Fourth National Planning Framework - position statement: consultation analysis

A Plan for a Wellbeing Economy

The third key outcome is a Wellbeing Economy. The Position Statement highlighted intentions to: create healthier, fairer and more prosperous places and ensure future development contributes to a green, sustainable, and inclusive economic recovery; identify and support development that works with our assets, key sites and opportunities for strategic investment; take a flexible and enabling approach to future business and employment uses; support development in the parts of Scotland where quality jobs and investment are most needed; and support development that helps to maintain and strengthen strategic transport and digital connectivity.

Further detail on the Plan for a Wellbeing Economy was provided under ten headings:

1. Support a sustainable and green economic recovery

2. Reduce inequality and improve health and wellbeing

3. Provide certainty and flexibility to encourage investment

4. Grow our food and drink sector

5. Support sustainable tourism development

6. Stimulate culture and the creative industries

7. Transition to a circular economy

8. Promote sustainable resource management

9. Secure strategic transport connectivity

10. Improve digital connectivity

Question 3: Do you agree with our current thinking on planning for a wellbeing economy?

General comments

General comments at Question 3 included points about the principle of a wellbeing economy, and how achievable this is likely to be. Some respondents saw 'The Wellbeing Economy' as a poorly defined concept, with reference made to the extent to which understanding of the concept differs across stakeholders (and particularly the general public). It was suggested that a clearer definition of what a wellbeing economy 'looks like', and what it adds to current strategic priorities, is required if the concept is to underpin NPF4. This included a perceived need to explain or justify why the concept is being introduced, and what 'wellbeing' means in relation to the economy.

There was also concern that NPF4 will maintain a focus on economic growth as part of a 'wellbeing economy', and suggestions that continuing economic growth may not be compatible with the key principles of a wellbeing economy – for example improving health and wellbeing, delivering fairer communities and achieving net-zero objectives. Some respondents wished to see NPF4 acknowledge the potential tension between economic growth and delivery of a wellbeing economy and make clear that wellbeing and environmental objectives should over-ride consideration of economic growth where they are mutually exclusive.

It was also suggested that "healthier, fairer and more prosperous places" have been strategic priorities for the Scottish Government for some time, but that limited progress had been made over this period. These respondents expressed some scepticism around the potential for NPF4 to achieve real change. This also appeared to be connected to concerns raised regarding the financial and resource cost of achieving the outcomes set out in the Position Statement, and a view that significant investment will be required to achieve real change.

There was some concern that policy support may not be sufficient to achieve health/wellbeing and environmental outcomes relating to a wellbeing economy. Some called for the introduction of stronger legislative or policy requirements around reducing the impact of development on communities and environmental quality.

Support a sustainable and green economic recovery

Collaborative spatial planning at a national, regional and local scale, will help us to recover from the impacts of COVID-19 through a sustainable, green economic recovery, as recognised in the 2020 report by the Advisory Group on Economic Recovery. We have an opportunity to actively promote strategically important locations for future investment and business growth as part of a coherent vision for sustainable, inclusive growth.

Our policies on planning for business development will recognise the fundamental role Scotland's natural capital plays in supporting our economy and will aim to achieve sustainable, inclusive growth by protecting and investing in our natural assets and supporting the health and wellbeing of our communities. This will support Scotland's ambitions to build a wellbeing economy. Planning can enable sustainable, inclusive growth by attracting investment, sustaining future employment, restoring natural capital and seizing the new economic opportunities created by our transition to a net-zero, circular economy. Our natural assets can play a key role in securing our path to net-zero by 2045 and achieving the long-term vision of our Environment Strategy.

Our strategy will be informed by emerging regional scale spatial and economic strategies which will align with city and regional growth deals and the work of Regional Economic Partnerships. For example, early thinking in Argyll and Bute indicates the significant potential for place-based approaches that unlock the potential for jobs that make use of the area's natural resources, such as aquaculture. Orkney's emerging spatial strategy sets out a strong vision for development that capitalises on the area's exceptional natural energy resources and marine connections, underpinned by an emphasis on innovation and research. Moray is exploring how its natural assets can help to build a place-based approach to future development and investment in key sectors, such as the whisky and outdoor recreation industries. Community wealth building is also being explored at a regional scale, for example in an emerging regional spatial strategy for North, East and South Ayrshire which links with the area's growth deal and economic strategy and promotes place-based investment. Sustainable tourism is emerging as a key theme for regional spatial strategies to consider, including for the National Parks. Enabling business growth, alongside visitor management and low carbon accessibility are shared themes that can inform a national spatial strategy that will guide us to 2050.

Around 85 respondents commented on supporting a sustainable and green economic recovery in their answer to Question 3.

Many respondents expressed their support for this focus, and the role of NPF4 in supporting the transition to a net-zero, circular economy. There was also support for specific elements of the approach to a sustainable and green recovery as set out by the Position Statement including a spatial strategy targeting investment in areas and sectors where jobs and investment are needed most, and which can help to deliver wider economic and environmental targets. Some respondents suggested more linkages with the 'plan for net-zero emissions'.

There was also specific support for the Position Statement recognising the role of natural capital in supporting a green recovery, community wealth building, and ensuring the wellbeing economy is inclusive of communities across urban and rural areas. Respondents cited multiple examples of local policy and development projects focused on securing a wellbeing economy through a sustainable and green economic recovery, including some where respondents identified a need for support to ensure these developments can contribute fully to NPF4 policy objectives.

However, most of those providing comment on a sustainable and green economic recovery raised concerns or issues they would like to see addressed through NPF4. These are summarised below.

Priorities of a wellbeing economy

Some respondents wished to see further detail on how NPF4 can balance purely economic benefits of development with key aspects of a wellbeing economy such as health and wellbeing, inclusivity and equality. This included suggestion that there remains a tension between the commitment to continuing economic growth and wellbeing economy outcomes as set out by the Position Statement. These respondents suggested that placing wellbeing as the central driver of the economy would require a commitment to removing inequalities and poverty but would not necessarily identify continuing economic growth as a key focus. Indeed, it was suggested that the target of net-zero emissions may not be achievable alongside economic growth. Some called for NPF4 to provide a strong message that development should contribute first to the needs of Scotland's people and environment, before consideration of economic growth.

In contrast, others raised concerns that it is not the right time to prioritise human and ecological wellbeing, and that NPF4 should maintain a focus on sustainable economic growth to support recovery from the COVID-19 pandemic. Respondents referred to the pandemic having contributed to higher levels of ill health, redundancies, unemployment and poverty, and suggested that a strong focus on sustainable economic growth is required to address these issues.

More generally, some respondents also wished to see further detail on how the wellbeing economy will function for Scotland, and how its success will be measured. This included a specific focus on what 'sustainable' means in relation to a green recovery and wellbeing economy, and a view that a new set of success measures are required which focus on health and wellbeing, social justice and reduced inequality. Reference was made in this regard to the National Performance Framework and UN Sustainable Development Goals.

Regional approaches

There was specific support for NPF4 taking a local and regional approach to achieving a green economic recovery. This included suggestions for NPF4 to be aligned with indicative Regional Spatial Strategies, to take account of learning from City and growth deals and, more generally, to ensure a strong role for communities in the development of a wellbeing economy.

However, there were also calls for more detail on how this will work in practice, and how funding and investment will be shared at a regional level to ensure equality across urban and rural regions. This included a suggestion that NPF4 needs to set out a clear policy change to rebalance economic growth across Scotland, to close the gap between the highest and lowest performing regions.

Respondents also expressed support for the examples of local and regional projects cited by the Position Statement in relation to supporting a green recovery. However, some wished to ensure that LPPs and local planning decisions would not add a further barrier to the development required to support a green recovery.

Role of particular sectors

Responses made reference to a range of specific sectors (including from respondents active in these sectors) as having a role to play in a green economic recovery, highlighting the extent to which these contribute to the Scottish economy and/or are aligned with climate change targets. These comments most commonly related to renewable energy and aquaculture/marine development. Respondents also referred to tourism, food and drink, housing development (and particularly affordable housing development), sustainable transport, life sciences, and forestry.

However, others saw a need for NPF4 to ensure that some sectors improve their practices towards a green economy before they receive further support through the planning system.

Skills pipeline

Some respondents argued that NPF4 should address the skills pipeline to ensure the right people are equipped with the right skills to support a green recovery, including reference to specific sectors such as forestry and the historic environment where there was a perceived need for further skills development. The college sector was also seen as having a role in supporting a skills-led economic recovery.

Other issues

Other issued raised included suggestions that:

• The role of the historic environment should be acknowledged alongside Scotland's natural assets in supporting a wellbeing economy and green recovery including, for example, through supporting skilled jobs.
• The robustness of the evidence base available to enable the planning system to support a green recovery is a matter of concern. This included specific reference to limited access to biological data for planning authorities.
• All proposed National Developments should be assessed against a clear set of criteria to ensure they contribute to a green recovery.

Reduce inequality and improve health and wellbeing

A shift from economic growth towards a wellbeing economy provides us with an opportunity to consider how development and investment can help us to address longstanding health and wellbeing inequalities.

Sustainable and inclusive growth will depend on a planned approach to ensure that development happens in locations that provide the greatest benefits for society as a whole. Economic performance and access to employment vary across Scotland and spatial planning has the potential to close the gap between the highest and lowest performing areas by intervening to create opportunities which are accessible to everyone. The spatial strategy will need to consider where we want to target future investment, and the land and premises required to support the sectors that we expect to grow in the future.

We will continue to actively enable investment in sustainable locations across Scotland – both urban and rural – including key investment sites and strategic opportunities for Scotland to attract international investment. Our approach will aim to strengthen the economy of our diverse cities and towns, and enable development that supports a vibrant rural economy. In the past, industrial and business areas have tended to be located at a distance from residential areas. As our economy continues to evolve, there may be scope for greater integration of work and living as inter-related land uses. The climate change agenda may benefit from a strategy that broadens choice and flexibility, for example through the provision of community hubs and flexible workspaces. These types of initiatives could complement other strategies such as revitalising our town and community centres and helping to create footfall that supports local traders.

This strategic approach to future investment and infrastructure will be brought together with our other aims of localism and quality of place to provide a coherent spatial vision for Scotland as a whole. We may need to make choices to ensure that all areas play to their strengths with complementary, rather than competing proposals. Digital infrastructure, remote working and our current re-evaluation of the future working environment are expected to feature in a new approach to planning the distribution of our future jobs.

Around 35 respondents commented on reducing inequality and improving health and wellbeing and there was broad support for NPF4 having a role to play. This included specific support for:

• A focus on delivering jobs in the right sectors and right places.
• Recognising the need for a more inclusive and fairer set of economic growth metrics.
• NPF4 to recognise what is expected to be an increasingly digital future.
• An emphasis on health and wellbeing (including mental health) as key elements of a wellbeing economy.

There was a view that NPF4 provides an opportunity to address negative health and wellbeing impacts in some places, and to create more places which support good health and wellbeing. A number of specific locations and sectors were referenced as in need of more targeted support and development. The COVID-19 pandemic was also described as having demonstrated an opportunity to redistribute jobs to more remote rural areas as part of a wider strategy to support repopulation of these areas.

It was suggested that NPF4 should require a clear indication of how a development will generate specific community wellbeing and equalities outcomes prior to a planning application decision being made.

Reducing inequalities

Respondents saw a role for NPF4 in ensuring the move to a wellbeing economy is delivered in a fair way. This included suggestions that NPF4 should ensure the framework for economic development is aligned with public health principles and commits to tackling health inequalities, supports economic success measures which value public health and inclusivity, and seeks to ensure that the burden of climate change adaptation and mitigation is borne by those most responsible.

Digital connectivity was seen by some as a key area of inequality, including reference to differences in the quality of digital connectivity across Scotland, and evidence of deprived households being impacted by digital poverty. There was support for NPF4 incorporating the ending of digital poverty and inequality as a key policy priority. However, there was also some concern that support for digital working could amplify existing inequalities, for example if this is at the expense of jobs where digital connectivity is not a viable option. Concern was also raised regarding potential for a shift to more home working to add to house price inflation in rural locations, potentially limiting access to housing for local residents.

Gender was also highlighted as a key measure in relation to current inequality within Scotland's economy and employment. Specific suggestions for NPF4 seeking to address gender inequalities included incorporating analysis of the gender pay gap and women's representation as part of local and national strategic planning.

Focus on health and wellbeing

A range of approaches were suggested to ensure a focus on health and wellbeing across the planning system, including Public Health Scotland being made a statutory consultee, and health impact assessments being introduced alongside Equalities Impact Assessments. It was also suggested that NPF4 should seek to support the creation of places that enable sustainable travel and active lives, as key contributors to health and wellbeing.

Some respondents wished to see NPF4 more clearly acknowledge the importance of mental health as part of a move to a wellbeing economy. This included suggestions for a new framework for strategic investment in mental health services and infrastructure and supporting development which enables mental health benefits such as outdoor access, leisure and recreation.

There was also a suggestion that NPF4 should recognise the potential contribution of green spaces, including green belt, to community health and wellbeing. It was noted that access to green space has been particularly important during the COVID-19 pandemic. Respondents also highlighted the benefits of green space in terms of the wellbeing of communities, and cited evidence that lower income households and Black, Asian and minority ethnic communities are disproportionately impacted by loss of green space. Some wished to see NPF4 provide additional protections for these areas.

Recognition of the contribution of particular sectors to health and wellbeing was also suggested including:

• Culture and the historic environment.
• Food production – via aquaculture and farming on land - by contributing to food security and ensuring access to locally produced food. Reference was also made to UN Sustainable Development Goals as of relevance to a wellbeing economy, including 'zero hunger' and 'good jobs and economic growth'.

Strengthening local economies

There was support for localism in cities and town centres, and development of 'community hubs', including suggestions that these could support better community engagement in the planning system. However, it was also suggested that an emphasis on redevelopment of vacant and brownfield land could stifle choice of housing location. Some wished to see NPF4 recognise that self-sufficient places can be achieved within new development in suburban or rural locations. There were also suggestions that NPF4 must recognise that town centres will still play an important role in local economies, in addition to development of town centres as 'cultural hubs'.

Some respondents wished to see more detail on the types of work and business that are considered suitable for integration with residential spaces, including suggestions that specific criteria should be applied to ensure such integration does not reduce community wellbeing.

There was a perceived need to strengthen the evidence base available to identify the sectors and spaces where development is required. This included reference to gaps in evidence on employment land requirements and business audits.

Provide certainty and flexibility to encourage investment

Planning can stimulate investment and growth by providing certainty. At the same time, recent months have shown that our planning policies must be flexible enough to respond to rapid and significant economic and social change. Whilst many of our existing policies on business and employment remain relevant, we can improve on them so that they reflect our aspirations for a wellbeing economy.

We will consider how this can be supported by local development planning which is underpinned by a stronger evidence base at the local level for local land use decisions. We will review the role of business land audits and consider the extent to which they link with local economic strategies. We will also explore whether the resilience of investment sites would benefit from fuller risk assessments to help business adapt to the impacts of climate change.

Around 20 respondents commented on providing certainty and flexibility to encourage investment. A number of these respondents expressed their support, particularly in the context of supporting the post-COVID economic recovery. It was seen as important that NPF4 strikes the right balance between the certainty of a plan-led system, and the flexibility required to respond to social and economic change.

Respondents also referred to a number of specific sectors seen as having potential to contribute to government objectives, and where there was a perceived need for NPF4 to do more to encourage investment. These included renewable energy, ports, transport infrastructure, aquaculture, and recycling and waste management.

There was also support for other specific points raised by the Position Statement in relation to encouraging investment. These included reviewing the role of business land audits and their links to local economic strategies and attracting investment to support employment across sectors.

Other issues seen as impacting how NPF4 can provide certainty and flexibility to encourage investment are summarised below.

Consistency

There was a call for NPF4 to provide guidance to enable a consistent approach to business land audits and economic strategies. This included consistent methodology for the assessment of employment land requirements and for development of local economic strategies (including forecasting of need and demand, opportunities and threats). These were highlighted as key elements in ensuring a robust local and national evidence base for land use decisions.

Flexibility

Some respondents suggested that robust policy will be required to ensure the planning system effectively supports a wellbeing economy, and that flexibility in the planning system should be grounded in process (rather than policy). MCAs were suggested as a means of providing the necessary flexibility.

There was a perceived need for greater flexibility in the planning system to encourage investment in ports, including suggestions that attracting investment will be essential in enabling ports to contribute to climate change objectives. This included specific suggestions of additional flexibility around employment uses within operational ports and the scale of port development.

Greater flexibility was also suggested with respect to elements of the waste management system, including with respect to waste inputs and to site opening and operational hours.

In contrast, some respondents suggested that flexibility is already built into Scotland's planning system, and that the system is well placed to respond to economic and social change (for example as compared with planning systems based on zoning and fixed legal terms). Nevertheless, the potential value of the additional certainty that a plan-led system can provide for investors was recognised.

Other issues

Other issues raised included calls for:

• Closer alignment of private capital and government funding to deliver infrastructure.
• Specific support for cross-funding of development of serviced employment land or buildings, alongside housing development. It was noted that this would also support delivery of the 20 minute neighbourhood policy set out under 'A Plan for Resilient Communities'. It was also suggested that NPF4 should help to protect viable employment uses, considering options for suitable marketing periods before alternative uses are considered.

Grow our food and drink sector

Planning can support our internationally renowned food and drink sector by protecting our natural assets that underpin production and facilitating the development of production and processing facilities.

This includes fishing and aquaculture, farming, food and beverage manufacturing. It is significant for employment in the islands and accounts for a high proportion of employment across rural Scotland. Our current policies recognise the importance of high quality agricultural land but there is scope to more fully reflect the importance of land as a finite resource that delivers many benefits for society. Wider policies will inform our approach. For example, the Land Use Strategy sets out that where land is highly suitable for a primary use this should be recognised in decision making so that multiple benefits can be secured. Links with our rural policies, flood management, water catchment management and carbon storage will also be important.

We will look to enable the sustainable growth of the finfish and shellfish sectors, including by guiding new development to coastal locations that reflect industry needs and take into account wider marine planning. Scottish aquaculture and its wider supply chain is of particular significance for some of our most remote rural communities. Farmed salmon has one of the lowest carbon footprints by production of health protein foods. The industry's growth strategy for 2030 aims to double the economic contribution of the sector to £3.6 billion and double the sector's jobs to 18,000. The Scottish Government continues to work with the Aquaculture Industry Leadership Group to achieve this.

Around 30 respondents commented on growing our food and drink sector. Some respondents expressed their support for the priority assigned to growing Scotland's food and drink sector. This included a focus on the economic significance of the sector, particularly for rural and island communities, and reference to the role of aquaculture in the Scottish Government's Economic Recovery Implementation Plan. Support for the Position Statement also included reference to evidence indicating that salmon farming has accounted for the majority of the food and drink sector's economic impact. Specific opportunities for further growth in Scotland's food and drink sector were also cited.

It was noted that the Position Statement does not provide a definition of the term 'high quality agricultural land', and that 'prime agricultural land' is a long-established and clearly defined term. Some respondents argued NPF4 should provide stronger protection for prime agricultural land, for example by removing the current permission for development which is 'essential as a component of the settlement strategy'.

There was also an objection to the distinction between aquaculture and land farming made in the Position Statement, and a suggestion that NPF4 should provide stronger support for development of the latter alongside aquaculture. It was also suggested that NPF4 should reference opportunities for community growing and green spaces to support a local food system.

In relation to integration of planning and land use, it was suggested that a Scottish Nature Network could provide a means of co-ordinating action to support a green recovery.

Aquaculture

Some respondents raised concerns about proposed support for the aquaculture sector and the reference to salmon farming having 'one of the lowest carbon footprints by production of healthy protein foods'. These respondents cited what was described as 'growing evidence' of the adverse impact of salmon farms, particularly in sensitive marine environments. There was a perceived role for NPF4 in ensuring that growth in the aquaculture sector is not to the detriment of surrounding seafloor and wildlife. This included particular concern regarding development of salmon farms within Marine Protected Areas, with some suggesting that further salmon farm development should be discouraged or prohibited in these areas. Some also saw a need for review of existing and planned salmon farms to assess and mitigate adverse environmental impacts, and to identify suitable and unsuitable locations, before further salmon farming development is supported by NPF4.

However, others suggested that the aquaculture sector has been changing rapidly in recent years and wished to ensure that NPF4 is based on an accurate picture of the sector and its current environmental impact. The extent to which sustainable growth in the aquaculture industry is important in tackling the challenges facing rural and island communities was also highlighted. This included reference to diversifying rural economies, helping to reverse population decline, and supporting local infrastructure.

It was also suggested that NPF4 could include provision for potential new aquaculture sectors such as seaweed harvesting, bivalve shellfish and algae production.

Assessing proposals

Several respondents noted the reference to 'criteria for assessing aquaculture proposals' in the potential policy changes relating to the food and drink sector. Some wished to see further detail, with suggestions that the criteria should reflect other relevant policy and guidelines (such as National Marine Plan Interactive (NMPi) Good Environmental Status characteristics) and the most recent developments in marine research and evidence. Respondents also provided detailed suggestions regarding the areas they would like the criteria to address including guidelines on aquaculture waste, seabed condition, water quality, incorporating risk-based spatial tools, and net servicing/changes. It was also suggested that NPF4 should include detail on the role of SEPA and/or Marine Scotland in assessing proposals against these criteria.

Some comments regarding the assessment of aquaculture proposals appeared to reflect the respondent's wider view that NPF4 requires more detail on how the planning system can strike a balance between supporting economic growth and ensuring environmental and economic sustainability of the food and drink sector. The World Bank principles were referenced here. Some were of the view that the Position Statement places greater emphasis on 'growth' rather than 'sustainability', and there were calls for NPF4 to include stronger protections to ensure development is sustainable and meets environmental protection standards.

Some respondents expressed support for NPF4 being informed by RSSs and regional economic strategies, including examples of this approach already being taken forward by planning authorities. Regional Marine Plans (RMPs) were noted by some as a means of managing aquaculture development, and of ensuring that the cumulative impacts of development are considered alongside conservation objectives. It was suggested that all aquaculture, including salmon farms, should be integrated into RMPs.

It was also suggested that:

• In relation to the spatial approach to salmon farming and other aquaculture development, NPF4 should reflect the recommendations of the Salmon Interactions Working Group regarding development control for salmon farms and NMPi guidelines.
• A distinction should be made between open-cage and other forms of salmon farming. It was suggested that if open-cage farming is deemed unsuitable in a specific location there may still be scope for use of other technologies (such as semi-closed or closed cage farming, or vertical ocean farming) to reduce or remove environmental impacts.

Support sustainable tourism development

Our strategy and supporting policies will include a renewed focus on enabling sustainable development that helps to strengthen and grow our tourism sector. Tourism plays a major role in our economy – in 2018, spending by overnight tourists and day visitors in Scotland was around £10.4 billion. This generated around £12 billion of economic activity in the wider Scottish economy and contributed around £7 billion to Scottish GDP.

The Sector also employed 218,000 people accounting for 1 in 12 jobs in Scotland. The sector has been significantly impacted by the pandemic. The Scottish Tourism Emergency Recovery Group, and now the Tourism Recovery Taskforce has provided a partnership-driven response. The Taskforce report focuses on recovery, investment and stimulating demand. Whilst overall levels of employment in Scottish tourism are highest in Edinburgh and Glasgow, as a proportion of all jobs tourism is of particular significance in rural areas such as Argyll and Bute and Highland. Tourism will have to continue to adapt to further influences including climate change and its impact on travel, and the economic challenges ahead. NPF4 will reflect the priorities set out in our Tourism Strategy.

Our many great places and exceptional natural environment, landscapes and wildlife are assets that the sector depends on, and so a sustainable, planned approach to future development will help to ensure the long term future of the industry. Destinations such as island and rural locations often have a 'carrying capacity' that is placed under threat by the influx of large tourism numbers. Consequent impacts on the environment and communities have to be managed, through visitor management facilities, investment in appropriate infrastructure or by striking the right balance between tourism accommodation and maintaining an adequate housing supply to support and retain the existing population. Temporary accommodation for the sector's workforce in rural areas is often a challenge that can be addressed by positive planning policies.

Around 35 respondents commented on supporting sustainable tourism development. Many of these respondents expressed their support for the focus on enabling sustainable tourism development and the commitment to build on investment through the Rural Tourism Infrastructure Fund. The economic significance of tourism at a national and regional level was noted, with references to a particular need to support recovery following the COVID-19 pandemic. Respondents also expressed specific support for the need to strike a balance between providing the infrastructure required to support tourism, while protecting the interests of local communities and minimising environmental impacts.

Supporting sustainable approaches

There was a suggestion that greater clarity is required on what 'sustainable' means in the context of NPF4 supporting tourism. This included specific suggestions that NPF4 should make reference to climate resilience and net-zero emissions, in addition to economic sustainability.

Some respondents highlighted the extent to which the approach to sustainable tourism development will need to be tailored at a local and regional level, recognising the uneven distribution of tourism attractions and infrastructure. Some discussed opportunities for sustainable development to support growth in tourism activity, including in terms of specific locations/developments and/or key tourism sectors.

However, other respondents referenced locations where it was felt that the focus should be on making existing tourism more sustainable and inclusive, rather than seeking further growth in overall tourism activity. It was also suggested that NPF4 should recognise links between sustainable tourism and other policy areas such as cycling and active travel, the food and drink sector rural businesses, and climate change targets (including a suggestion that a reduction in international travel and increase in 'eco-tourism' could provide opportunities for growth in tourism in Scotland).

There was support for the proposed link between NPF4 and the Tourism Strategy, although it was suggested that the degree of regulatory and economic flux in the tourism sector would mean that the strategic approach will need to be reviewed over time. It was also suggested that NPF4 should link with regional strategies to ensure the approach to sustainable tourism development takes account of regional needs and opportunities.

There were calls for NPF4 to set out clearer policies that recognise the economic importance of tourism in enabling recovery from the impact of the COVID-19 pandemic and supporting development that improves environmental and landscape quality. It was suggested that this should include developments to expand existing tourism accommodation and infrastructure, as a platform for future growth.

Tackling adverse impacts

The importance of striking the right balance between promoting places as tourist destinations and ensuring the wellbeing of the settled community was highlighted. This included a particular focus on the impact of short-term lets on housing supply with some respondents calling for a review of existing legislation and policy around tourism accommodation. Specific examples of tourism development were also cited which were perceived to have been at the expense of the wellbeing of an existing community.

Respondents also cited several examples of local approaches to tackle adverse impacts of tourism on communities, but there was a view that a national policy framework and guidance is needed from NPF4 to inform local approaches.

Stimulate culture and the creative industries

We will recognise the importance of creativity, culture and the arts to our collective identity and future places. Culture defines our diverse places and many of our buildings reflect our architectural, social and economic history that contributes to part of our sense of wellbeing, heritage and economy. Regeneration and development has used culture and creativity to inspire new futures, from Dundee Waterfront where the V&A has helped to transform the city centre, to Paisley where creativity has been used to stimulate a new future for the area. Despite this, culture has not featured prominently in our suite of national planning policies to date and there is significant scope to improve on this in NPF4.

Scotland's Culture Strategy sets out a vision for strengthening and transforming culture, and using it to empower communities as well as individual lives. The strategy aims to ensure that culture is embedded into all policies, so that its transformative potential can be fully realised. It outlines the significance of the creative industries as our second fastest growing sector that accounts for 3.3% of employment in Scotland and is made up of numerous small businesses.

Around 15 respondents commented on stimulating culture and the creative industries. There was support for a stronger focus on culture and the creative industries. This included a particular focus on the potential contribution of these industries to health and wellbeing and as a significant economic sector, with potential to support regeneration of deprived areas. Some respondents also expressed a view that a wellbeing economy requires a stronger role for communities, for example through community businesses and social enterprises. Local examples were provided of policy seeking to support cultural and creative industries.

Respondents also expressed support for the reference to protection of existing cultural assets and the importance of ensuring clear links between NPF4 and A Culture Strategy for Scotland. This included comments noting that the Culture Strategy includes the historic environment as a key element of Scotland's cultural assets, with some wishing to see more explicit recognition of the historic environment within NPF4. The role of archaeology in the planning system was also highlighted as helping to preserve Scotland's cultural heritage.

However, while no respondents expressed disagreement with support for culture and the creative industries, some felt that NPF4 needs to provide a more detailed framework setting out how the planning system can achieve this, with guidance for developers, investors and planning authorities. Issues raised included that:

• There should be a stronger emphasis on the role of community-led approaches to stimulating culture and creative industries, and in supporting the wider shift to a wellbeing economy.
• NPF4 should include the specific aims of the Culture Strategy.
• A stronger emphasis is required in relation to cultural heritage assets and archaeology, including a requirement for clearer policy and guidance.
• Culture could be a key thread running through NPF4 and in planning across Scotland.

Transition to a circular economy

We will update our policies on zero waste to reflect the new opportunities arising from a shift towards a circular economy. Planning can support development which reflects the waste hierarchy, prioritising the reduction and re-use of materials, and facilitate the delivery of new infrastructure required to achieve this. Our policy on this was updated in 2016 and the Climate Change Plan and emissions reduction targets are relevant, together with the more detailed policies including the forthcoming ban on landfilling of biodegradable municipal waste. At a European level, the European Commission also launched a Circular Economy Action Plan in March 2020, which aims to mainstream and support action in this area, including in relation to buildings and construction.

Minimising construction waste and promoting the sustainable use of the existing built environment has an important role to play as part of this. Infrastructure to support the circular economy, including for collecting, sorting, processing and re-manufacturing materials, that can help reduce the demand on primary sources of materials, will also need to be considered. This might take the form of increasing capacity at existing sites or the provision of new sites and there will be choices to be made on opportunities for example for co-location of facilities.

Around 30 respondents commented on transitioning to a circular economy. Reference to the circular economy within the Position Statement was welcomed, with responses emphasising the importance of a transition to a circular economy including for wider climate change policy priorities and to support economic recovery. The role of the circular economy was also highlighted specifically in relation to the forthcoming ban on biodegradable landfill. There was also support for recognition of a role for the existing built environment and of opportunities for existing and new economic sectors to respond to the transition to a zero carbon Scotland. The effect of the COVID-19 pandemic in hampering progress on elements of the circular economy (for example through reintroduction of single use plastics) was noted and it was argued NPF4 should seek to protect and build on progress made prior to the pandemic.

Some respondents wished to see more clarity on the specific policy direction, including detailed policy objectives and targets, in relation to the circular economy. In this context, it was noted that the delayed Circular Economy Bill could offer additional clarity.

In terms of specific aspects of the circular economy, there were calls for greater detail on the role of waste management particularly in respect of:

• The infrastructure required to support the transition to a circular economy, both reflecting the 'waste hierarchy' and minimising exporting of Scotland's waste.
• Greater clarity on how NPF4 will promote sustainable use of the existing built environment.
• Earlier involvement of the resources and waste sector in the planning process as part of a 'whole systems approach'.
• A clear policy on the role of various waste disposal methods in response to the forthcoming ban on biodegradable landfill.

Respondents offered a range of views on the potential role of incineration in response to the ban on biodegradable landfill. These included suggestions that increased use of incineration would not be consistent with the commitment to the waste hierarchy and reference to alternatives seen as more consistent with the overall objectives of the Position Statement. Some respondents also expressed concern around the extent to which support for energy from waste development is compatible with a circular economy and net-zero targets, although others suggested that appropriately designed developments can have a positive role to play in relation to climate change targets.

It was also suggested that there will continue to be a requirement for landfill provision for non-recyclable and non-combustible waste, and that proposals which meet wider sustainability and climate changes objectives should be supported.

Other points on transition to a circular economy included that:

• NPF4 should support a circular approach to the built environment. This included calls for detail on how NPF4 will seek to minimise construction waste, and proposed policies to support a 'whole life approach' to development.
• There should be more detail on the role of LDPs to support the transition to a circular economy.
• Greater emphasis should be placed on 'repair and reuse', and the additional infrastructure required to support this element of the waste hierarchy. There was a perception that support for the circular economy has been too heavily focused on recycling, and a view that NPF4 should encourage a greater focus on repair and reuse, particularly in relation to 'high impact material streams'.
• Reference to the circular economy could be expanded to include the sharing economy, for example to support co-working spaces and sharing of vehicles and equipment.

It was also noted that the list of suggested National Developments does not appear to include any circular economy projects.

Promote sustainable resource management

Our spatial strategy and supporting policies will continue to set out proposals and policies that safeguard workable mineral resources whilst ensuring demand for primary materials, where required, can be met in a safe and acceptable way, including continuing to safeguard air quality. The substantial decline in the demand for coal for energy production, suggests there is also an opportunity to review our policy approach for this sector.

Peatland also has a critical role to play as a nature-based solution in supporting our climate change targets as well as providing many other long term benefits, and so our strategy and policies will help support both the phasing out of the use of horticultural peat and our investment in the restoration of peatlands. We will also consider how we can restrict further development on peatland given its role in carbon sequestration.

We have already committed to including our policy position on unconventional oil and gas in our draft NPF4. This is currently contained in a Statement of 3 October 2019 and sets out that the Scottish Government does not support the development of unconventional oil and gas in Scotland. This means development connected to the onshore exploration, appraisal or production of coal bed methane or shale oil or shale gas using unconventional oil and gas extraction techniques, including hydraulic fracturing and dewatering for coal bed methane.

Around 20 respondents commented on promoting sustainable resource management.

In relation to peatland, there was support for the reference to preservation and restoration, and in particular the proposed restriction of further development on peatland to ensure its role in carbon sequestration. This included calls for more detailed guidelines and tools to enable planning authorities to control operations and development on peatland and reference to existing guidance or codes that could inform NPF4. It was also noted that the Climate Change Plan includes specific targets for peatland restoration and it was suggested that these should be reflected by NPF4.

Respondents also highlighted potential tensions between preservation of peatland and other aspects of NPF4, including concerns around a 'blanket ban' on development on peatland. These included reference to:

• The continuing use of peat in some industry sectors.
• The extent to which an outright ban on development on peatland could severely limit development activity in some parts of Scotland.
• Balancing the net carbon benefits of renewable energy development with potential impact on peatland.

There were calls for NPF4 to set out a clear policy framework for how planning authorities should weigh the relative benefits of peatland preservation against renewable energy or other developments that can offer net carbon benefits.

It was also suggested that further detail is required regarding management of other finite resources such as conventional oil and gas which are still used across the transport, energy and other sectors. There was a perceived need for NPF4 to include a clear strategy for sustainable minerals supply. This included a suggested role for community participation and ownership in promoting more sustainable resource management. Reference was made to the importance of a sound evidence base to support the Scottish Government's strategy for mineral resource management, including citation of specific data sources.

There was also support for the proposed review of the Scottish Government's policy approach for coal for energy production. This included respondents noting that any fossil fuel development approved during NPF4 would still be in operation by the target date for Scotland to reach net-zero emissions. It was noted that coal is no longer being mined in Scotland, and that LDP requirements should be updated to reflect this.

There was support for the Position Statement's reference to the current moratorium on unconventional onshore oil and gas extraction, and a suggestion that NPF4 should clarify the Scottish Government's position.

Secure strategic transport connectivity

Our spatial strategy will work with, and plan for, our future strategic transport network. Connectivity, physical and virtual, is essential for inclusive growth. National Planning Framework 3 identifies key connections including airports, high speed rail, long distance walking and cycling routes and some freight facilities as national developments. The National Transport Strategy and Scotland's Economic Strategy recognise the importance of strategic transport connections, links and gateways. Brexit will heighten the importance of connectivity with external markets in the future.

Our new strategy will inform, and be informed by, the second Strategic Transport Projects Review, identifying key transport hubs and intermodal nodes that support connections within Scotland and with the wider world. We recognise the importance of long-term strategic road, rail, air and sea networks and will consider their role in relation to health and quality of life for their neighbouring communities.

There are plans to decarbonise Scotland's passenger railways by 2035, scheduled flights within Scotland by 2040 and an ambition to phase out the need for new petrol and diesel cars and vans by 2032, with public bodies taking the lead to phase these out from 2025. We will also ensure that rural and island communities can travel sustainably to access the services they need where those are not provided locally.

The new technologies which are emerging to make vehicles less dependent on fossil fuels will contribute to achieving the net-zero target. However, that will not be enough. We will not plan infrastructure to cater for forecast unconstrained increases in traffic volumes. Instead, we will manage demand and reduce the need to travel by unsustainable modes. Not taking steps to effectively manage demand for car use is no longer an option and our approach will focus on encouraging people not to make unnecessary journeys. Some of our existing infrastructure will need to be adapted for anticipated climate change that may make their location more vulnerable to erosion, flooding, land instability or heat for example.

Freight also has strategic transport needs and it may be that larger settlements, towns and cities require to identify land where distribution centres can be located to enable long distance goods vehicles to be unloaded ahead of onward distribution by smaller and alternatively fuelled vehicles and cargo bikes. Consideration of the location of additional dedicated rest stops or services areas will also be needed.

Connectivity is emerging as a shared priority, and a challenge to be addressed across the range of spatial scales; from local, through regional to national – this is evident in the emerging regional spatial strategies. Whilst the importance of transport links is recognised, we will need to consider how strategies can take forward an infrastructure-first approach which minimises the need to travel. We will use existing infrastructure capacity to direct where growth can happen in a way that is consistent with the travel and infrastructure investment hierarchies.

Around 30 respondents commented on securing strategic transport connectivity.

Managing car use

There was support for interventions to manage demand for car use, and to avoid "unconstrained increases in traffic volumes". Respondents also saw potential links between managing demand for car use and other NPF4 priorities such as achieving net-zero emission targets and promoting inclusion and equality (by reducing the exclusion faced by those without access to a car). Some also referred to links with town centre regeneration and active travel networks.

However, it was suggested that significant work and investment will be required to achieve the required shift away from car use, particularly outwith urban centres. Comments here focused on a perceived need for investment to improve access to other transport options, particularly public transport, and for better integration of active travel networks. However, some respondents also saw a continuing need for infrastructure improvements to make car use more efficient, or reflected on the extent to which managing demand for car use will require significant behavioural changes around how people live and work in Scotland.

Respondents reported a significant variation across Scotland in access to alternatives to car travel. This included a focus on the extent to which access to suitable affordable public transport remains a barrier for rural communities. Some suggested that NPF4 will have to help reverse long-term decline in access to public transport in some areas.

It was also argued that the Position Statement includes apparently contradictory statements in relation to transport connectivity, with a conflict suggested between support for all forms of strategic transport and recognising the need to manage demand for car use. There was a call for clarity on how the planning system will balance climate change targets with objectives for economic growth in circumstances where these are not aligned. This included specific reference to the Climate Change Plan target to reduce car traffic by 2030.

Reducing freight emissions

There was also support for improved transport connectivity to reduce emissions associated with freight. This included reference to an anticipated increase in the role of alternatives to road freight, and support for the role of distribution centres in enabling onward freight distribution by cargo bikes and other small vehicles. It was noted that the COVID-19 pandemic has accelerated growth in demand for logistics and freight infrastructure, and that NPF4 may have to respond if this demand remains at current levels.

Other issues

Other issues raised with respect to strategic connectivity included that:

• NPF4 must recognise the limits of decentralisation, and the extent to which it is unlikely to be possible for some jobs and workers. There was a perceived need to ensure sufficient transport connectivity between localities to enable necessary travel for work.
• NPF4 should make explicit reference to noise as a key aspect of the impact of transport networks on communities, including consideration of noise as part of the assessment of potential national developments.
• The potential impact of climate change on existing transport infrastructure should be recognised, including reference to specific locations seen as most vulnerable (particularly to coastal flooding).

Finally, a need for NPF4 to respond to changing global markets was identified, particularly in relation to Brexit and renewable energy growth. The potential for these global changes to increase the strategic importance of Scotland's transport connections and gateways with countries outwith the UK was also suggested.

Improve digital connectivity

We will reflect future plans for investment in digital infrastructure and consider implications for our long-term spatial development. Our spatial strategy will continue to support the roll-out of digital infrastructure across Scotland. This will play a key role in maintaining and growing our communities in both urban and rural Scotland, and has potential to form the foundations of a new emphasis on localism.

Scotland's Digital Strategy aims to stimulate innovation and investment in digital technologies and industries across Scotland. Connectivity has a central role to play in unlocking the potential of our places and the economy and in opening up more remote parts of Scotland for investment and community expansion. We have already created permitted development rights for digital infrastructure and recently consulted on proposals to expand these further. These proposed changes need to be delivered in a way that minimises the negative impacts on the natural and built environment and safeguards air safety. Physical distancing arising from COVID-19 has also demonstrated that the planning service is well-placed to drive forward digital engagement in planning and decision making, creating opportunities for a wider range of people to get involved in more strongly influencing the design of their places.

Around 30 respondents commented on improving digital connectivity. Some respondents expressed their general support for the inclusion of improved digital connectivity as a priority for NPF4, including noting its importance in enabling more home-working and reducing travel. The increase in home-working during the COVID-19 pandemic was suggested to have reinforced the importance of access to digital connectivity for all, not only in terms of home-working but also communication and access to services.

However, it was also suggested that the COVID-19 pandemic has highlighted the inequality of access to high quality digital connectivity in Scotland. This included comments around the link between economic deprivation and digital poverty, and to specific barriers such as cost, rural infrastructure and digital skills. It was suggested that NPF4 should consider the underlying drivers of digital inequality and set out where the planning system can help to address these.

Other comments on digital connectivity included suggestions that:

• Lower income workers may be less able to adapt to a shift to more digital working, and that without better access to digital connectivity for all, a continuing increase in home-working could reinforce existing inequality in the workforce.
• The emphasis on digital engagement in the planning system should not be to the exclusion of other forms of engagement; for example, retaining face to face engagement was seen as important if the planning system is to be accessible to all parts of the community.
• More emphasis should be placed on the potential for improved digital connectivity to benefit all parts of the Scottish economy, including 'traditional' sectors.
• Increased digital connectivity, by enabling more home working, could adversely impact town centre footfall.
• Approaches to avoid or mitigate adverse visual impacts of digital infrastructure should be emphasised alongside proposals to improve digital connectivity.

With respect to funding it was suggested that public and private development will both be key elements in improving Scotland's digital connectivity, and that NPF4 should provide some guidance on how this will be co-ordinated and controlled. An emphasis on the potential contribution that local developers can make to improving Scotland's digital connectivity was proposed.

It was also suggested that improving digital connectivity has been a Scottish Government priority for a number of years, and that more work is needed to increase the rate of change. There was a view that significant investment may be required to achieve the necessary improvement in digital connectivity in more rural parts of Scotland.