This is the first of three loosely linked posts arising from the draft National Planning Framework 4. This one is on the draft itself; the second is on Retail Impact Assessments; and the third is on implications for existing developments.
A few weeks ago, the long anticipated draft National Planning Framework 4 (The National Spatial Strategy for Scotland 2045) was published and is now open for consultation. You can download the draft and the details of the consultation here. Whilst at over 125 pages, the draft is a bit of a slog and there are numerous specific consultation questions, it is something anyone interested in the future shape of Scotland should become engaged with; especially if you are interested in towns and places.
Now I won’t swear that I have read every word, but I did try. My focus in particular here is on aspects in the draft that align with and have impact on town centres and retail. This National Spatial Strategy for Scotland 2045 is presented in four parts; the strategy, national developments, the policy handbook and delivery. The focus is on ‘Future-proof places’ and the policies come under headings of places that are sustainable, liveable, productive and distinctive. These deliver on principles of:
- compact growth
- local living
- balanced development
- conserving and recycling assets
- urban and rural synergy
- just transition
Taking these on face value, they provide a focus for a different development path for the future, aided by the strong presence throughout of the Place Principle, 20-minute neighbourhoods and to a lesser extent, community wealth building. People and place are positioned before travel and the aim is to reduce unsustainable travel and the use/reliance on the private car. These approaches are given a stronger statutory basis, here and at various planing levels, which is to be welcomed.
The devil of course is in the detail, and its implementation. The section of most interest to me perhaps is the one on distinctive places (p97-99 and p104 especially) and the policies on centres (policy 24), retail (policy 25), town centre first assessment (policy 26), town centre living (policy 27) and vacant and derelict land (policy 30). Much of this section accords with the thrust of the recent Town Centre Action Plan Review and its report “A New Future for Scotland’s Town Centres”. Again, this is to be warmly welcomed, but more consideration of detail and operation may perhaps be needed.
The Retail policy focuses development on town centres, building on the work of the last decade or so. However I am worried that the phrase used is ‘should not be supported’ for out-of-town locations; why is this not ‘must not be supported’ if we want to be serious? It removes any ambiguity. This is the same for edge of town developments, where they ‘should’ not be supported unless in development plans. For me this leaves wriggle room on a number of dimensions – why?
It also seems that the sequential approach (and thus Retail Impact Assessments) remain, though sense in their use, given 20-minute neighbourhoods, is encouraged. This is seen more clearly in policy 26 on town centre first assessment, which outlines the sequential approach, but does then seek to ensure proposals are appropriate in scale, the impacts are assessed and importantly ‘the proposal will not adversely impact on action to tackle climate change by generating significant levels of additional journeys with the reliance on the private car’. This reads fine, but I can see legal issues about ‘significant’ and ‘additional’ to start with. My next post is on aspects of Retail Impact Assessments and some problems I think they have.
We discussed the draft NPF4 at our session at the Scotland’s Towns Partnership Conference last week. A video of our session which included myself, Tom Arthur MSP and Craig McLaren on place and policy is available on YouTube). An interactive poll showed that attendees though the draft was on the right lines, but some wanting it to be stronger. I am encouraged by my first reading of the draft, and thus my initial reaction was positive so I ‘voted’ for ‘right lines’ in the poll, but I am wondering if a more careful read might tip me over into wanting stronger words in places?
That though is a consideration for the next few weeks and for my response to the consultation. I would encourage everyone to have a look and state their views. The Scottish Government have outlined the consultation opportunities thus:
“Draft NPF4 is now subject to Parliamentary scrutiny for up to 120 days and the Scottish Government is inviting representations until 31 March 2022. We are encouraging the submission of responses through the Scottish Government’s consultation portal.
We want to encourage responses to the consultation from a wide range of interests and have therefore prepared a range of resources to help you respond. These resources include:
– emerging details of a range of online discussions which you can sign up for.
– access to online material on NPF4, including on regional and thematic issues.
– details of the 18 proposed national developments.
– details of a community grant scheme to support communities respond to the consultation. These, and other resources, can be found on www.transformingplanning.scot.”
As a final note I would say (and thanks to a twitter user for this – I apologise for not remembering who) that once you see the graphic as a head you can’t not see it (and good to see it is looking towards Europe).