Transform Scotland’s Policy Advisor, Tom Flanagan, reflects on the NPF4 Ministerial Statement.
In his address to the Scottish Parliament, the Minister noted that the revised draft of the NPF4 Planning Framework was being published on ‘World Town Planning Day’ which could either be considered as serendipitous or unfortunate, depending on your point of view.
Given the changes that have been made since the draft NPF4 and the obvious cognisance that the Scottish Government has taken to respond to the concerns and criticisms of stakeholders, Transform Scotland believes it is more the former than the latter.
Transform Scotland welcomes the reference that the Minister made to the good work undertaken at COP26 and the challenges that still need to be addressed post-COP27. This highlights the global context and the scale of the challenge for Scotland that NPF4, along with the Climate Change Update Plan and other recent policy initiatives, will help to address.
We particularly welcome the clarity around the policy imperative of the climate and nature emergency that was rather obscure and ambiguous in the draft document. This will help planners with the hierarchy of importance when it comes to applying the various policy drivers to planning decisions, that addressing the climate and nature crises is paramount.
It was also gratifying to hear that the implementation of NPF4 would be a collaborative and cross-cutting Scottish Government endeavour as the planning framework will underpin vital interventions across departments, such as transport decarbonisation.
In that context, we welcome the declaration that NPF4 is designed to support the delivery of renewable energy. However, we are concerned that there remain arbitrary limits on the delivery of renewable energy. For example, permitted development rights for solar are limited to 50kW, while in England the limit is 20 times higher, at 1MW. For transport decarbonisation to be successful there needs to be more flexibility to the delivery of renewable energy that can be directly applied to supporting low emission travel. We would urge the Scottish Government to address this anomaly as it reviews the criteria for permitted development rights.
Transform Scotland commends NPF4 as it puts climate change at the front and centre of the planning system while tackling long-standing challenges and inequalities. We also support the six core spatial principles that include local living, which is about improving our places to support health and wellbeing through ensuring easy access to services, green space, learning, work and recreation. The 20-minute neighbourhood concept, which is at the core of that, facilitates delivery of the place principle while providing compact growth, promoting town centres, encouraging the reuse of assets and reducing the need to travel unsustainably.
We welcome the approach that local living and 20-minute neighbourhoods is not designed as a template, but it is expected to be applied according to the circumstances of each plan area, including in rural areas and islands.
The place-based investment programme, NPF4, local development plans and local place plans will support and enable communities as they tackle local challenges while becoming better connected and greener. This approach aligns well with the newly stated priorities of Transform Scotland and we would offer to work with the Scottish Government and its agencies to ensure that low carbon living and sustainable travel becomes the norm.
As the Minister rightly stated, people want liveable places with local services and thriving town centres and we welcome the reiteration that the Scottish Government wants to cut car kilometres travelled by 20 per cent by 2030 to help cut transport emissions. However, many developments, including in the retail, health education and business sectors are often still planned and constructed out-of-town. We would urge the Scottish Government, in its advice to local authorities on their Local Development Plans, to resist any further out-of-town development and instead look to the sustainable revitalisation of our town and city centres.
Similarly, with housing developments, while we recognise the need for more affordable housing we need to move away from car-dependent and car-dominant neighbourhoods and ensure that sustainable travel options are built-in from the outset and not left for transport planners to try to retrofit solutions into environments that are hostile to active and sustainable travel.
Along with many other stakeholders, we would concur with the view that the planning system and service is under-resourced and while we acknowledge the financial efforts to support planning departments, such as the increase in planning fees, there needs to be a much broader programme of investment in skills, technology and engagement so that there are no ‘Cinderella’ services in what was described as a cross-cutting and collaborative endeavour.
The Minister stated that the publication of the revised draft NPF4 was the end of the beginning of the process and we must ensure that, moving forward, monitoring and evaluation of the delivery programme will be essential to maintaining momentum. In that regard, the alignment of specific policies with the identified Sustainable Development Goals (SDGs) is a welcome initiative which we hope will now be applied consistently across all policy areas.
It has been a rather long road, or perhaps cycle track, to get to this point and it has taken some considerable time. We now need to urgently pick up the pace and move to implementation and delivery. Transform Scotland, along with fellow NGO’s and Government agencies, stands ready to play its part and contribute to the sustainable future that NPF4 endeavours to deliver.