Letter from the Convener to the Convener of the Local Government, Housing and Planning Committee, Ariane Burgess, 23 February 2022
Dear Convener,
The Rural Affairs, Islands and Natural Environment Committee has been conducting scrutiny into the draft Fourth National Planning Framework (NPF4). The Committee has considered the written evidence within its remit received in the call for views and held an evidence session with the Cabinet Secretary for Rural Affairs and Islands and the Minister for Public Finance, Planning and Community Wealth on 9 February 2022. Two Committee members also attended the stakeholder engagement event on 7 February 2022 organised by your Committee and the Parliament’s Participation and Communities Team to hear evidence from hard-to-reach stakeholders at sessions hosted by Scottish Rural Action and Rural Housing Scotland.
The Committee has agreed to highlight to you a number of ways that the draft NPF4 can be strengthened ahead of it being finalised.
Broadly, the committee’s concerns in relation to the draft NPF4 relate to:
The Committee considers that the NPF4 needs to offer more of a vision for rural communities. What does the plan envisage these communities to be? Will they have young people? Will they have attracted people from outside the community, and, if so, where from? At the stakeholder engagement event, evidence was heard that housing in rural areas is central to these questions. Opportunities for population growth cannot be taken up unless there is adequate and affordable housing (and adequate infrastructure to ensure connectivity). The Committee suggests that consideration is given to the Scottish Land Commission’s submission which highlights some key rural issues in relation to housing in the comments on Policy 31.
Bòrd na Gàidhlig’s evidence also suggested that the future of Gaelic is bound up in the questions of what these rural communities look like. The Committee welcomes the Minister’s evidence in which he committed to giving full consideration to this issue in working towards the final NPF4.
The evidence heard at the stakeholder engagement event suggested that stakeholders did not consider the concept of 20-minute neighbourhoods to be workable in a rural context. The Committee therefore considers that greater thought is needed to if, and how, 20-minute neighbourhoods can apply in a rural setting and this needs to be made clear in the NPF4.
The Committee considers it vital that rural areas are not viewed as carbon sinks and that it is recognised that people are required to live in those areas in order to manage them most effectively. In written evidence, the Woodland Crofts Partnership stated, in relation to Policy 32, that:
“It is important to recognise that people are needed to help 'protect and restore natural places', and it is desirable that these people live in those places, to reduce unnecessary travel and maximise local knowledge of special sites.”
The Committee considers that the action areas in the draft NPF4 are not well defined and the concerns raised by stakeholders need to be reflected in the final NPF4. For example, Galloway and Wester Ross UNESCO Biosphere (among others) noted that the North and West Coastal Innovation Area is made up of communities that are very different (particularly in terms of population size) and therefore have very different needs. The action areas were also discussed at the stakeholder engagement event, with the Isle of Bute falling within Central being considered a further problematic example. This highlighted a related concern that island communities were not well represented in the draft NPF4, which needs to devote some attention to the needs of these communities specifically, rather than as they exist within the defined action areas.
When the action areas were explored in the Committee’s evidence session with the Cabinet Secretary and Minister, it was stated that these action areas are “indicative and very much open for comment” (Fiona Simpson, Chief Planner). The Minister added that these:
“are not dividing Scotland up neatly. Clearly, some of the action areas that might be applicable to remote communities might also be applicable to urban communities, while there will obviously be completely distinct areas that do not have the same relevance to others. Although we have identified five action areas in the NPF, again, it is important to look at it holistically and see the complementarity that exists between the different regions and areas”.
This flexibility in how the action areas are viewed is welcome but the Committee considers that this needs to be better reflected in the NPF4 itself.
The Committee considers that the relationship between NPF4 and a number of other policies and strategies could be more explicit and the NPF4 could elaborate on how conflicts between them are dealt with – which strategies take priority. For example, transport policies (such as the second Strategic Transport Projects Review) and the ‘Just Transition’ have a relationship with NPF4 but the way in which they interact is not clear. These are policies that have a significant impact on rural communities and so the Committee would welcome clarity on their interconnectedness in the final version of NPF4.
The lack of reference to the Land Use Strategy in NPF4 was something specifically raised by a number of stakeholders in written evidence (for example, National Trust for Scotland, Association for the Protection of Rural Scotland, WWF Scotland and NatureScot). While the Committee appreciates the Cabinet Secretary’s assurances that, while it may not be made explicit, neither the draft NPF4 or related strategies are considered in isolation, it also considers that the lack of direct reference to certain strategies does leave a lack of clarity about how these matters interrelate. Other strategies, such as the Marine Planning Strategy, are mentioned in NPF4 so it is unclear why some are mentioned while others are not. The Committee considers that the relationship between NPF4 and existing related strategies needs to be clear.
The Committee also considered how the NPF4 interacted with existing or proposed legislation. In particular, the Committee highlighted existing crofting legislation as something that may interact with the ambitions in NPF4. The Cabinet Secretary stated in response that engagement with the Crofting Commission has taken place to ensure read across between the NPF4 and crofting legislation. The Committee considers the interaction between NPF4 and crofting legislation to be an issue that requires further exploration to identify and address any conflicts. The Committee also considered the relationship between NPF4 and the Good Food Nation (Scotland) Bill and, in particular, the need for people in urban areas to have access to food-growing areas. Stakeholders including Obesity Action Scotland set out in their written evidence the importance of the food environment and the role of the NPF4 in that regard. The Committee considers the NPF4 to be significant in ensuring the Good Food Nation (Scotland) Bill can meet its aims. In particular, the Committee recognises that policies 2 and 3 (climate and nature emergencies) could reduce the impacts of climate change on food production and fish stocks, and ensure that the land and marine space used for food production and harvesting is not polluted and degraded. However, this raises a question around the prioritisation of these policies within planning decisions. Further clarity around how policies should be prioritised is also required.
The Committee also considers that the role of communities in relation to the NPF4 needs to be clearer. One of the participants at the stakeholder engagement event stated that community engagement should be the “golden thread” running through the NPF4. The Committee shares this view. Mechanisms must be in place to ensure the views of the community are heard in planning decisions and that the needs of communities are central to decision-making.
Community benefit from development was highlighted as important by a number of stakeholders and this, and community engagement more generally, is central to the Land Rights and Responsibilities Statement. The Scottish Land Commission stated in its written evidence that the NPF4 could be strengthened by recognising this statement and principles which:
“strongly align with, and offer a practical basis for, exercising the long-term public interest in land ownership, management, and use across all land use sectors. Adopting this into planning policy can provide a consistent approach and foundation across land use sectors in Scotland. Additionally, embracing principles such as good stewardship, community engagement, and transparency, can empower planners to act in the public interest and encourage productive land use and ownership.”
This therefore provides a further example of how existing policies could be more explicitly recognised in the NPF4 and the relationship between them clarified.
The Committee would also welcome clarification on the effect of NPF4 on local authorities’ ability to make decisions and set their own priorities, given the significant implications for rural settings. It is important that local authorities are not overly constrained by the national plan and that decisions can still be taken at a local level.
The lack of detail in the draft NPF4 was something that the Committee also explored in its evidence session and the Minister emphasised that the NPF4 was not intended to be prescriptive in order to allow flexibility in the planning system.
While recognising this argument, the Committee does feel there are areas where further detail is required in the NPF4. For example, there are issues in relation to rural housing that need to be addressed such as lack of affordable housing in rural areas pricing young people out of the market, lack of housing more generally preventing rural communities from being able to attract new residents, inability to succession plan on farms due to housing constraints, and often sub-standard housing for agricultural workers more generally. The current lack of detail in the plan does not make it clear how these issues will be addressed. The Committee therefore considers that something more prescriptive is required for planners. This view is supported Heads of Planning Scotland who stated in their written submission that the draft NPF4 contained “too many ‘coulds’ and ‘shoulds’ rather than directing change”. This suggests planning officers themselves recognise the need for clearer guidance.
More general concerns about planners were also raised by stakeholders around their capacity, skills and access to expertise on technical subjects. This was raised in the written evidence considered by the Committee, particularly around matters such as biodiversity, peatland restoration, windfarms and aquaculture. It was also discussed in the stakeholder engagement event, with participants suggesting further training and guidance was required for planning officials. Participants were keen to avoid the ambiguity in the draft NPF4 leading to more planning applications being rejected, rather than the NPF4 being used as an opportunity for planners to become drivers of change in steering forward developments that communities really need. Providing greater detail in the NPF4 could empower planning authorities to take on this role and lead to real positive developments in rural communities.
Further detail has also been called for by a number of stakeholders (including RSPB Scotland, Scottish Environment LINK and John Muir Trust) in relation to Nature Networks. The committee considers that there should be greater guidance for local authorities about what sort of projects would best contribute to Nature Networks, where the best sites are to begin from, and how to deliver cross-boundary Nature Network projects.
The Committee hopes the points highlighted here are helpful in your own committee’s scrutiny of the draft NPF4 and that the cross-committee working on this will prove effective in the development of the NPF4.
Yours sincerely
Finlay Carson MSP
Convener of the Rural Affairs, Island and Natural Environment Committee