Fourth National Planning Framework - position statement: consultation analysis

A Plan for Better, Greener Places

The final key outcome is Better, Greener Places. The Position Statement highlighted intentions to: support development reflecting the character and identity of distinctive places and neighbourhoods, and safeguard and restore natural assets; promote re-use of vacant and derelict land and buildings; ensure the approach to development focuses more on place and includes stronger and updated policies on design and place-making; broaden policies on city and town centres and on the re-use of historic buildings; future-proof natural and historic assets and coasts; enhance policies on vacant and derelict land; and encourage development that helps to repopulate rural areas.

Further detail on the Plan for a Better, Greener Places was provided under eight headings:

1. Focus on place-based outcomes

2. Achieve higher quality design

3. Re-imagine city and town centres

4. Re-use vacant and derelict land and empty buildings

5. Actively promote working and living in rural Scotland and the islands

6. Protect and restore Scotland's natural environment

7. Protect and enhance our historic buildings and places

8. Adapt our coastline to the impacts of climate change

Question 4: Do you agree with our current thinking on planning for better, greener places?

There was broad support for the Plan for Better, Greener Places. However, some respondents cited specific examples of policy or planning decisions they felt were leading to damage to their local environment, running counter to the aspirations set out in NPF4.

Other general points at question 4 included that there should be:

• Less emphasis on development.
• More clarity on what the policy areas described actually mean.
• More emphasis on protecting the environment and on reversing biodiversity loss.
• Reference to renewable energy development and the infrastructure required to tackle climate change.

The scale of the challenge was also highlighted and was suggested to require new thinking – for example in encouraging development in the countryside, looking beyond retail in town centres, and seeing developers and landowners as key agents of positive change for biodiversity.

Focus on place-based outcomes

The Place Principle means that all action and investment should be place-based to secure multiple benefits. Our spatial strategy will focus on the qualities and character of our places. We want to ensure that all parts of Scotland play to their strengths to support our wider objectives of community resilience, inclusive growth and environmental sustainability. Our strategy will support existing successful places and reflect on those that have not served us well, by considering how Scotland's cities, towns, rural areas, coasts and islands work together to form a uniquely rich and diverse country where everyone benefits from our wealth of natural assets. We will also focus on opportunities for regeneration to ensure our most disadvantaged and fragile communities are prioritised for development and investment.

Climate change action needs to work with our places so that we can effectively focus on climate vulnerable communities and tailor action for a just transition that improves our neighbourhoods. We need to build the resilience of our infrastructure and lifeline links through adapting to the challenges around our changing climate, as well as our unique natural, coastal and historic environment assets. Protecting, restoring and enhancing our natural and cultural heritage should form the foundations of a place-based approach to our future development.

Regional spatial strategies are considering ways in which our land and natural assets can form the basis of a green recovery. The two national parks are exploring their contribution to the quality of life of people living across Scotland, and identifying priorities including affordable housing as key to unlocking their potential. Urban futures will also contribute to this. Emerging priorities from the Glasgow conurbation focus on unlocking the potential of land along the Clyde, across local authority boundaries, to attract investment, strengthen communities and improve the quality of our places. Addressing vacant and derelict land is a common theme across the emerging regional spatial strategies.

Around 60 respondents made a comment on the focus on place-based outcomes.

The Place Principle and spatial planning

A number of respondents expressed support for the application of the Place Principle, which was described as a step-change in how planning can look holistically at areas at various spatial scales. In terms of delivering effective placemaking, comments and suggestions included that NPF4 should seek to align spatial planning with assessments of the capacity of places to accommodate new growth and ensure that neighbourhood and place planning are not focussed solely on the provision of new assets which will require funding.

However, it was also suggested that a place-based approach should not become too focused on existing assets as a context. It should also identify truly new outcomes and seek to catalyse long term change that addresses social challenges. Also with reference to spatial planning, it was suggested that NPF4 should make clear that attaining net-zero carbon emissions will require the provision of more large-scale new infrastructure and that landscape change should be anticipated.

It was suggested that the challenge for NPF4 will be how it accounts for the importance of the Place Principle at a national level while allowing for local interpretation and direction to reflect the variability of Scotland's places. In relation to traditionally harder to reach localities, it was reported that the collaborative and participative approach to decisions on services, resources, land and buildings can, and in many cases already is, delivering better outcomes for communities.

Further comments about the potential of placemaking included that:

• Planning authorities are increasingly important contributors to delivering wider policy ambitions around health, wellbeing and sustainable inclusive growth. The focus on place will further enhance this role and will also give them more authority when discussing details (for example around housing numbers and design and connectivity and natural capital) with developers.
• A key role of the Place Principle is around encouraging collaborative working and co-ordinating the activity of different partners.
• It will require a local authority or government masterplan level of implementation. Work on public and utility infrastructure is required at a national level, including to reduce environmental impact and allow for improvement to local biodiversity. An example given was that many domestic and urban areas could have significantly improved air quality if electric and low carbon transport is planned and implemented properly.

However, it was also suggested that:

• Place Principles are only effective if they are embedded and sustainable, representative and resourced.
• Clarity around maintenance responsibilities and certainty of maintenance funding must be embedded. It is counter-productive to provide capital funding to deliver new assets with no clear plan or resources for maintenance. The consequence of not doing so undermines place intentions and the principle intention behind new assets leading them to being perceived as harmful rather than beneficial to quality of place.

With reference to the policy framework to support placemaking, one perspective was that policies should not be overly prescriptive, for example they should recognise that quality, usable open space and play areas could have a much higher value to a community than a larger area of unused, green space. However, an alternative view was that placemaking principles should be made more prescriptive. Green space was again a focus, with the suggestion that any changes to the planning system should ensure access to these spaces is both sufficient and equitable in any new development.

Connections between placemaking and other NPF4 themes

Respondents frequently connected the application of the Place Principle with the delivery of other themes set out within the Position Statement (and covered elsewhere within this analysis), including:

• 20 minute neighbourhoods: The connection between the Place Principle and the 20 minute neighbourhood approach (covered at Question 2) was highlighted. It was suggested that a move to developing proper 20 minute neighbourhoods will need clear and robust changes in NPF4, alongside leadership from the Scottish Government, to influence local strategic plans and local authority decision making.
• Community facilities and infrastructure: Delivering high-quality community facilities in response to a community's needs. The connection was made to LPPs and it was suggested planning must also consider the impact on the infrastructure services of any new development.
• Cultural heritage: Protecting, restoring and enhancing cultural heritage.
• Biodiversity and carbon capture: The interrelationship between climate change, biodiversity, land use and natural capital needs to be recognised.

Alignment with Regional Spatial Strategies

A small number of concerns were raised about NPF4 aligning with RSSs. It was reported that:

• Councils have not consulted stakeholders in preparing the interim RSSs.
• RSSs have gone far beyond their expected remit (addressing cross boundary infrastructure issues) by identifying housing land requirements and even identifying new "Areas of Restraint" where development will be resisted.

It was suggested that if RSSs are to have any influence, they must be prepared in collaboration with the development industry.

Place Standard Tool

While there was some support for embedding of the use of the Place Standard Tool – including as a reflection of the importance of public involvement in a collaborative approach to place-making – a small number of issues were also raised. These included that:

• While tools such as the Place Standard have a role to play in enabling discussions around design, these do not fit every situation. The use of these should continue to be promoted, but not ultimately required.
• The Tool has been developed to be a simple framework that considers physical elements against social aspects; the ambition to transition to better, greener places, especially with regard to delivering a positive effect on biodiversity, peatland protection and woodland creation is not at its heart.
• With reference to public transport, perceptions, opinions, and value judgements about availability, access, quality and reliability often hold sway without balancing evidential input. Action to address this would strengthen the Place Standard tool.

Achieve higher quality design

We will promote the planning and development of healthier, inclusive, sustainable and well-designed places across Scotland. Good quality development will stand the test of time and provide much wider benefits for people's health, wellbeing, the economy and environment. The public realm, including the design, layout and accessibility of our streets and spaces, has an essential role in creating better places. We will build on the six qualities of successful places to maintain a cross-cutting policy on design and place-making. We will ensure that more specific sectoral or place-based policies incorporate design considerations that reflect the diverse needs and aspirations of people.

Many existing plans and strategies reflect the importance of design and place-making including Creating Places and the Place Standard.

Around 20 respondents made a comment about achieving higher quality design. Comments tended to be brief sometimes simply offering support for emphasis and recognition being placed on high quality design.

Other general comments included that improving the quality of design of new development should be a fundamental outcome for the planning process. However, it was also suggested that design should not be seen as 'separate', as it is fundamental to achieving positive outcomes in many other policy areas.

In terms of how NPF4 could further support high quality design, suggestions included that a stronger policy direction on the design of places - and incorporating nature based solutions - should be a priority. A connected point was that (as under the previous theme) embedding the Place Principle throughout NPF4 is welcome but that increased support for planning authorities to resist poorly designed proposals will be important. Further comments and suggestions included that NPF4 could state unequivocally that design will be a material consideration, in line with current SPP.

There was also support for the plan to refresh Designing Streets. In terms of that review/refresh, further comments included that:

• The outcome of any review should create a more succinct and cohesive suite of documents.
• To be truly effective, their overall purpose and status needs to be widely understood as a guide for all concerned. They should not become a 'pick and mix' by which individual parts can be 'cherry-picked' by decision makers and designers.

With reference to new housing development, it was suggested that it is often subject to 'value engineering', meaning that the quality of a scheme given planning permission on paper is not reflected when the project is constructed and sold. To address this problem, it was proposed that housebuilders should be required to place greater emphasis on design quality and experience with green infrastructure when they rank contractors and make procurement decisions. As a condition of planning permission, housebuilders should also be required to identify a single person who is responsible for overseeing the design of a scheme from start to finish and can make sure that the housebuilder's construction partners are aware of their role in delivering design value.

With specific reference to MCAs, there was support for there being a framework which clearly and explicitly covers the role of place in delivering on climate, biodiversity and wellbeing. However, it was also suggested that a clear definition, and clarity in terms of 'ownership' and responsibility for delivery, is required. It was suggested that the approach and process is more important than the status and that, rather than being a tool of restraint, it should be a mechanism used by multiple agencies to deliver development in a co-ordinated manner.

Re-imagine city and town centres

We will look at how our policies can help our city and town centres to respond to current and future challenges so that they can adapt and be vibrant, creative, enterprising and accessible places to live, work and visit.

Scotland's city and town centres were already facing significant challenges prior to the global pandemic. Our living and working patterns in recent months have raised further fundamental questions about their future and wider objectives including climate change and how community empowerment will influence how our town centres will evolve in the future. A new emphasis on localism raises opportunities for town centres that will require a planning policy response, building on our existing approach, to diversify and balance the use of land and buildings, provide services and activities for people of all ages, and stimulate new investment especially in the maintenance and re-use of existing buildings and infrastructure as part of a circular economy.

We will reflect on the Town Centre Action Plan, continue to embed the Town Centre First Principle in decision making and respond to the outcome of the ongoing review of the plan to ensure our policies help to create more vibrant, healthier inclusive and greener town centres. Greater consideration will be given to the provision of more good quality homes in town centres, with access to shops and facilities, which can bring life back into town centres and create good places to live including by making sustainable and efficient use of the existing building stock.

City and town centres have the potential to contribute a great deal to our response to climate change, and to meeting the future needs of our diverse population. By making better and more creative use of our settlement centres, we can significantly reduce the need to travel unsustainably whilst maintaining and enhancing the character and identity of our towns and cities to create vibrant places that meet our future needs. Although the approaches will vary to reflect local circumstances, we will highlight shared opportunities to reinvent town centres and strengthen our networks of settlements.

Around 35 respondents commented on re-imagining city and town centres, with some noting their support for a new approach to town and city centres, recognising the need for these places to be revitalised to create attractive and vibrant places, and the contribution that they can make to wider climate change and economic objectives. It was suggested that the COVID-19 pandemic has accelerated the need for new models for town and city centres.

Respondents expressed specific support for the "town centre first" policy, the integration of the Place Principle and Place Standard Tool in the planning system, repurposing available infrastructure and vacant buildings (including historic buildings), and an integrated approach to development to minimise the need for travel. Links were made to the concept of 20 minute neighbourhoods (as already covered at Question 2). Respondents cited examples of town centre masterplans and other policies seeking to reimagine the character and operation of towns across Scotland.

A need for greater transparency around the research and evidence base that informs the NPF4 policy framework in relation to town centres was also suggested. This was seen as crucial in the context of the impact of the COVID-19 pandemic in accelerating changes to town centre use, and in providing evidence to inform understanding of how town centre sectors might evolve, and the role of sustainable transport options. Some respondents reflected on the degree of change required of town and city centres, including reference to changing shopping habits and the growth in home working. A need for funding and investment to achieve the required change was suggested, as was a focus on stabilising the decline of town centres before looking at significant changes in character or use.

Respondents also cited the Town Centre Action Plan Review Group report "A New Future for Scotland's Town Centres" ^[11] as being relevant to the reimagining of city and town centres and wished to see relevant recommendations reflected in NPF4.

Local approaches

Respondents argued that NPF4 should emphasise the need for a localised approach which takes account of the specific character of each town and city centre and which is integrated with a wider regional spatial strategy (for example reflecting the changing role of out-of-town developments and similar developments). This included for rural and island communities where it was suggested that the locational requirements of rural and remote communities should be considered. However, some also saw a need for a national review of town centres and relevant sectors to inform local approaches. This included for example guidance on which existing uses should be safeguarded, and how to integrate these with new uses.

The role of communities in shaping the approach to their town centres was highlighted, including a role working with planning authorities and developers to revitalise town and city centres. The need to provide communities with training on the planning system to support growth in community input and ownership in town centres was suggested.

Promoting active travel

There was a perceived need for a shift towards town and city centres being planned for people rather than cars, making them attractive places for people to live and work. This included calls for NPF4 to ensure access to high-quality green spaces in town centres, with respondents highlighting potential health and wellbeing benefits.

Transport was highlighted as a key factor in making town and city centres more attractive places for people. This included particular support for reducing the volume of car traffic and promoting active travel and public transport. Some respondents highlighted a need to improve infrastructure to support walking and cycling, including reference to evidence of the prevalence of barriers to walking or cycling. Support for town centres being better designed for cycling in particular included reference to benefits to retail activity, house prices, reduced health care costs and improved productivity.

Greener city and town centres

Respondents wished to see environmental improvements and consideration of wider climate change targets integrated as part of the approach to revitalising town and city centres. This included suggestions that 'Green Plans' should be drawn up for major towns and cities, setting out specific actions that will be taken to reduce emissions and contribute to net-zero targets. Some also wished to see further detail on how the approach to delivering vibrant and accessible town centres will protect and restore biodiversity.

There was also a suggestion that development on some lower quality green spaces may be beneficial, for example if these developments are better located and are linked to the creation of new green spaces within town centres.

Barriers to regeneration

Concerns were raised around the support for reuse of existing buildings, and potential for this to have unexpected adverse impacts on the diversity of town centres. Higher costs of retrofitting energy efficient technologies to older buildings were suggested to have the potential to affect the viability of projects, and to reduce scope to alleviate fuel poverty and deliver fully accessible homes. However, others suggested that policies around building standards and energy assessments could be shaped to support re-use of historic and other existing buildings.

Respondents also cited other potential barriers to achieving town centre regeneration objectives and wished to see these addressed by NPF4. Specific issues raised included: business rates; a need for use class reform; complex land ownership; surface water drainage capacity (in relation to residential development); and the financial viability of more sustainable development.

Re-use vacant and derelict land and empty buildings

There is a clear case for acting now to prioritise the use of vacant and derelict land and properties. This has the potential to deliver significant benefits including sustainable, inclusive growth and reduced emissions as an integral part of our future sustainable and circular economy.

Scotland has too much vacant and derelict land – this is rightly regarded as unacceptable and an issue of national concern that needs to be urgently addressed. The consequences come at too high a price, directly impacting on health and blighting economic, social and environmental recovery. Vacant and derelict land introduces a level of redundancy that our society can ill afford. Whether it is large scale long-term dereliction, or small scale short-term vacancy, we need to set out a stronger policy framework that will give confidence to communities and public and private sectors that vacant and derelict land represents an opportunity to stimulate a positive future whilst building on the legacy of the past.

Our national planning policies can complement wider work on vacant and derelict land. The Vacant and Derelict Land Taskforce has identified longstanding vacant and derelict sites which the planning system could play a role in bringing back into use and this is a key priority highlighted by the Scottish Land Commission which proposes this as a national priority for NPF to address, and the Vacant and Derelict Land Fund seeks to provide funding solutions to the issues.

We must change the perception of vacant and derelict land from being a liability to becoming an asset. We could do much to inspire innovation and imagination in considering how we can achieve this. The strategy can set out spatial priorities and opportunities that help to guide future investment.

The relationship between town centres and suburbs and the role of the green belt will also benefit from a long term spatial perspective that reflects our net-zero and environmental ambitions. We will develop a vision for the future use of vacant and derelict land so that regional strategies and local development plans can work collectively to unlock the potential of land within our existing settlements to provide multiple benefits. Supporting this, stronger policies to limit greenfield development and recognise the potential for green belts to form a part of multifunctional green networks could help to achieve positive effects for biodiversity whilst also helping to realise the health and climate benefits of growth within existing urban areas.

Around 85 respondents commented on re-using vacant and derelict land and empty buildings. A number of respondents offered their support for NPF4 having a focus on reuse, including recognising the opportunities for re-development. This included specific support for a 'brownfield first' approach prioritising re-use of brownfield sites over greenfield development, for the review of green belt policy and for potential expansion of land assembly and compulsory purchase.

Respondents also noted the importance of these proposals in terms of reducing development pressure on valuable green spaces, supporting delivery of climate change and other environmental objectives and revitalising town and city centres. It was suggested that the COVID-19 pandemic has further increased the value placed on local access to green spaces, parks and amenities. A number of local examples of policy and projects supporting re-use of vacant and derelict land and buildings were cited.

Respondents also raised a range of concerns or issues for the approach taken by NPF4 in relation to vacant and derelict land and buildings. These are summarised below.

Limiting greenfield development

Reflecting support for prioritising development of brownfield sites, some wished to see NPF4 set out stronger measures to limit greenfield development. This included a suggestion for a presumption against greenfield development unless specific criteria are met, stronger enforcement of conditions on planning permission, or a requirement for all available brownfield sites to have been fully considered before greenfield development is permitted. It was also suggested that a 'regional registers' of available brownfield sites could enable developers to consider these opportunities at the outset.

Reviewing greenbelt policy

In relation to the proposed review of green belt policy, and wider policies to limit greenfield development, some respondents suggested that NPF4 should set out how the planning system will balance delivery of climate change and other environmental objectives with the protection of green belt and other designated areas. This included suggestions that national developments and other sustainable development on green belt should be permitted where they are required to meet climate change objectives or form part of work to improve the overall biodiversity of specific green belt land. Some respondents specifically referred to the potential need for renewable energy development on some greenfield sites and wished to see this acknowledged by NPF4.

It was also suggested to be "extremely disheartening" that NPF4 addresses green belt policy so briefly, particularly since the threat of loss of greenbelt is a contentious issue for many communities. It was argued that action should be taken to prevent multiple speculative planning applications for development on green belt land.

Recognising assets on brownfield sites

Some respondents suggested that the planning system must recognise the potential for brownfield sites to contain important natural or heritage assets. It was argued that proper environmental assessment should be undertaken on a site-by-site basis before re-development, and that relevant data on biodiversity across brownfield sites should be made available to planning authorities. This included specific reference to ecological, biodiversity and archaeological assessment. It was also suggested that this assessment could identify opportunities for brownfield sites to be re-purposed as part of blue and green infrastructure.

There was also a suggestion that NPF4 should support additional measures for buildings at risk including, for example, Compulsory Sale Orders. Comments reflected a view that NPF4 will need to provide clear policy guidance for planning authorities implementing the 'brownfield first' approach to deliver sustainable outcomes, including a recommendation for stronger policy on site requirements including co-produced design briefs.

Empty buildings

Concerns were raised regarding potential for a focus on re-using empty buildings to have unintended negative impacts on the diversity of town centres, and the re-use of historic and listed buildings. Specific reference was made to the cost of conversion and retrofitting of technologies required to achieve low carbon objectives and it was suggested that some relaxation of regulations around the use and adaptation of heritage buildings may be required to support re-use of vacant buildings.

Concerns were also raised regarding the extent to which it is always preferable to re-use industrial units, and the cost associated with developers making the case for demolition and rebuild (and the capacity for planning authorities to assess these cases).

Balancing demand for development on greenfield and brownfield sites

Although supported by many, some respondents argued against prioritisation of brownfield over greenfield development, suggesting that releasing greenfield land for development as part of a planned national strategy could help to contribute to economic and environmental targets. This included reference to limited opportunities for the 'greening' and creation of open space through development of urban brownfield sites. One perspective was that greenfield development will be necessary to meet Scottish Government strategic objectives.

There was also concern that a focus on brownfield sites will be insufficient to meet housing supply targets, and could be at the expense of other beneficial uses such as employment, recreation or green infrastructure. Some respondents suggested that development of green infrastructure may be the preferred option where derelict land is not ideally placed for housing or other development, noting the potential benefits to local communities in terms of providing green space (including for example for food production) and supporting communities to contribute to emissions reduction in their area.

It was also suggested that support for brownfield development has been a development plan priority for some time, but that policy support alone may not be enough to make development of brownfield sites viable. Reference was made to a range of factors that have limited re-development of brownfield sites to date, primarily relating to the costs of making land viable for development. These included reference to: site ownership; demolition costs; conversion costs; assessment and remediation of contaminated land, including for sites previously used for or adjacent to storage of hazardous substances; drainage and flood risk; constraints on land-use due to development plan zoning; and restrictions on 'meanwhile' uses of vacant land or buildings.

It was suggested that significant public intervention and funding will be required to facilitate the development of many brownfield sites, particularly in rural areas where, it was suggested, the viability of sites can be more significantly impacted by the factors noted above.

The need for a wider review of planning, roads and building standards regulations as part of a holistic approach to re-use of vacant and derelict spaces was suggested and it was recommended that the Scottish Government considers exemplar cities which have successfully brought derelict or vacant land back into use, to identify which regulatory interventions have been required.

Some respondents felt that NPF4 should acknowledge that vacant and derelict land is also an issue for many rural areas. It was suggested that some local plans currently oppose redevelopment of rural brownfield sites, and clarity on whether NPF4 support for brownfield development would include rural locations was requested.

Community involvement in decision making

The importance of communities being able to contribute to the approach to re-use of specific derelict or vacant land and buildings was highlighted, including through contribution to LPPs. However, there was also a view that there have been inequalities in the opportunity and capacity for communities to inform this process. For example, it was suggested that some communities have been left out of opportunities to re-use derelict and vacant land and buildings due to both lack of resourcing, and a failure to connect with local communities. It was suggested that the approach to re-use of these sites and buildings must be embedded within local communities, and properly resourced. There was also a suggestion that NPF4 should ensure that prioritising of brownfield sites for development takes account of inequalities, for example by prioritising vacant and derelict land in areas of deprivation.

Actively promote working and living in rural Scotland and the islands

The issues arising from COVID-19 and future impacts of Brexit mean that the time is right for a fundamental rethink on how we can support a positive future for rural Scotland. Development planning in Scotland is now required by the Planning (Scotland) Act 2019 to contribute to increasing the population of rural Scotland, particularly in depopulated areas. Last year we commissioned research to explore how future planning policy can support strong and vibrant rural communities and economies in the coming years, and identified scope for significant policy changes in NPF4. Our National Islands Plan identifies how we can improve outcomes for our island communities and our approach will be informed by an island communities impact assessment.

We are currently exploring significant changes to our policies on rural and island development, to support prosperous and sustainable communities and businesses whilst protecting our unique natural assets. Our rural areas and islands are one of our greatest assets and our strategy will reflect our ambition to build low carbon rural communities where the quality of life is exceptional. We will identify opportunities to build the long term sustainability of our more fragile areas by highlighting infrastructure requirements and facilitating development that strengthens their future. While it is right that rural and island areas are developed in a different way to our urban centres, people still need to be able to access goods, services, healthcare, education, work and recreation in a fair, affordable and low carbon way for health and wellbeing. Access to low carbon heat options and water supplies are of critical importance for households that are not connected to wider networks. Local authorities have been working together to explore what low carbon rural living will look like in the future and this will inform a new national spatial strategy with supporting policies.

NPF4 will need to align with a wide range of policies relating to rural development including our National Islands Plan, Forestry Strategy, the Rural Economy Action Plan and the Land Rights and Responsibilities Statement. There are particular opportunities to link planning more closely to the Land Use Strategy and Regional Land Use Partnerships, to achieve an approach to future development at national, regional and local scales, that more fully supports, and is supported by, wider land use management.

Rural repopulation is a key theme for emerging regional spatial strategies including for the South of Scotland, Argyll and Bute, Western Isles, Orkney and Highland, where authorities are exploring how the areas' high quality of life and environment, growth of local economic development together with a growth in remote working can unlock new futures for rural communities and businesses. Emerging strategies are also exploring how the challenge of an ageing population can be addressed through long term planning.

Around 45 respondents commented on working and living in rural Scotland. There was support for a change of policy approach to actively promote working and living in rural and island areas. There was particular support for the focus on rural repopulation and for links to land use and other policies and strategies including the National Islands Plan, the Land Use Strategy and Rural Planning to 2050. Local policies and developments seen as having a contribution to make to the desired policy outcomes for rural Scotland were also referenced.

Some respondents wished to see NPF4 set out more detail on policies for rural development. This included suggestions that rural and island communities differ greatly in terms of the scale and type of development that may be sustainable, and a wish to see a tailored approach developed with planning authorities. The need to ensure that development is supported by sustainable infrastructure, including transport and digital connectivity was also highlighted. It was suggested that LDPs are the most appropriate place to specify how rural development is to be supported, given the variation in rural areas across Scotland.

There were specific concerns that the focus on rural repopulation should not risk the quality of countryside environment by permitting unsustainable development in rural areas, and a view that NPF4 must be clear on how planning authorities can strike this balance. This concern was also expressed in relation to countryside around populated areas; some respondents wished to see NPF4 include policies specific to these areas and recognise that they can come under significant pressure from developers.

A number of respondents suggested that, while NPF4 policy support for sustainable development in rural areas is welcomed, the Scottish Government should recognise potential for barriers to limit sustainable development. This included reference to what were seen as excessive regulatory requirements for some rural development, where it was felt that regulations have not been adapted to the specific characteristics of rural areas.

Reviewing policy on wild land

Some respondents objected to the proposal to consider whether wild land policy needs to change to support repopulation of rural Scotland, expressing concern that permitting more development in wild land areas risked degrading the quality of these areas for the benefit of what was expected to be a small number of housing units. These respondents wished to see policy support for rural repopulation focused round established settlements and infrastructure.

However, others argued that current wild land policies are overly restrictive and curtail sustainable development such as renewable energy projects. These projects were seen as offering key opportunities to stimulate rural economies and support repopulation.

Sustainable development

Reference was made to a range of specific economic sectors and land uses which were seen as having potential to contribute to sustainable economic growth, to develop sustainable communities and support rural repopulation. This included: renewable energy development; aquaculture; education; tourism and holiday accommodation; and creative industries.

Some respondents wished to see a greater focus on ensuring rural communities can offer opportunities for young people, noting that this was identified as a key priority by the Land Use Strategy.

In relation to a proposed national spatial strategy to support low carbon rural living, it was suggested that this should take account of the potential role of local energy systems, particularly in off-grid locations.

However, it was also suggested that the focus on promoting working and living in rural Scotland may conflict with net-zero targets.

Protect and restore Scotland's natural environment

Our spatial strategy will strengthen our approach to protecting and restoring the health and quality of Scotland's natural environment. We will ensure that our approach to planning supports Scotland's role in responding to the twin global crises of biodiversity loss and climate change, including by strengthening policies designed to protect and restore Scotland's biodiversity and natural assets and to improve their long term resilience to the impacts of our changing climate.

Our national planning policies include measures to protect Scotland's unique natural environment, reflecting the hierarchy of natural heritage designations, from international networks to locally important landscapes and nature conservation sites. Building on this, we will strengthen policies to protect and restore biodiversity and natural assets. For example, the Planning (Scotland) Act 2019 requires NPF4 to set out how development will contribute to securing positive effects for biodiversity and we are keen to build on existing good practice in Scotland and elsewhere. It also requires planning authorities to prepare Forestry and Woodland Strategies for their areas as a way of guiding future woodland creation and supporting the sustainable management of existing woodlands to increase the social, environmental and economic benefits they can deliver. We will look to align NPF4 with the vision and outcomes of Scotland's new Environment Strategy and the principles set out in the Land Use Strategy as well as considering the issues for the natural environment arising from the Climate Change Plan and Adaptation Strategy.

Our approach will recognise the fundamental role that a healthy and resilient natural environment plays in supporting Scotland's economy and the health and wellbeing of our communities. It will help to ensure that our natural assets are managed in a sustainable, regenerative way so they can continue to provide the benefits Scotland's people and businesses rely on.

Around 70 respondents made a comment about protecting and restoring Scotland's natural environment.

There was support for strengthening the approach to protecting and restoring the natural environment and for the focus on biodiversity which, it was argued, should be central to decision making throughout the planning process. In addition to protecting existing habitats, it was suggested NPF4 should incorporate policies that make nature recovery a consideration in every planning decision. It was also argued that SPP should support the new Scottish Biodiversity Strategy.

The need for SPP to include stronger policies to secure positive effects for biodiversity was also suggested and, specifically, that it should enshrine the UN Sustainable Development Goal target of integrating "ecosystem and biodiversity values into national and local planning, development processes, poverty reduction strategies and accounts".

There was disappointment that proposals for a National Nature Network are not taken forward in the Position Statement.

Positive effects for biodiversity from new developments

Securing positive effects for biodiversity from new developments was welcomed, with an observation that partnership working between developers, local authorities and key stakeholders should be promoted to ensure co-ordinated action. It was suggested the policy should also include the marine environment where the aquaculture industry can contribute to biodiversity enhancement. The importance of local authorities having access to all available biological data was also highlighted since it was argued some brownfield sites have "rewilded" and may themselves be havens for biodiversity. It was argued that NPF4 must emphasise application of the mitigation hierarchy^[12] to ensure any biodiversity gain is additional to the mitigation required to prevent environment damage.

Absence of any reference to biodiversity net gain (BNG) in the Position Statement was noted, and it was suggested this a widely accepted term, the absence of which may be confusing for developers. The comprehensive guidelines and well-established case studies relating to BNG were also noted and it was suggested that, at present, NPF4 lacks information on mechanisms for achieving positive effects or on how they will be measured. A requirement to explain the terms 'positive effects' and 'positive outcomes' was also suggested.

There were contrasting views on the intention to deliver "positive outcomes for biodiversity from development without the need for overly complex metrics." One perspective was that this is the correct approach, with a suggestion that the BNG metric approach in England has the potential to significantly hinder the growth of low carbon energy, for negligible environmental benefit. An alternative view was that the DEFRA metric is straightforward and established, and that many industries, have already adopted the BNG approach and metrics successfully in Scotland.

A standardised methodology, metrics, and focus on a Scotland-wide approach was argued to be essential to avoid delays and complexity and it was suggested updated UN biodiversity frameworks should be taken into consideration when formulating the metrics to be applied. It was also suggested that, to ensure a proportionate approach, smaller scale developments and certain types of development could be kept below the threshold at which the metric approach would apply. Whatever the approach, it was argued that NPF4 must ensure policies to secure positive effects for biodiversity are accompanied by robust means of enforcement.

Other points with respect to biodiversity gains from new development included a suggestion for emphasis on integrating species habitation structures, such as nest boxes into new builds.

Safeguarding and promotion of forestry, environmentally significant locations and green or blue corridors

The safeguarding and promotion of forestry, environmentally significant locations and green or blue corridors was welcomed, although it was also suggested consideration should be given to incorporating the concept of 'natural capital', including as a funding tool and economic lever to meet objectives of nature conservation and growth. However, concern was expressed that any application of natural capital approaches must make clear what is expected of everyone involved in the development process.

Woodland

As already noted at Question 1 in terms of nature-based solutions, there was broad support for creation and protection of woodlands and, specifically, for protection of ancient woodlands.

Specific suggestions included both that woodland creation should take priority over other habitats and that it will be important to ensure policies support planting in locations which will not have negative impacts on other important habitats. Other suggested requirements included that:

• Species selection should be site-specific, with a focus on native species.
• There should be a mix of commercial species and broad-leaved trees.
• Tree planting should include urban environments.

Clarity was also suggested to be necessary to understand when woodland removal requires compensatory planting, to ensure this is not requested in inappropriate situations.

Peatland

Issues relating to peatland are also covered at Questions 1 and 3, but in the context of protecting and restoring the natural environment, several Energy Suppliers noted their own record or that of the onshore wind industry in general to peatland restoration work and other environmental improvements. Concern was expressed that reference to "restricting…development on peatland" could be interpreted as a blanket ban on any development, without recognising the opportunity for the net benefits of wind farms. It was suggested that NPF4 should acknowledge it is not always possible for developments to avoid all peatland resources.

Other comments in relation to protecting soils included that NPF4 and the Land Use Strategy should address the problem of unsustainable soil erosion on agricultural land.

Wild land

The Position Statement notes that there will be consideration of whether policies on wild land need to change in the context of requirements in the Planning (Scotland) Act 2019 to support the repopulation of rural Scotland. There was support for this approach, particularly amongst Energy Supplier respondents, who reported the barrier that wild land areas can present for wind energy development and that, as a consequence, new proposals are coming forward that are closer to houses and settlements or in landscapes less well suited to commercial scale developments.

Also suggested were:

• Clarification that any changes in the spatial framework should unlock land for renewable energy, and are not just seen in the context of repopulating rural areas.
• An EIA-led approach for renewable developments.
• Redrawing wild land areas to take account of local knowledge or the needs of local communities.

However, other respondents made the case for retaining or strengthening protection for wild land areas with arguments that wild land is an important national asset that should be managed sensitively. Retaining the framework on appropriate locations for onshore wind farms set out in SPP Table 1^[13] was proposed as the backbone to a spatial strategy that strengthens the approach to protecting and restoring the natural environment. Recognition of wild land areas as part of a National Nature Network was also suggested.

Reservations were also expressed with respect to a review in the context of repopulating rural areas, with suggestions that there should be no conflict in this respect given the extent of wild land areas and the likely sites for expanding rural populations. It was argued both that, as the number of people who would want to live in designated wild land areas would be extremely small, the benefit to re-populating rural areas would be insignificant, and also that one of the ways to combat depopulation is to maintain these rural areas as an attractive place to live.

Other points on wild land included that there should be:

• Recognition that many of its qualities now considered to be 'natural' are in fact a product of the intervention of people, over time.
• An update of wild land mapping to understand how quickly wilderness qualities are compromised.
• A more positive policy narrative on the value of wild land, drawing out broader benefits in addressing the climate and biodiversity emergencies, as well as recognition as an important landscape, recreation and tourism asset.
• A new approach to wild land areas to make consultation with local communities on planning proposals mandatory. Such consultation would ask local people where they think any new development should go, and would cover LDPs and alternative siting and design options.

Green and blue corridors

In terms of green and blue corridors, there was support for both a National Nature Network and the Central Scotland Green Network. The value of connecting habitat was highlighted, with a suggestion that climate change will make this increasingly important to minimise the effects of shifts in species ranges. The role of greenbelt, both in its own right and as part of a green network was noted, as was commitment to resource Forestry and Land Scotland towards acquisition and remediation activities that will assist in the creation of green corridors.

Landscapes

It was suggested NPF4 gives only limited recognition to the importance of landscape, that national and local landscape designations should be safeguarded or that relevant wording from NPF3^[14] should be retained. Other suggestions included that NPF4 should reframe landscape as an asset rather than a constraint in transition to net-zero and should better engage in meaningful discussion with communities and stakeholders.

It was also argued that NPF4 should be clear that:

• Certain parts of the country are suitable for renewable generation technologies and others are not.
• Attaining net zero will require the provision of more large-scale new infrastructure and that landscape change should be anticipated.

A need for NPF4 to take a proactive role in facilitating acceptance of renewable energy schemes in landscapes was suggested. It was also argued that solar technologies can occupy green spaces without undermining local aesthetics or amenities.

Locally important assets

It was reported that SPP currently provides adequate policy for the designation of local landscape and nature conservation sites, although that clarity could be improved and that a nationally consistent level of protection (or minimum protection) for local sites could be set out.

However, it was also suggested that non-statutory designations such as Local Wildlife Sites appear to have little impact on development applications, and it was proposed a new designation of a "Site of Special Community Interest" could provide greater protection.

Other points on locally important places included that:

• All natural assets should be assessed for the level of protection needed, and that this process should involve community knowledge.
• There should be clear criteria regarding use of EIAs which, it was reported, may currently be discouraged as being too onerous.

Protect and enhance our historic buildings and places

'Our Place in Time – the Historic Environment Strategy for Scotland' sets out a vision for how we will care for, understand and promote access to our historic environment. It recognises the important contribution that historic sites and buildings make to communities across Scotland; promoting a sense of belonging and identity, encouraging civic participation and supporting local economies. Our policies for the historic environment will aim to respond to the outcomes and objectives of the Strategy.

Like our natural environment, our historic buildings and townscapes are key assets that contribute to our sense of belonging, economy and quality of life. Planning should provide the framework in which change in the historic environment can be managed sensitively to preserve the special characteristics of our buildings and places, while also ensuring that we capitalise on the opportunities they offer. In doing so, we will acknowledge that the historic environment is itself an asset that can help us to deliver our wider policy ambitions for example, for mitigating climate change, improving health and providing housing.

Since NPF3 was adopted, Historic Environment Scotland (HES) has been established as our lead public body for the historic environment. In 2019, HES published Historic Environment Policy for Scotland (HEPS). We will consider our policies for the historic environment in relation to HEPS to ensure a consistent framework for decision making.

Around 25 respondents made a comment about protecting and enhancing historic buildings and places. There was support for the intention to protect and enhance historic buildings and places, although also an observation that the historic environment is not just buildings and places as Scotland's landscapes – including wild land areas - are largely a product of human activity over time. In this context it was suggested that "protect and enhance our historic buildings and places" might be revised to "protect and enhance our historic environment".

It was also suggested that the Position Statement should acknowledge that the historic environment is a finite resource which cannot be replaced, and should place increased emphasis on facilitating the acquisition and re-use of neglected historic buildings to secure their long-term future - a strategy to enhance and conserve the historic environment through rejuvenation for the benefit of wider society, the local economy and future sustainability targets.

Other suggestions were:

• A specific reference to archaeological remains.
• A definition of 'historic assets' to differentiate them from 'brownfield sites', as it was reported that nationally important monuments have been described as brownfield sites.
• A more holistic approach to the management of designated historic battlefields, and gardens and designed landscapes.

Respondents also welcomed recognition of the importance of the historic environment as an integral part of Scotland's sense of place, and of historic buildings and places as key community and economic assets with potential to contribute to delivery of wider policy ambitions including in relation to climate change. The role cultural heritage can play in supporting town centres was also noted. It was reported that forthcoming Historic Environment Scotland (HES) guidance "Talking about Heritage" will help communities to identify the land and buildings that are important to them as part of the LPP process.

While 're-use where appropriate of historic buildings…' was supported, it was also suggested that:

• Locally important, non-designated assets currently lack sufficient protection in LDPs, and valuable interiors are being lost as a result.
• Protection should include the broader context of the building or place not just the immediate vicinity.
• "Appropriate" needs to be defined as this could be problematic from the perspective of a future user and/or one wishing to maintain the status quo.
• Cost implications for conversion and retro-fitting might have an adverse impact on diversifying town centres, and the policy could have an unintended adverse impact on the re-use of historic and listed buildings.
• Refurbishing Victorian building stock will require flexibility on heritage restrictions and policy recognition that loss of some heritage assets may be acceptable in order to deliver wider economic and community benefits. This view was suggested to be in line with Historic Environment Policy for Scotland (HEPS) and HES guidance on Managing Change in the Historic Environment.

Alignment

The intention that NPF4 will maintain, strengthen and clarify existing historic environment policies, and align them with both Our Place in Time and HEPS was welcomed. Good management of the historic environment - including both designated and undesignated heritage assets – was suggested to be central to the delivery of other outcomes, especially in relation to place. The importance of policies that reflect the value of heritage in its own right, as well as recognising that it is an enabler across principal policy areas was highlighted.

Heritage Impact Assessments

There was support for making Heritage Impact Assessments mandatory for all listed building and conservation area applications, including to offer another tool to consider the potential impacts of development.

However, it was also suggested that:

• It is unclear what benefit this policy change will achieve that is not delivered by existing mechanisms.
• There are concerns with respect to how the expertise and neutrality of assessments can be assured, and that model baseline approaches might need to be developed.
• Such assessments may serve little practical purpose and may become a barrier to the maintenance and reuse of historic buildings.
• Formal assessment should only be required where appropriate, rather than as a blanket requirement.

Other issues raised:

With respect to the intention to "future-proof our natural and historic assets and coasts…" the need to protect historical assets from flood risk was suggested, but also that, in some situations, this may prove unrealistic without significant sea-defences that themselves damage the landscape.

Finally, it was reported there are concerns across the sector as to where planners and others within local authority teams dealing with heritage will point decision makers. Inclusion of detail in documents such as PAN 2/2011 'Planning and Archaeology' in the new NPF4 as a form of supplementary planning guidance was requested.

Adapt our coastline to the impacts of climate change

We will consider how the future development of our coastal areas and communities can be achieved in a way that helps them adapt to long term challenges. Terrestrial and marine planning come together in our coastal areas, and NPF4 will align with Scotland's National Marine Plan as well as sectoral plans for offshore wind and aquaculture, emerging regional marine plans, plans for our ports and harbours and the Blue Economy Action Plan. The Scottish Crown Estate Act 2019 will also provide opportunities for coastal communities to benefit from their own assets, opening up new opportunities for strengthening their future.

We will consider whether proposed national developments can help us to deliver on this vision. The full list of proposals we have received is available to view at www.transformingplanning. scot and includes, for example: area-based environmental transformation projects; green and nature networks; town centres; regeneration projects; rural developments; and redevelopment of vacant and derelict land.

Around 20 respondents commented on adapting our coastline to the impacts of climate change.

The potential impact of coastal erosion was highlighted, and it was reported that the Dynamic Coast project^[15] is providing case studies that include developing adaptation plans for vulnerable stretches of coast. It was also suggested there could be an opportunity for NPF4 to embed marine and coastal planning in the planning system more strongly and to articulate how and where nature-based solutions could apply, in light of funding for flood risk management and coastal change adaptation announced in the Programme for Government of September 2020. Adapting communities to flood risk and coastal change was noted to have significant resource implications.

Recognition of the need to align terrestrial and marine planning was supported, with a view that it is essential that conservation action in the marine environment includes land management and terrestrial activity. It was suggested to be essential that NPF4 recognises the role Scotland's marine environment can play in tackling both the climate and nature crises and that Scotland's network of Marine Protected Areas is completed. There were also calls for the development and adoption of RMPs to address specific regional pressures and to integrate with other management plans, such LDPs.

Alignment of marine and terrestrial planning was also identified as of central importance in relation to offshore wind energy, to ensure offshore development is provided with the necessary onshore infrastructure including grid connections, substations, and improvements to ports and harbours. It was suggested that the commitment to revisit the interface between terrestrial and marine planning should be considered alongside wider UK and Scottish Government offshore wind policy streams focused on reducing current barriers and delays to offshore wind delivery.

The proposed support for the development and infrastructure needed to realise the potential of the blue economy and coastal communities was also welcomed, in relation to the contributions that could be made by:

• Development and implementation of Nature Networks.
• Ports and EcoPorts.
• The aquaculture industry.

Several specific policies were proposed with respect to aquaculture development, including incentivising development in rural communities that would benefit from regeneration and redevelopment of the waterfront, and identification of dedicated areas which would allow the aquaculture sector to trial innovative technologies and bring investment to local communities.

Other potential opportunities highlighted for coastal communities included:

• Development in relation to cruise ships and pleasure boats.
• Circular economy opportunities for example arising from the waste from seafood processing.
• Potential for agroecology.