Yesterday I gave evidence to the Scottish Parliament’s Local Government, Housing and Planning Committee on the Scottish Government’s draft National Planning Framework 4. It was an interesting experience and lasted 90 minutes or so with a panel of myself, Professor Cliff Hague and Dr Caroline Brown (Heriot-Watt University). The recording of the session should be able to be found here, and the official report of the session will be available here, once they are prepared.
I have commented previously on my initial reading of NPF4. extended this with a discussion of Retail Impact Assessments and then a plea for a balance of measures to both encourage good things and discourage bad things.
In preparation, I re-read NPF4 and thought a little more about some of my initial response and recent experiences (see later). I thus had in my mind six key messages I wanted to get over (within a supportive view of NPF4). These were:
- The language needs strengthening to bring more clarity and certainty; there is too much ambiguity overall and not enough certainty and definition.
- The section on retailing, impact and town centre first assessments needs to be much stronger to avoid ‘wriggle-room’. This is a good example of the ambiguity. I am not sure how to interpret for example that developments should not have a “significant adverse impact” on the town centre. Perhaps more starkly why are we allowing any developments that have any negative impact on town centres, given the thrust of the draft NPF4 and other policies?
- Loopholes need closing now. There will be zoning, land banks, policy declarations that are no longer acceptance or compatible. These need closing now to avoid a decade long drift into the new policy. Given the direction of this and other policies we need to revisit decisions over the last decade or so (e.g. zoning, unbuilt permissions) and if not matching our new directions, should remove them.
- NPF4 could do with a closer alignment to other policies. This is a two-way street – other policies need to be clear about NPF4 e.g. the response to the Town Centre Action Plan Review (where the links are clear in my view and are made) and the forthcoming retail strategy. This would give a greater sense of purpose e.g. on housing and retail development, and more priority for the things, and type of things, we need. It might also provide clarity about types of developments we do not need.
- The Delivery and Action section reads like an afterthought when it needs to be the strongest part in my view. This is especially in the area of additional resources coming into planning; upping the fees is not enough to build the planning skills and progression we need. There needs to be a more fundamental shift of resources and we need to ensure we have a vibrant and suitably robust planning profession to meet our national ambitions and to provide robust responses to proposals that do not fit our agreed ambitions.
- The role of community in planning and place needs clarifying. It is there in part but the how and when of serious community co-development needs to be more firmly drawn out, made consistent and supported, probably financially. One of the common themes in my Town Centre Action Plan review evidence and in the discussions at the Social Renewal Advisory Board was that people and communities did not feel engaged nor listened to and that barriers were sometimes put in their way, leading to a feeling of things to do them and their places and not with them.
I am not sure I got all of these over, but I had a go.
The discussion covered a very wide range of topics, some of which I was not competent to comment on fully, but to hear community wealth building, diversity of ownership, social and community assets, design and wellbeing, historic and heritage assets, 20 minute neighbourhoods, town centre redevelopment, housing in town centres, data and metrics for the new economy and society and other such themes was gratifying. I did conclude by reiterating the point that we need to encourage these sorts of changes, but combine this with an active discouragement of developments and practices we do not want or need. I feel this is essential to making progress.
This concern over ensuring the right direction and re-balance was brought into stark focus last week by the decision of four Stirling Councillors to permit an out-of-town retail and other uses development despite being recommended by officials not to. That decision flies in the face of so many things, including draft NPF4, and is deeply disappointing and damaging. It is one reason why I now more convinced of the need for robust local council action coupled with central oversight of local decisions which go against national policies and also of closing the loopholes which will continue to damage all of us for years if we are not vigilant. That decision in Stirling is the focus of the next post, later this week.