National Planning Framework 4 - a community response

NPF4 Position Statement Response

Southside Community Council (SCC) supports the emphasis in the Position Statement on addressing climate change and the requirement of the planning system to help achieve net zero targets. We welcome its statement of intent with regard to creating a wellbeing economy, and its aim of achieving better and greener places.

All of the above are admirable high-level aims which invite agreement; however, SCC would expect to see in the draft and adopted NPF4 much greater detail and action-planning as to how these aims are to be achieved by planning and more widely.

With regard to the planning system, we believe that all of its stakeholders have a role to play. Strong policies are needed at national and local level on which local authorities can confidently base planning decisions, and which will create new development proposals that fit with the ethos of NPF4. We are not aware of research as to what influence previous versions of NPF4 have had beyond setting national developments – the new status of NPF4, we hope, will allow a new direction to be set in particular for the development of new homes.

SCC would offer the following further observations based on our experience of planning and place:

• The Position Statement places a strong focus on the idea of the 20-minute neighbourhood as a model for good placemaking. SCC supports this principle as we understand it, although details are not included of how these would be defined or achieved. We would hope that new development proposals – especially new housing areas on edges of existing settlements - can reflect these principles. This needs to be supported by strong planning policies and decision-making at local authority level.
  
  
• SCC would like to see a collaborative planning system with an approach where – for major and locally significant development significant proposals and key local development plan site allocations - local authorities work with developers and communities very early in the process. This should be a co-design approach to creating briefs and development proposals to a set of key principles (covering design, layout and circular economy) – possibly the planning policies that are to follow in NPF4.
  
  
• SCC would like to see in NPF4 a commitment to better integrating new housing – and other development – with transport infrastructure. SCC operates in an area which offers a good range of local services used by the local community but that will also be attractive to residents of new development on the southern and eastern edges of the city, and areas outwith the City boundary. We believe these developments need better land use and transport integration to avoid total reliance on private motor vehicles, and lower congestion and pollution in south Edinburgh. We therefore support the infrastructure-based approach to new development set out in NPF4 but currently remain unsure as to how this will be achieved. It is clear that the bulk of new housing around Edinburgh and probably in most of Scotland is primarily being delivered by a land-hungry standard model– this has continued for decades without much sense that the planning system can effectively influence this. Use of 20-minute neighbourhood principles to design new developments may have potential to help in this regard. We also feel a cross-Local Authority approach to addressing these issues between Edinburgh, Midlothian and East Lothian will be required.
  
  
• SCC strongly supports the emphasis placed on creating a circular economy in Scotland. We are aware of the impact of construction waste and feel this needs to be addressed through planning policy. If Health Impact Statements are now required for larger development proposals, perhaps Circular Economy Statements setting out how achievable targets can be met could be required as a condition of gaining planning permission. Will planning polices in NPF4 address the use of building materials which are known to reduce climate change? We understand that in France new public buildings must be made 50% from wood – could Scotland follow or expand on this approach? All of this will require collaboration between planning, architects and building standards regimes.
  
  
• SCC notes numerous references to community/ies in the Position Statement but not specifically to Community Councils. Given the statutory role of Community Councils and their potential to be involved in Local Place Plans, it would be positive to see them referenced in this national plan.

You can read the Scottish Government's Position Statement here.