The 8th November saw the publication of the revised National Planning Framework 4 – the national spatial and planning strategy for Scotland. It will now be the subject of further parliamentary discussion before hopefully being approved.
This revision is the result of a year-long process of consultation and reflection. About a year ago, I gave some initial reactions to the original draft as the first in a series of three linked posts (the others on the question of retail impact assessment and the need for a more radical reflection on the existing situation). In January 2022 I followed my initial reactions to NPF4 up with a more considered set of reflections as I prepared to give evidence to the Scottish Parliament’s Local Government, Housing and Planning Committee (the official report of the oral evidence session which I attended is available here, and the final report of the Committee into NPF4 is available here). In that post I suggested six areas for development of NPF4:
- Tighter language
- Re-consideration of (retail) impact approaches
- Closing of loopholes
- Alignment with other policy/strategy
- Delivery and action plan development
- Stronger role of community voices.
The newly published revision of NPF4 is accompanied by an extensive reflection on the wide range of general and specific points received in the consultation. It is impossible here to do justice to the range of these or the work that has gone into the revision.
Looking at the revised NPF4 it is heartening to see a lot of progress in some of my six areas. The language is certainly more directive, and alignment, and delivery are more central. The revision has I think a stronger place focus (though I regret the loss of “distinctive places” as a separate policy approach) and is clearer on the principles and possible issues, as for example the 20-minute neighbourhood and the problems with drive thru’s.
As ever, it will be the operation on the ground that will decide the effect NPF4 has. Here I do have some concern over the question of impact, in thayt I am not sure that my concerns expressed last year on retail impact assessments have fully gone away. Whilst the language is much stronger in the revised NPF4 and Town Centre First and the Place Principle are clear drivers, there remains scope for a Local Development Plan to do odd things and for quantitative “deficiency” to be used as a lever for out-of-town development. One hopes this will not be the case, given the clear thrust of the overall NPF4 approach and the wider policies with which it links, but my prior experience with some local authorities gives me pause. We must align all levels of the approach.
As an example, there was some press coverage last week about Scotland banning drive thru’s and out of town retailing, but this will be unclear until practice settles down and much may depend on local actors – which brings us to Stirling.
My two posts of last February that followed my appearance at the Parliamentary Committee were about the situation in Stirling (and in particular the over-ruling by members of officers in regard to a proposed major out-of-town Asda development) illustrated my concern about questionable local decision making destroying national, local and good policy intent. The posts (Stirling – all at C and Stirling- still all at C) focused on local decision-making and policy approaches. This decision to permit the out-of-town superstore, was in March 2022 called-in by the Scottish Government and last week saw their decision on the application (decision letter here and newspaper coverage here).
I was very pleased to note that the Minister agreed with the Reporter and refused planning permission. The grounds revolved around the Retail Impact Assessment and the Local Development Plan and inter alia the change in retailing and consumer behaviours since the late 2000s and during the pandemic. It was very positive to see the Minister making this decision, and one hopes it sends a clear signal for others. One hopes that this is the end of this matter, but that remains to be seen. The direction of NPF4 would certainly suggest that such developments should be consigned to history.
So overall I think it was a very good week, with a revised and strengthened national framework and some sense on a controversial local decision. It will take time to fully read NPF4 (and its implementation plan) and I may have further thoughts. Likewise, the reporter’s report into the Crookbridge site at Stirling is an interesting read and may warrant a further exploration of some of the issues.