RTPI Scotland's response to draft Local Development Plan Regulations

PART A – Introduction

1. Do you agree with the principle that regulations be kept to the minimum necessary and that more detail be provided in guidance and kept updated?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland understands the intentions set out within this consultation of providing flexibility and adaptability by including detail within guidance which is regularly reviewed and updated. However, to support the new regulatory framework, Regulations need to contain a sufficient amount of detail to provide legal clarity and certainty, so a careful balance needs to be struck. RTPI Scotland believes there are a number of draft Regulations that lack this sufficient amount of detail and are relate to matters that are too important to be left to non-statutory guidance. RTPI Scotland believes that as substantial redrafting of the Regulations may be necessary, as discussed in our response to the draft NPF4 consultation, Scottish Government may have to re-evaluate previously set out timeframes to ensure enough time is allowed to carefully redraft the Regulations and guidance accordingly.

2. i). Do you have any views on the content of the interim assessments?

• Yes
• No

Please explain your views:

No comment.

2.ii) Do you have or can you direct us to any information that would assist in finalising these assessments?

• Yes
• No

Please provide or direct us to the information: You can upload a file here

RTPI Scotland notes with interest the intentions set out in the Interim Business and Regulatory Impact Assessment (BRIA) to launch a questionnaire which will try and assess the current costs of community engagement in the planning systems and possible resource impacts of proposals on Local Development Plan (LDP) preparation, with the outputs reflected in the final BRIA. As expressed in the consultation response RTPI Scotland share significant concerns on additional resource burden on Local Planning Authorities (LPAs) and we are willing to support Scottish Government on this work.

There is a need to take account of the context of diminishing resources and increased workloads in planning authorities with recent research from RTPI Scotland^[1] showing that:

• Nearly a third of planning department staff have been cut since 2009
• Planning authorities’ budgets have diminished in real terms by 42% since 2009
• In 2020 local authorities only spent 0.38% of their total net revenue budgets
• Planning application fees only cover 66% of their processing costs
• There are 91 new and unfunded duties in the Planning (Scotland) Act, which could cost between £12.1m and £59.1m over 10 years
• Over the next 10 to 15 years there will be a demand for an additional 680 to 730 entrants into the sector

Whilst we welcome the imminent increase in planning fees to bring much needed resource into the system, as set out in recently published research^[2] we do not believe this will guarantee the adequate resources for the planning service to undertake its statutory duties. We are particularly concerned that if the increased fee income is reinvested back into the planning service, it will predominantly be reinvested into the development management service, thereby creating specific resourcing issues for development planning teams.

3. i). Do you have any views on the Fairer Scotland Duty and Strategic Environmental Assessment screening documents?

• Yes
• No

Please explain your views:

As the Guidance sets out additional detail on the intended delivery of National Planning Policies (NPPs), there is a potential for it to generate new environmental effects and should be subject to further Strategic Environmental Assessment (SEA) scrutiny.

3.ii) If you consider that full assessments are required, please suggest any information sources that could help inform these assessments.

Please put down your suggestions here:

No comment.

PART B – Proposals for Development Planning Regulations

4. Do you agree with the proposals for regulations relating to the form and content of Local Development Plans?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland is broadly supportive of the proposals for regulations relating to the form and content of LDPS, however we have some specific concerns:

• RTPI Scotland is concerned that no legal framework has been provided for planning authorities on the means by which policies can be varied from the NPF4 or drafted to suit local circumstances. Therefore, additional regulatory provisions will be needed to define the circumstances which may require a different policy approach in LDPs and the process by which planning authorities are to justify any such deviations.
• Whilst the new-style LDPs are expected to be slimmer with more focus on map-based approaches instead of written policy content, this may not be practicable in many circumstances, for example, through implementing duties such as setting out the methodology for planning obligations.

5. Do you agree with the proposals for regulations relating to the preparation and monitoring of LDPs?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland is broadly supportive of the approach to regulations relating to the preparation and monitoring of LDPs, however we wish to see a number of additions to Regulation 8 including:

• This section needs to set out the legal framework for policy deviation as discussed in response to Q4 and include NPF within Regulation 8(1). With NPF and LDP now, in combination, forming the statutory Development Plan, greater clarity must be provided regarding how LDPs are expected to comply with the NPF. This is especially important considering Section 13 of the 2019 Act will, once commenced, repeal Section 25(2) of the 1997 Act (as amended), which, following passing of the Planning (Scotland) Act 2019, states that “in the event of any incompatibility between the National Planning Framework and the development plan, whichever of them is the later in date is to prevail” which may create confusion around the interactions of LDP and NPF
• Additional background information needing considered to meet the requirements of section 15 of the 1997 Act (as amended)
• Climate considerations to ensure compliance with public body duties under Section 44 of the Climate Change (Scotland) Act 2009 including associated mitigation and adaptions plans.
• SEA Scoping Report which should identify the plan's significant impacts and ways of minimising its negative effects to make the plan more sustainable and more responsive to its environmental effects
• Scottish Infrastructure Needs Assessment and infrastructure assessment framework and methodology, which are due to be prepared in 2023 in line with the Infrastructure Commission’s recommendations
• Consistent wording with 4ZB of the 1997 Act (as amended), which requires LPAs preparing LDPs to have regard to Regional Spatial Strategies (RSS)

RTPI Scotland is aware that the provisions of section 20AA of the 1997 Act (as amended), once implemented, will allow for amendment of LDPs and provide some flexibility with issues if they arise. This work should be done in a timely manner to clarify procedural approaches to Reporters.

6. Do you have views on additional information and considerations to have regard to when preparing and monitoring LDPs?

• Yes
• No
• No View

Please explain your views:

See answer to Q5 and Q7 regarding scope of the Evidence Report.  

7. Do you agree with the proposals for regulations relating to the Evidence Report?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland wishes to see greater clarity in the Regulations and guidance as to what is expected in relation to Evidence Reports. We understand from statements in the guidance that the intention of the Evidence Report is to improve the consistency in the approach to evidence gathering and plan preparation across Scotland. In order to achieve this RTPI Scotland believes provisions should be set out in the Regulations for minimum data requirements. This should also be supported by the  ambitions of the Scottish Government’s Digital Planning Strategy. RTPI Scotland would like to see more detail in the Regulations as to the process by which evidence bases are assessed for their sufficiency at the Gate Check. This could include, for example, testing the evidence base on the grounds of it being up-to-date, relevant, and robust. It could also set out what the scope and parameters of the Reporter’s powers are, for example, further information requests.

The consultation refers to Section (15) of the 1997 act (as amended) but does not provide much needed detail on how this will work in practice. For example, 15(5)(cd) sets out ‘the health needs of the population of the district and the likely effects of development and use of land on those health needs’ be considered. This would be difficult to implement at this stage of LDP preparation as developments and site allocations have not been put forth. There is also a lack of clarity in terms of challenging housing delivery pipeline as no new sites will have come forward at this stage. RTPI Scotland supports the introduction of a mechanism to review existing sites that have failed to come forward as a part of Evidence Report and Gate Check process.

8. Do you agree with the proposals for regulations relating to the preparation and publication of the LDP?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland is broadly supportive of the proposals for regulations relating to the preparation and publication of the LDP, however we have some specific concerns:

• The status of the ‘Call for Ideas’ is unclear – is it a formal stage as insinuated in Annex C or an optional stage as set out in Section 2 of the guidance?
• If the process is to remain as formal stage, then there is a clear need for this to be set out in Regulations, including setting out the necessary information requirements from land promoters to demonstrate deliverability   

9. Do you agree with the proposals for regulations relating to the examination of the LDP?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland generally agree with the proposals for regulations relating to the examination of the LDP but wish to see a number of clarifications including:

• Clarity of scope of examinations including what matters can be re-examined and when. RTPI Scotland believes the scope of examinations should be expanded to consider alignment with the NPF.
• How a Reporter should invite representations on further information requests
• Purpose and remit of the Gate Check and Examination

 

10. Are there matters you wish to highlight relating to amendment of the LDP which may have bearing on the proposals for regulations being consulted on in this document?

• Yes
• No
• No View

Please explain your view:

As discussed previously RTPI Scotland refer to the provision in the Planning Act for the amendment of the LDP, which has not been included as a part of this consultation.

11. Do you agree with the proposals for regulations relating to Development Plan Schemes?

• Yes
• No
• No View

Please explain why you agree or disagree:

No further comment.

12. Do you agree with the proposals for regulations relating to Delivery Programmes?

• Yes
• No
• No View

Please explain why you agree or disagree:

No further comment.

13. Do you agree with the proposals for regulations relating to the meaning of ‘key agency’?

• Yes
• No
• No View

Please explain why you agree or disagree:

No further comment.

14. Do you agree with the proposals for regulations relating to transitional provisions?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland share concerns with other stakeholders over the lack of detail of transitional arrangements and welcome the intention to bring forward separate regulations on the matter.

PART C – Draft Guidance on Local Development Planning

15. Do you agree with the general guidance on Local Development Plans?

• Yes
• No
• No View

Please explain why you agree or disagree:

As mentioned previously RTPI Scotland understands the intentions of providing flexibility and adaptability by providing detail within guidance which is regularly reviewed and updated. This approach however consequently requires that the guidance provide the upmost clarity, all necessary detail and be consistent with the Regulations to support the plan preparation process.

RTPI Scotland have a number of outstanding concerns relating to the general guidance:

• Status of guidance which provides substantial detail beyond the legal requirements
• Whilst a range of national plans and strategies have been referred to in the guidance, it has been done in an inconsistent manner, with no mention of, for example, Housing 2040, the Land Use Strategy, Low Emissions Zones, Cleaner Air for Scotland 2, Onshore Wind Policy Statement, STPR2 and the National Economic Transformation Strategy.
• Poor connection has been made to regional plans and strategies including city region deals, regional growth deals, regional economic strategies and Regional Spatial Strategies
• Whilst further detail has been provided on certain NPPs, this has been provided in an inconsistent manner, with others lacking necessary detail for implementation.
• Detail is needed for the anticipated timescales for each stage of the LDP preparation process
• The timeline should clarify that planning authorities are to prepare SEA Scoping Report in advance of the Evidence Report
• The guidance should better embed the Place Principle and demonstrate how it can be applied to different stages in the plan preparation process

On the consultation more broadly, we are concerned that there are a significant number of uncertainties resulting from the process. Scottish Government has previously set out that the draft Delivery Programme could not be published alongside the draft NPF4 due to the latter document having not been fully agreed and finalised. With this same logic, RTPI Scotland do not understand why the draft LDP regulations and guidance has been published before the NPF4 has been finalised. If significant change is made to the NPF4 following consultation, extreme care must be taken to cross-reference and align the LDP guidance and regulations accordingly.

RTPI Scotland would like to highlight the significant amount of up-skilling that will be required for planners to prepare the new style of LDPs as set out in this consultation. This, alongside upskilling requirements derived from the draft NPF4, will likely need a nationwide training programme. RTPI Scotland would welcome the opportunity to support Scottish Government and other key stakeholders in this regard.

16. Do you agree with the guidance on Development Plan Schemes?

• Yes
• No
• No View

Please explain why you agree or disagree:

No further comment.

17. Do you agree with the guidance on the Delivery Programme?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland agree in principle with the guidance on the Delivery Programme although we believe there is a number of areas where it can be strengthened.

RTPI Scotland welcomes the recognition that preparing an LDP is an on-going activity and support the maintenance of the development planning evidence base but wish to highlight the resource intensive nature of this.  As RTPI Scotland mentioned in our response to the draft NPF4 we see an important role for the Scottish Government’s Digital Planning Strategy in this regard. This includes the development of a shared data resource for infrastructure, planning and place data to support infrastructure providers to provide necessary information available in time for the early stages of the LDP preparation process through to monitoring delivery. RTPI Scotland wishes to see more detail on how the maintenance of the development planning evidence base will form part of the feedback loop that enables planning authorities to assess progress on the implementation of the LDP and potentially trigger a full review of the LDP.

RTPI Scotland supports that the Delivery Programme is to be reported to full Council, but this does not guarantee it will get corporate buy-in and funding to support its actions. Whilst the guidance acknowledges the important role that a planning authority’s Chief Planning Officer will have in terms of preparing an LDP it does not recognise the important role Chief Planning Officers will have in supporting the delivery of the plan, especially through communicating the importance of aligning corporate operations of local authorities with the LDP. We hope that the emerging guidance on Chief Planning Officers can provide further thinking on the matter and are happy to contribute to this. We have published a briefing paper on this which can be read at https://www.rtpi.org.uk/policy/2021/october/chief-planning-officers/

As mentioned in Q15 there is no mention of the Place Principle in this section, which RTPI Scotland believes should form an important part of implementing LDPs. Beyond this the guidance should recognise the role of other stakeholders in delivery such as landowners, developers and infrastructure providers.

Importantly there is no mention of the NPF4 Delivery Programme in this section, which we hope will be significant in terms of delivering at local level, on a number of aspects especially National Developments.

18. Do you agree with the guidance on Local Place Plans?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland believe this section could be strengthened through reference to the recently published Local Place Plan - how to guide. RTPI Scotland are also aware that there may be possible issues around timing which could affect the preparation of an LDP e.g. if an LPP is registered after the Evidence report or before the examination.

19. Do you agree with the guidance on the Evidence Report?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland agree in principle with the guidance on the Evidence however we wish to highlight a number of outstanding areas of concerns:

• RTPI Scotland believes that the Thematic Guidance section of the draft guidance is introducing a number of additional requirements over and above those listed at annex B which could have significant resource implications for this stage of the LDP preparation process
• RTPI Scotland supports the ambition to front load LDP preparation but would caution that many planning authorities currently don’t have the resource to build robust and extensive evidence bases which can be interpreted by GIS
• Whilst reference is made to place-based approaches elsewhere, there is a lack of reference in regards evidence gathering. This section may benefit from some thinking on how evidence may be gathered in a holistic place-based manner to avoid siloed policy approaches to issues
• There is lack of clarity as to whether the Evidence Report is intended to build a robust evidence base to support policy decisions to be taken later on in the process, or to directly draft the policies themselves.
• If the report is simply an LPAs assessment of the evidence base and information is not made available to consultees, the Evidence Report runs the risks of baking in conflict or being perceived as lacking transparency. In terms of presentation RTPI Scotland urge Scottish Government to explore ways in which the digital document can be displayed in a meaningful and engaging way
• RTPI Scotland agree with the recommendations published by the Infrastructure Commission for the establishment of a Scottish Infrastructure Needs Assessment and publication of a new infrastructure assessment framework and methodology. This will be crucial means of supporting preparation of Evidence Reports. Similarly, RTPI Scotland wish to see the role of RSSs clarified in terms of infrastructure assessment
• As set out in Q7 we are concerned that it may be difficult for the Evidence Report to avoid site specific matters regarding certain issues
• As set out in Q5 we believe the SEA Scoping Report should be prepared before the Evidence Report but at present the guidance is not clear on SEA timing

RTPI Scotland support the intentions of the guidance regarding the ‘Call for Ideas’ stage, that is in trying to encourage a range of proposed development types to come forward beyond housing. Under the current Call for Sites process, there can be high volumes of responses, with LPAs in active market areas reporting numbers of 500 upwards. We are concerned over the resourcing implications of this process, following the site appraisal methodology as contained in the Evidence Report will be resource demanding and may require expert input. In order to undertake this important stage of plan preparation, RTPI Scotland would again like to stress the need to effectively resourcing planning departments.  

20. Do you agree with the guidance on the Gate Check?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland broadly agree with the guidance on the Gate Check but seek clarity on what is consider sufficient in terms of the evidence base. As discussed earlier, it may be beneficial to set out the scope in Regulations.

21. Do you agree with the guidance on the Proposed Plan?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland agrees in principle with the guidance on the Proposed Plan, however we wish to highlight a number of outstanding areas of concerns:

• As discussed in Q4 RTPI Scotland is concerned that no legal framework has been provided for LPAs as to the means by which policies can be varied from the NPF4 or drafted from scratch to suit local circumstances. Additional regulatory provisions and guidance will be needed to define the circumstances which may require a different policy approach in LDPs and the process by which planning authorities are to justify any such deviations
• To support the decision maker, it would be useful to clarify what guidance is to be incorporated with the NPF4 which in turn will support preparation and implementation of LDPs
• Whilst RTPI Scotland understand the rationale behind moving focus of LDPs to places and locations with greater use of maps, this will increase the need for NPPs in the NPF4 to have clear and detailed wording.
• The intended enhanced status of development briefs and masterplans set out in guidance needs to be matched by clarity over greater weighting in decision making process
• RTPI Scotland are concerned that the proposed word limit for representations is arbitrary and may not be possible to adhere to for complex matters
• The deliverability of sites needs to consider the role of market forces. RTPI Scotland wish to highlight the resource intensive nature of such work

22. Do you agree with the guidance on Local Development Plan Examinations?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland agrees in principle with the guidance on LDP Examination, however we wish to highlight outstanding areas of concern:

• As discussed in Q5, RTPI Scotland advocates that the draft Regulations provide greater clarity on how LDPs are expected to comply with the NPF, potentially widening the scope of examinations for Reporters beyond issues raised by representations
• RTPI Scotland wishes to see further clarification regarding the ability of the Reporter to recommend allocations for sites that have not been subject to SEA and public engagement during the preparation of the LDP through post-examination consultations

23. Do you agree with the guidance on Adoption and Delivery?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland broadly support the guidance on Adoption and Delivery.

24. Do you agree with the proposed guidance on the Evidence Report in relation to the section on Sustainable Places (paragraphs 240–247)?

• Yes
• No
• No View

Please explain why you agree or disagree:

RTPI Scotland agrees in principle with the guidance on the Evidence Report regarding the section on Sustainable Places, however we wish to highlight a number of outstanding areas of concerns:

• RTPI Scotland wishes to highlight the expected increase in workloads for LPAs from a number of new and additional policy areas set out in this section
• RTPI Scotland wishes to see the SEA Scoping Report included in the indicative list
• As discussed in Q7 & Q19 RTPI Scotland is concerned that it will be difficult for the Evidence Report to avoid site specific matters regarding certain issues, including ones set out in this section such as National developments and strategic land use tensions
• RTPI Scotland wishes to see fuller analysis of air pollutant and carbon emissions beyond considering existing sources to understanding targets and requirements. Reference to Low Emissions Zones and Cleaner Air for Scotland 2 could be useful in this regard
• RTPI Scotland is concerned that no further detail has been provided on Community Wealth Building, which in our response to the draft NPF4 was flagged as NPP needing more clarity, detail and ‘stress-testing’. This is especially important to consider as the Community Wealth Building policy has been proposed as a Universal Policy and therefore need applied to all planning applications

25. Do you agree with the proposed guidance on the Evidence Report in relation to the section on Liveable Places (paragraphs 248 – 283)?

• Yes
• No
• No View

Please explain why you agree or disagree

RTPI Scotland agree in principle with the guidance on the Evidence Report regarding the section on Liveable Places, however we wish to highlight some areas of concerns:

• As discussed in Q24, RTPI Scotland is concerned that the resourcing burden has not been fully considered for a number of evidence areas which may be difficult to collect and evaluate. This includes, for example, identifying a direct connection between planning decisions and health outcomes or considering the quality of an areas existing services
• RTPI Scotland wishes to reiterate comment made in Q19 that the establishment of a Scottish Infrastructure Needs Assessment and publication of a new infrastructure assessment framework and methodology will be crucial means of supporting preparation of Evidence Reports. Similarly. RTPI Scotland also wishes to see the role of Regional Spatial Strategies clarified in terms of infrastructure assessment
• Given the UK Climate Change Committee’s recent appraisal of Scotland’s readiness for climate change highlighting poor performance in handling flood risk^[3] RTPI Scotland wish to see specific reference to the Local Flood Risk Management Plans to strengthen this section
• RTPI Scotland believe the Sustainable Transport section could be strengthened through reference to the shortly expected Strategic Transport Review Project 2

 

26. Do you agree with the proposed guidance on the Evidence Report in relation to the section on Productive Places (paragraphs 284 – 296)?

• Yes
• No
• No View

Please explain why you agree or disagree

RTPI Scotland agree in principle with the guidance on the Evidence Report regarding the section on Productive Places. As before RTPI Scotland is concerned with the resourcing burden of a number of proposed evidence areas including proposed Business Land Audits.

27. Do you agree with the proposed guidance on the Evidence Report in relation to the section on Distinctive Places (paragraphs 297 – 310)?

• Yes
• No
• No View

Please explain why you agree or disagree

RTPI Scotland agrees in principle with the guidance on the Evidence Report regarding the section on Distinctive Places, however we wish to highlight a number of outstanding areas of concerns:

• As before RTPI Scotland is concerned that the resourcing burden has not been fully considered for a number of evidence areas which may be difficult to collect and evaluate. This includes for example proposed town centre audits which could be significant depending on the local authority area. Provision of further guidance on this matter would be useful
• RPTI Scotland would support the recognition of diminishing retail elements in town centre in order to support a shift to town centre living and leisure uses.
• RTPI Scotland is aware that guidance on the historic environment could be strengthened by additional reference to sources such as Scottish Burgh Survey, and local and national Historic Environment Record data

28. Do you agree with the proposed guidance on the Proposed Plan in relation to the section on Sustainable Places (paragraphs 317 – 328)?

• Yes
• No
• No View

Please explain why you agree or disagree

RTPI Scotland agree in principle with the guidance on the Proposed Plan regarding the section on Sustainable Places, however we wish to highlight a number of outstanding areas of concerns:

• RTPI Scotland wish to highlight the expected increase in workloads for LPAs from a number of new and additional policy areas set out in this section
• Given the withdrawal of statutory supplementary guidance RTPI Scotland wish to again question the practicability of producing LDPs that are mainly map based. RTPI Scotland see a leading role for the Scottish Government’s Digital Planning Strategy to set out clear digital and data standards for mapping to improve the consistency of approach throughout Scotland
• RTPI Scotland supports the need for LDPs to minimise new greenhouse gas emissions, maximise emissions reduction and take account of long term future climate risks. However, this is a difficult and technical task to undertake and therefore may necessitate the development of a tool or guidance to support LPAs to do this in a consistent and robust manner
• RTPI Scotland support the inclusion of design frameworks alongside design briefs and design codes. As discussed in Q21, the intended enhanced status of development briefs and masterplans set out in guidance needs to be matched by clarity over greater weighting in decision making process. As stated in our response to the draft NPF4, RTPI Scotland is concerned around the reference to Designing Streets which is now considerably out-of-date and needing refreshed

29. Do you agree with the proposed guidance on the Proposed Plan in relation to the section on Liveable Places (paragraphs 329 – 400)?

• Yes
• No
• No View

Please explain why you agree or disagree

RTPI Scotland agree in principle with the guidance on the Proposed Plan regarding the section on Liveable Places, however areas of outstanding concern include:

• The expected increase in workloads for LPAs from a number of new and additional policy areas set out in this section. This is especially so when considering the proposed production site briefs or masterplans on medium or longer-term housing land allocations, which may not even be included in the adopted LDP
• RTPI Scotland understand there is a need to better clarify the mechanism of identifying potential heat networks through establishing better detail on the relationship between the LDP and Local Heat and Energy Efficiency Strategy (LHEES), recognising that they might not be produced in tandem

30. Do you agree with the proposed guidance on the Proposed Plan in relation to the section on Productive Places (paragraphs 401 – 424)?

• Yes
• No
• No View

Please explain why you agree or disagree

RTPI Scotland agree in principle with the guidance on the Proposed Plan regarding the section on Productive Places, however we wish to highlight a number of outstanding areas of concerns:

• Again, RTPI Scotland wish to highlight the expected increase in workloads for LPAs with several new and additional policy areas set out in this section
• RTPI Scotland understands that the wording in the guidance to support implementation is Policy 19 not clear enough in terms of how LDPs at to comply with the "full potential" requirement of draft NPF4 Policy 19(a) or consistent in terms of managing national designations in line with Policy 19(c). This section could be further strengthened through better representation of a range of renewable energy technologies beyond onshore wind
• RTPI Scotland support the extended application of the Town Centres First approach to when locating the creative sector, culture, heritage, and the arts

31. Do you agree with the proposed guidance on the Proposed Plan in relation to the section on Distinctive Places (paragraphs 425 – 466)?

• Yes
• No
• No View

Please explain why you agree or disagree

RTPI Scotland agree in principle with the guidance on the Proposed Plan regarding the section on Distinctive Places, however we wish to highlight a number of outstanding areas of concerns:

• RTPI Scotland wishes to highlight the expected increase in workloads for LPAs with several new and additional policy areas set out in this section
• RTPI Scotland believes that significant additional policy consideration has been undertaken on draft NPF4 Policy 31 on approaches to rural planning and in our response to the draft NPF4 consultation, we have recommended that some if it be moved to the NPF4 to give it more primacy, especially content of the Paragraph 453. RTPI Scotland wish to see a more joined up approach to Urban/Rural classification across Scottish Government policy.
• RTPI Scotland believes additional guidance should be provided on how the Evidence Report can inform the Proposed Plan regarding managing land use such as flood risk, carbon sequestration and renewable energy development. This section could be strengthened with reference to the Land Use Strategy
• Whilst Policy 32(i) in the draft NPF4 refers to the consideration of Wild Land Areas, RTPI Scotland has not seen any information in the guidance about how this policy approach be implemented through LDP preparation process

32. Do you agree with the proposed thematic guidance on the Delivery Programme (paragraphs 467 – 482)?

• Yes
• No
• No View

Please explain why you agree or disagree

• RTPI Scotland wish to see reference design frameworks and masterplans included in the Design, Quality and Place section.
• As discussed in Q17 there is no mention of the NPF4 Delivery Programme, which we hope will be significant in terms of delivering at local level, on a number of aspects especially National Developments.

 

[1] https://www.rtpi.org.uk/research/2021/june/resourcing-the-planning-service-key-trends-and-findings-2021/

[2] https://www.rtpi.org.uk/research/2021/november/funding-the-planning-service-2021/#_ftn3

[3] https://www.theccc.org.uk/publication/is-scotland-climate-ready-2022-report-to-scottish-parliament/