizes and scales, and in different locations to achieve a balance of tenures and dwelling types. This mix should be informed by rigorous evidence on local need and demand.

In terms of what would be considered appropriate locations for development, for some, the focus should be on existing settlements, and there was support for prioritising use of brownfield sites and vacant and derelict land. However, an alternative perspective was that brownfield sites with high ecological value should not be used for housing.

While it was acknowledged that it can be more complex and challenging to identify and deliver smaller sites within existing settlements, it was also suggested that meeting housing land supply requirements by large-scale site allocations brings significant disadvantages, including:

• Restricting activity to only those developers who have the capacity and knowledge to deliver large-scale projects. Limiting the participation of smaller developers reduces competition, the pace of housing supply delivery and consumer choice.
• Large-scale allocations tend to drive the type of mono-use relatively low density development that would fail to meet the principles of a design value standard focused on creating 20-minute neighbourhoods.

Use of vacant and derelict land is covered in greater detail at Question 4, but in summary comments raised in relation to housing development included that:

• The technical impact assessment of appropriate sites should be completed during the local plan process, rather than as part of site-specific planning applications further downstream.
• NPF4 should support local authorities and public bodies to change their approach to land disposals to bring more sites into use, valuing the wider economic and social benefits along with the disposal value. It could also explore ways to allow landowners and developers to spread the costs of bringing marginal sites into use.
• Communities should have a voice in defining whether and how the land should be developed.

Some respondents also suggested there should be a firm presumption against greenfield site development. In particular, it was suggested that NPF4 should protect important areas of green space and biodiversity from new developments, unless there is a highly significant economic and/or social justification to do otherwise.

Other comments about appropriate locations for housing development included that:

• Consideration should be given to incentivising building "on sites that have already been deemed suitable for housing" by introducing a presumption against the renewal of planning permissions for housing developments or, in the case of larger sites, a requirement for a phasing agreement whereby planning permission would be revoked if the permitted housing is not delivered.
• Developments should not lock-in car dependence, should be accessible by active travel and should be well served by public transport to ensure their long-term sustainability and resilience. It was suggested that no new housing developments which necessitate car ownership should be allowed.
• NPF4 should recognise that National Parks need their own approach to housing and should deliver on this. New housing should be focused on meeting local need and on people who are not in a position to buy or rent on the open market.

The density to which properties should be developed was also raised. On the one hand, some respondents were concerned about a perceived drive to building to a higher density, and a view that this does not lead to the creation of balanced communities, or a high quality living environment. It was suggested that the COVID-19 pandemic has shown how much we need space to live, and consideration should be given to reinstating minimum sizing standards or raising minimum levels of space provision.

An alternative perspective was that, particularly given the commitment to the 20 minute neighbourhood, density of development in cities and towns needs to be considered at levels sufficient to provide a viable market for goods and services and for frequent public transport services for journeys out of the area. It was reported that standard housebuilder development models are typically too low in density, particularly where greenfield development is needed, to support that approach. It was suggested that there is an opportunity to promote more sustainable land uses including higher density affordable housing in established urban areas, with more housing and other development on former brownfield land, helping to support our town and city centres.

Property type and tenure mix

Other comments addressed the type and mix of housing that is required or should be developed. It was suggested that NPF4 must provide clear policies that ensure the availability and delivery of a range of types and tenures of housing, and that any approach should be applicable in both urban and rural settings. It was also suggested that it will be important to focus on the needs and preferences of communities rather than simply allowing the profile of new housing to be decided by developers.

When assessing the property mix required it was suggested that consideration be given to intergenerational needs and requirements, so that all ages can feel a part of the community.

The particular issue of accessible housing supply was raised, including through calls for the needs of groups such as older and disabled people to be explicitly considered at every stage of the development of NPF4 and the other policies and strategies that will sit alongside it. Respondents also made a range of specific suggestions relating to the delivery of accessible housing provision and how NPF4 should enable and support that delivery. They included that:

• The review of accessibility standards needs to happen as a priority.
• NPF4 should introduce accessible housing-related targets and reporting and monitoring obligations on local authorities. A minimum of 10% of new housing should be built to wheelchair-accessible standards.
• Local authorities' obligation to meet the Public Sector Equality Duty when planning new housing should be embedded in NPF4.

Other suggestions in terms of how NPF4 should seek to frame housing development going forward included that the focus should be on mixed tenure approaches.

Comments often addressed the importance of new affordable supply, and it was seen as imperative that NPF4 supports the prioritisation of affordable housing development through the planning system. However, it was also suggested that policies to strengthen affordable housing provision should not apply a blanket increase to the provision of affordable housing above the current 25% requirement. The associated concern was that to do so could deter investment, particularly in marginal rural areas.

Some respondent wished to see a particular focus on social rented supply, with further comments including that there is good evidence that the benefits of growth and investment extend well beyond the housing sector – for example through supporting better outcomes and reducing costs to health and other services.

Other comments included that the development of new social housing could be supported by:

• Enabling local authorities to buy land at its existing use value for developing new homes and communities.
• Mandating that the first use for land made vacant by the demolition of social housing should be new social housing.

Rural areas and repopulation

The issue of affordable housing was also 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.

The connection was also made to a range of other factors, such as economic development and stimulus, that can help create resilient, rural communities. Examples given included in relation to renewable energy and food production and specifically aquaculture. It was reported that offering an appropriate range of housing to meet various needs, including having stock that will attract people to relocate to the region and take up economic opportunities, is critical.

One suggestion was that there should be an overarching presumption in favour of sustaining rural populations in planning policy and decisions. In terms of the scale, type and location of development, comments and suggestions included that:

• In rural areas, planning should rely on more fine-grained approaches than the standard HLA. Approaches should identify untapped housing demand and place less reliance on traditional measures of need and demand.
• The focus should be on existing settlements where possible, with new development looking to support the viability and vibrancy of existing town centres and smaller settlements.
• Small-scale developments are often required to enable people to take up employment. Opportunities for farmers to provide housing should be examined, including for their workers and for retiring farmworkers in order to facilitate succession planning.

Good quality, well-designed and energy efficient homes

Many respondents commented on the Position Statement's focus on good quality, well-designed and energy efficient homes. Those who commented generally welcomed putting design "at the heart of any new housing development". This was described as a critical step in the right direction, with NPF4 pivotal in delivering this in practice by ensuring that great design of both the built and natural environment is a requirement rather than simply a "nice to have". In terms of how good design can be facilitated, comments and suggestions included that:

• Design value standards would offer a key starting point but must be met by fundamental changes in the way design governance is practiced at the local level. The recommendations set out in Delivering design value: The housing design quality conundrum^[10] were reported as focusing on the ways in which local people are involved in decision making about where they live, the way that land is allocated for future housing, and how new development is masterplanned.
• A number of planning authorities have been successfully utilising design review panels which could be adopted more widely.
• It will be crucial to monitor the outcomes of NPF4 to avoid the current gulf between ambitious national objectives and poor implementation at the local level.

It was also suggested that the requirement to see "design at the heart" should not be solely a requirement for housing developments. If the aim is for mixed use, 20-minute neighbourhoods these will be comprised of multiple competing and supporting uses. Design should be at the heart of all development and from the inception. It was suggested that masterplans, and other formal design governance tools such as design codes, should be consistently employed as a formal regulatory mechanism for creating well-designed places. Further comments included that:

• Local authorities should establish a design vision and masterplan for allocated housing sites and should engage widely on its contents with both local people and development stakeholders.
• Reference to orientation, colour, shape, height, materials and access to public and play spaces can assist in reducing carbon emissions through use of solar gain.

With reference to high quality homes, it was suggested that this aspiration should be applied to all types of new buildings, with all development constructed to withstand the test of time.

In terms of energy efficiency, comments included that it is essential that homes are built to be as energy efficient as possible and future proofed. It was suggested that NPF4 can contribute to net zero carbon emissions by ensuring all new builds, private and social, achieve the highest standard of space and energy efficiency performance using Passivhaus or similar approaches. Specific suggestions included:

• Construction across all tenures must involve environmentally friendly carbon zero building materials.
• A major public sector-led programme of retrofitting existing housing.

Other issues

Existing housing stock: Housing and housing land policies in the NPF4 must be aligned with Scotland's emission reduction targets and follow the principles of a circular economy. As such, the main focus should not be on new development, but on revamping existing housing stock and other existing buildings and bringing empty homes back into use. The introduction of a regular national housing quality audit, to determine the quality of the housing stock and of new housing settlements in terms of climate, biodiversity, adaptability, amenity and other outcomes should be considered.

Housing adaptations: It was noted that the majority of the housing stock Scotland will have in 2045 has already been built and it was suggested that there is a need for better coverage of how we can sensitively and effectively adapt properties.

Different housing models: There was reference to many reports that have examined the potential benefits of promoting co-housing and other housing models that could allow older people to live well in the community. It was suggested that local authorities or the Scottish Government could support pilot projects.

There was support for proposals to promote self and custom build. It was suggested that self and custom build can make a vital contribution to housing delivery across Scotland. Further, and perhaps for rural areas in particular, this method of housing allows for a substantial quantum of local housing to be delivered, but without communities feeling that they are being 'overwhelmed'. It was seen as important that NPF4 offers further support to allow self-build it to make a greater contribution to housing in Scotland, and to increase its visibility to landowners who may then be emboldened to seek planning for a self-build project themselves.

Also with reference to promoting self and custom build housing and other innovative approaches to delivery, the reference to linking with the potential for Masterplan Consent Areas (MCAs) was noted. It was suggested that the MCA mechanism is well-suited to small-scale development of housing and may provide a means of controlling and encouraging development in rural areas that might otherwise not be permitted under housing in the countryside policies. However, the administrative resource implications for planning authorities of preparing and maintain a list of people interested in self-build was also highlighted.

Gypsy travellers: There was support for the expansion of current planning policy to support Gypsy travellers and a call for additional efforts to liaise directly with the Gypsy traveller community to ensure any strategy is fit for their purpose.

Promote an infrastructure-first approach to community development

It is crucial that the services and facilities we use on a day to day basis are fairly, easily and affordably accessed. A wide range of facilities are required to support our wellbeing including health services, transport, accommodation and support for an ageing population, education, energy networks, water and drainage, digital, community centres, places of worship, cemeteries and crematoria, libraries, retail including local healthier food outlets, markets, pubs, restaurants and cafes, banks, community growing space, green space, play and sports facilities and public toilets. During the passage of the Planning (Scotland) Act 2019, the Scottish Parliament emphasised the importance of planning these services, infrastructure and facilities for communities across Scotland. 20 minute neighbourhoods are a great opportunity to embed where appropriate, an infrastructure first approach to our future places.

NPF4 will help to prioritise the infrastructure investment needed for people to live better, and more locally, in the future. By taking an infrastructure-first approach to planning future development, we will be able to reduce the need to travel and minimise spend on additional transport infrastructure construction, contributing to an overall reduction in emissions from the transport sector. We will link with infrastructure plans to encourage place-based investment in local infrastructure to work alongside planned future housing developments. We will reflect and embed travel and investment hierarchies as set out in the Infrastructure Investment Plan and National Transport Strategy 2 within the appraisal and assessment of potential development options to inform the spatial strategy from the outset.

We will also explore the types of community services that will be required in the future, such as hubs for remote working and shared facilities, co-location and future-proofing. Natural (blue and green) infrastructure will be an integral part of a strategy for people, rather than an afterthought, helping to achieve multiple benefits for nature, communities and businesses.

The detailed consideration of infrastructure and service provision and implications are central to the preparation of spatial strategies and future land use decisions. Development plans can help to ensure the right infrastructure and services are in place at the right time to serve the needs of communities. We expect that the new requirement for an evidence report, examined through a 'gatecheck' early in the plan preparation process, will help to achieve this.

As part of the ongoing planning reform programme, we are carrying out a review of existing developer contributions mechanisms such as planning obligations. This was one of the recommendations made last year by the Scottish Land Commission in their advice to Scottish Ministers on land value uplift capture. The review will evaluate the effectiveness of planning obligations as a means of securing timely contributions to – and delivery of – the infrastructure and affordable housing that are necessary to create high quality places. This will help to inform NPF4's approach to infrastructure funding and delivery. We will also align with our Capital Investment Plan in terms of the role of private capital in developing sites of strategic importance to Scotland.

Around 75 respondents made a comment about promoting an infrastructure-first approach to community development, with many of these respondents making a broad statement of support. However, it was also suggested that the approach needs to be more clearly defined.

Other issues raised included that:

• The National infrastructure Delivery Plan is fundamental to achieving greater certainty and investor confidence.
• The infrastructure requirements set should be transparent, proportionate and viable. The ability to set out clearer requirements for infrastructure delivery will require additional capacity and training within local authorities and robust guidance on how it is to be delivered.

A number of the comments addressed the relationship between an infrastructure -first approach and communities. They included that:

• Further information about how the views of communities will be given more weight would be welcome.
• Community ownership should have a substantive part in NPF4's approach to infrastructure funding and delivery.

20 minute neighbourhoods and community services

A number of the comments addressed the infrastructure-related implications of 20 minute neighbourhoods, both in terms of the range of services required and the implications for travel, and particularly active-travel related infrastructure.

While respondents sometimes agreed that 20 minute neighbourhoods can offer an opportunity to embed an infrastructure-first approach to our future places, there was a call for clarity in terms of how this will be applied through policy and guidance. It was noted that some of the infrastructure essential for 20 minute neighbourhoods will be delivered by the private sector, and it was suggested that any plans need to clarify the delivery mechanism for these services.

In terms of the importance of those community services, it was suggested that referring to the approach as 'Infrastructure and Services first' would be helpful.

A number of respondents noted that COVID-19 has brought the need for more localised facilities and amenities into sharp focus, including in terms of helping to promote physical and mental health. It was noted that policy that may previously have been very much framed in relation to reducing emissions, such as reducing the need to travel, is also very clearly linked to helping to build community resilience and wellbeing. The ability to work from home or close to home was cited as an example, with the relationship to digital infrastructure noted. (Digital connectivity is discussed further at Question 3).

In terms of other infrastructure requirements, and particularly community facilities or services that will be required, comments and suggestions included:

• Community and employment remote working hubs and shared office spaces.
• Hubs for the sharing of resources, community transport schemes and charging hubs for electric vehicles.
• Spaces to undertake community activities such as community halls, gardens, parks and centres.
• Culture and heritage facilities (beyond libraries).

Respondents also highlighted some of the challenges to taking an infrastructure-first, 20 minute neighbourhood focused approach, including that caution needs to be applied in a rural context as the level of services provided in remote rural areas necessarily cover much wider geographies, not just in terms of distance but also time. The critical importance of good digital infrastructure, particularly for remote rural and island communities, was highlighted.

Housing development

It was suggested that an infrastructure-first approach, with a proactive approach to providing land for homes and jobs is essential. It was suggested that detailed consideration of infrastructure and service provision should be central considerations for future land use decisions and development plans; there was support for ensuring that place-based investment in local infrastructure works alongside planned future housing developments, and it was suggested that a long term vision should place individual development proposals within a wider context.

There was interest in the new requirement for an evidence report, examined through a 'gatecheck' early in the development plan preparation process. However, there was a query about how this would help ensure the right infrastructure and services are in place at the right time to serve the needs of communities.

There was a particular note of caution that a meaningful 'gatecheck' will be very difficult to achieve unless there is a statutory alignment of how money is invested in infrastructure. This was described as an issue of timing and it was suggested that a system of front ended strategic investment in new infrastructure capacity is needed, so that development can be brought forward in a planned and strategic manner following that investment, rather than a piecemeal approach.

Other suggestions relating to how the infrastructure-first approach should work alongside housing development included that core infrastructure requirements should be programmed and aligned with the pace and phasing of development.

As at a number of other themes, the particular challenges of developing and delivering an infrastructure-first approach in a rural context were highlighted. For example, it was observed that, in a remote rural context, there may be very little if any spare capacity – meaning that new development will require new or upgraded infrastructure. At the same time there may be little or no mainstream speculative housing delivery, with the only significant new build supply coming from Registered Social Landlord (RSL) development. As a result, the costs of any new infrastructure required needs to be covered from the public purse and it is planning of this spend in a forward manner, plus inclusion of these costs within the accepted costs of RSL housing delivery grants, that is required. In relation to developer contributions (discussed below), there will be no significant if any cross subsidy from private sector.

It was also noted that in areas where the majority of housing developments are small-scale or single property windfall developments, developer contributions are not sought. These issues were sometimes connected to the review of developer contributions (discussed below) and how benefits can be obtained and delivered in rural areas where RSLs are the only volume house builder.

Developer Contributions

The most-frequently raised theme was in relation to developer contributions, and specifically the Position Statement's reference to a review of existing developer contributions mechanisms such as planning obligations. The reference to the review, including looking at securing timely contributions to and delivery of infrastructure and affordable housing was often noted and generally welcomed. Other comments included that further detail on the review would be welcome.

Comments on the existing approach, and specifically section 75 agreements, included that they are a well-established mechanism for securing appropriate developer contributions but that their use needs to be more:

• Consistent, better aligned to policy and case law and less time consuming and unpredictable.
• Alive to the significant viability pressures that can arise from unpredictable and disproportionate developer contribution 'asks'.

A number of the comments went on to focus on how the planning obligations approach should be structured going forward. It was noted that a wide range of facilities are required to support new housing development and that the Position Statement refers to a number of these. One perspective was that it will not be reasonable for housing developments to cross-subsidise all of these services and a clear assessment will need to be made in relation to how these will be funded on an equitable and fair basis in line with policies, circulars and guidance on planning obligations.

It was suggested that a clear approach to developer contributions will be important in ensuring consistency across Scotland, although it was also suggested that planning obligations are a vital element in delivery of local infrastructure needs and should not be centralised.

Suggestions for how any overall approach should be framed included that the Scottish Government should recognise that wider investment in infrastructure and services is required and that local authorities must be better supported in using their powers proactively to front-fund and deliver infrastructure. It was also suggested that any approach should also align with the Capital Investment Plan in terms of the role of private capital in developing sites of strategic importance to Scotland.

Further comments included that:

• The Scottish Government could provide a clear and transparent methodology at the national level for quantifying contributions, for example in areas such as education provision.
• Consideration could be given to reducing the options for non and deferred payment of contributions.

With specific reference to looking at land value uplift capture, comments included that a significant proportion of the uplift in land value from major public infrastructure works should be made available to local authorities to invest in infrastructure and public services. However, it was also suggested that the idea of land value capture does not sit well with developer contributions. The concern was that there would be very little incentive for selling land for development, and limited inclination for developing and improving. Land value sharing, carried out through negotiation and recognition of the part which is played by landowners, developers, local communities, and local authorities, was described as a more realistic approach.

Other issues

Waste: A number of comments were made about the infrastructure for waste, including in the context of an infrastructure-first approach. They included that:

• Waste management infrastructure is not only a fundamental part of Scotland's economy in its own right but, at the very least, plays a vital role supporting the delivery of new housing, not only in processing of waste during its construction but also once it is occupied. NPF4 should help prioritise the waste and recycling infrastructure needed in planning for resilient communities.
• Some waste materials cannot at present be managed within 20 minutes of a neighbourhood or community; for example clinical waste or unavoidable food waste must travel further to be treated and this makes both environmental and economic sense.

Heat: Large scale development - both domestic and commercial or industrial - can provide an 'anchor' for major heat loads. As a source of major and reliable heat load, such developments would help mitigate the costs of installing a heat network which, once in place, would likely provide a more attractive prospect for other, smaller developments within the vicinity to connect to the network. NPF4 might therefore offer some steer on the criteria of an energy masterplan, and how those criteria would be enforced by local authorities.

Sustainable travel: Achieving more sustainable travel is discussed further below, but some respondents also raised the issue in relation to an infrastructure-first approach, and the reference to helping to "minimise spend on additional transport infrastructure construction".

In addition to welcoming the approach, comments included that it is vital that new developments are designed around sustainable and active travel infrastructure at the outset and that the planned approach will only be realised if there is more sophisticated, joined-up working between different agencies of government at a strategic level, and between different local authority actors at the local level. Clarification was sought about whether minimising spending on additional transport infrastructure construction applies to all transport infrastructure or to those elements whose externalities would not aid in reducing emissions from the wider transport sector.

Nature-based and blue/green infrastructure: This theme is also discussed in its own right below, but at a broader level it was suggested that an infrastructure-first approach represents a good opportunity to embed a nature-based solutions approach towards new installations at both a network and local level. The statement that "Natural (blue and green) infrastructure will be an integral part of a strategy for people, rather than an afterthought" was welcomed but it was suggested this could be further strengthened by ensuring it is defined and included in the definition of an infrastructure-first approach.

Enhance and expand natural infrastructure

Our strategy will enhance and promote open and green spaces and green networks as an integral part of successful place-making. By bringing together green and blue infrastructure, we will modernise our existing policies to ensure that our natural networks are nurtured and expanded to support our health and wellbeing, and contribute to our climate and biodiversity goals. We are aiming to strengthen our policy so that blue and green infrastructure are not an added benefit but an integrated requirement for future planning and development. For example, there is scope for new policies for planning green spaces and play. We also expect that much can be learned from innovation in green infrastructure planning as demonstrated by the Glasgow and Clyde Valley Green Network Partnership and Central Scotland Green Network.

Blue and green infrastructure will be an essential part of our approach to building our long term resilience to climate change and can also contribute to reducing emissions and carbon sequestration. In particular, opportunities for natural infrastructure to address the long term risk of flooding, water and drainage issues, temperature management and everyday livability of places will inform our approach to planning and enhancing our spaces and places. As part of this, consideration will also be given to the integration of ecological networks to protect and restore biodiversity and ensure that habitats and species can adapt to a changing climate

Around 35 respondents made comments about enhancing and expanding natural infrastructure. A number of respondents either noted the importance of natural (blue and green) infrastructure and its contribution to resilient communities or welcomed it being a focus on the Position Statement and NPF4. The recognition that the management and maintenance of natural infrastructure is essential was also welcomed.

A number of comments went on to address how the strategic and policy framework for planning can ensure that blue and green networks support good placemaking and contribute to delivering climate change goals. Suggestions included:

• Defining what is covered by natural infrastructure and including it within the definition of an infrastructure-first approach. All key terms should be clearly defined and described to avoid confusion and to reduce the chances of 'under delivery'.
• Requiring all local authorities to undertake an Ecological Coherence Plan to be used to inform decisions on green and blue infrastructure investment.
• Opportunity mapping under a Scottish Nature Network to help indicate key investments in green and blue infrastructure that could give greatest benefits to local communities.
• Building on existing local green infrastructure guidance. There was reference to local guidance which embraces the idea of 20 minute neighbourhoods and ensures that, as well as maximising active travel opportunities, we maximise opportunities for green infrastructure.
• Introducing statutory standards at a national level which ensure a future-proofed provision of local parks and green spaces. There was a connected concern that if green space is not required at a statutory level, it is vulnerable to a lack of investment.
• Developing a benchmark threshold of protected spaces for all local authorities to achieve as part of their Open Space Strategies and Play Sufficiency Assessments, and more rigorous signposting to existing guidance that is well established and widely used.

Enhancing nature networks

There was support for nurturing and expanding natural networks, with greenspace described as critical social and physical infrastructure that provides essential services to people and the environment. As at other themes, some respondents noted how the COVID-19 pandemic has shone a light on the health and wellbeing benefits of having access to good quality greenspace, but also on spatial inequalities across the country.

In terms of the creation and augmentation of natural networks, one perspective was that this should be a requirement of all new developments of a certain type and scale. A different perspective was that provision or maintenance of green or blue spaces should be encouraged and facilitated within appropriate developments, but that there should not be a 'blanket' approach to requirements, as these will differ, depending on the location of developments.

However, it was also noted that not all blue/green infrastructure is natural and that existing features including heritage assets can form part of blue/green infrastructure. It was suggested that the protections brought in through historic environment legislation have played a part in ensuring this infrastructure – such as the canal network, gardens and designed landscapes and historic battlefields - continues to deliver multiple benefits.

There was also a call for the development of a Scottish Nature Network. It was suggested that a piecemeal approach to the delivery of green and blue infrastructure and the protection and development of natural habitats does not allow Scotland to efficiently tackle the twin crises of biodiversity loss and climate change. A national approach could achieve a strategic network of natural and/or semi-natural habitats that can help to protect, enhance and restore nature, which in turn provide multiple benefits for people and climate. The approach could include the identification of suitable areas for nature-based solutions such as tree planting, peatland restoration, flood risk management, coastal management and natural flood management measures.

Flooding, drainage and water resilience

Other comments reflected some of the themes covered above in relation to creating resilient communities and included that blue/green infrastructure has a key role to play in natural flood risk management and flood prevention. Further comments and suggestions included that:

• In setting requirements for sustainable drainage systems (SuDS), policy should specify fully integrated, above/over ground solutions where possible in order to deliver maximum benefits; this approach also fits with the infrastructure-first approach principles.
• Any policy on SuDS requirements should be supported by illustrative design-led guidance that also specifies the requirements and arrangements for management and maintenance.
• There should be a much greater focus on the role that smaller developments have to play, including cumulatively.
• Where possible, flood management needs to be supported by national and local funding to also encourage retrofit projects.

There was also reference to the Scottish Government's Policy Framework on Water-Resilient Places, and it was noted that recommendations in the framework include a blue/green infrastructure-first approach in placemaking and master-planning. It was noted that this extends to new developments and retrofitting.

Achieve more sustainable travel

We will refocus our existing transport policies to specifically draw out how land use planning can build in sustainable travel choices. Scotland's second National Transport Strategy set out a vision for a sustainable, inclusive, safe and accessible transport system, helping to deliver a healthier, fairer and more prosperous Scotland for communities, businesses and visitors. NPF4 is being prepared alongside the second Strategic Transport Projects Review and we expect, in time, that future Regional Spatial Strategies will align with Regional Transport Strategies. The Active Scotland Delivery Plan; the 2030 Vision for Active Travel; and the Active Travel Framework also provide an important policy framework for NPF4 to align with.

By guiding development to the right locations, we can reduce the need to travel unsustainably. To achieve stronger local communities and reduce emissions that are harmful to the environment and our health, and in line with the NTS2 sustainable travel hierarchy, there will need to continue to be a sustained and significant shift away from use of the private car towards walking, wheeling, cycling, public transport, taxis and shared transport. This will need to be embedded in the land use decision making process and will require policies that can be directly and consistently applied, to avoid compromising on our climate change and health objectives.

Around 35 respondents made a specific comment about achieving more sustainable travel, albeit that sustainable travel solutions, and promoting active travel, were often referenced at other themes. The focus on achieving more sustainable travel was welcomed, including refocusing policies to draw out how land use planning can build in sustainable travel choices. However, it was also noted that the principle of integrating land use and transport planning and reducing the need to travel have been embedded in transport and planning policy for a number of years. It was suggested that there needs to be a strengthening of the intent and definition around the principles set out.

There were also a number of references to the importance of NPF4 aligning with the NTS2 and the key role of NTS2 in providing the right infrastructure in the right place at the right time if the infrastructure-first approach is to be delivered. There were also references to the second Strategic Transport Projects Review (STPR2), the 2030 Vision for Active Travel and Active Travel Framework and the Capital Investment Plan.

In terms of the importance of transport infrastructure, comments included that to be considered resilient, a community needs to have a range of travel options which meets its needs. Suggestions as to how this can be achieved included:

• Re-empowering and properly resourcing regional transport authorities with the ability to plan the whole system of transport around people's needs, integrating different modes of transport, with integrated ticketing and price caps.
• Prioritising development in locations which have access to existing public transport networks, or improved infrastructure through the STPR2, will ensure onward journeys to/from those developments can be taken by either active travel or public transport ahead of car travel. This would be in line with the sustainable travel hierarchy.
• Building in sustainable travel choices to new development is essential to address inequalities and reduce transport emissions. With specific reference to bus travel, it was reported that although developer contributions can support bus service provision for an initial period, they do not ensure long term sustainability of service provision, nor the delivery of an integrated network of travel choices. It was suggested that this needs to be addressed if sustainable and well-connected places are going to be achieved.

A number of other comments also addressed active travel and included support for the Position Statement's focus on its importance. The multiple benefits that active travel can bring to local communities, including improved health and wellbeing, reduced inequalities and benefits for national emissions and local air quality, were all noted. It was also observed that, although active travel is more closely aligned with sustainable transport objectives and the well-being economy, infrastructure for walking, wheeling and cycling as a whole threads through and connects all parts of NPF4. It was also suggested that active travel options have a vital role to play in providing better, safer connections between settlements and within settlements.

In terms of delivering these benefits, suggestions included that:

• A new definition for a 'strategic active travel highway network' that meets the aspirations of the Active Travel Framework and STPR2 should be agreed and included in NPF4 as a National Development.
• National walking and cycling infrastructure, with a path network to be identified, mapped, expanded and promoted as a strategic national infrastructure project, could be transformative.
• Practical and workable solutions need to be promoted for supporting active travel at the local level.
• New housing developments should be required to include the creation of safe, segregated active travel routes into city and town centres and to local services.
• Mobility hubs can provide a sustainable and accessible alternative to private car ownership. Smart ticketing offers and other incentives across a network of hubs can assist social inclusion by helping those less able to afford to pay for their travel and encouraging those on the margins to try what is on offer.
• It is important that work is done to tackle some of the key barriers to children and young people participating in active travel.

As under other themes, some of the particular challenges associated with delivering the right travel infrastructure in rural areas were highlighted. In particular, the tensions in a remote rural context between bringing forward good opportunities for quality homes in places that would benefit from them and development being guided to places which can currently be sustainably accessed was highlighted. Solutions and options identified included:

• Striking a balance which allows development where it creates a positive impact on biodiversity or where it can be part of an EV charging infrastructure-first approach which helps contribute to net-zero carbon outcomes, for example.
• Isolated rural communities can benefit from mobility hubs to extend the reach of the public transport network, improving accessibility and connectivity.
• The design of networks which promote dedicated cycle routes, and use of electric bikes with appropriate charging opportunities, can play an important role.