This is the fifth in our series of blogs on the draft National Planning Framework 4, previous blogs in the series can be found here. In this article we look at the emerging policies on business and employment use.
One of the aims of NPF4 is to create productive places to "attract new investment, build business confidence, stimulate entrepreneurship, facilitate future ways of working" whilst "improving economic, social and environmental wellbeing".
The focus is on "supporting good, green jobs, businesses and industries for the future." It is anticipated that a "green economic recovery will support our ambitions to build a wellbeing economy that maximises economic, social and environmental wellbeing for all."
Whilst this may sound commendable and inspiring, what does it actually mean for applicants and planning authorities? Ultimately NPF4 will provide the backbone of the planning process, so it needs to be more than bluster and buzzwords; it needs to provide a solid framework for decision-making and economic investment.
Wellbeing Economy
Draft Policy 16 requires LDPs to set out proposals to meet requirements for employment land which support a 'greener, fairer and more inclusive wellbeing economy.'
The phrase 'wellbeing economy' is used 26 times in the draft NPF4 yet there is no attempt to define what amounts to a wellbeing economy. There are already differing views as to what amounts to a wellbeing economy; some take the view that economic growth is only one part of the picture and shouldn’t be the determining factor. It should sit equally with other factors such as diversity or climate change objectives. Others believe that economic growth should remain the primary focus.
The Scottish Government, as part of the Wellbeing Economy Governments, refers to a wellbeing economy as being one which is "inclusive and that promotes sustainability, prosperity and resilience, where businesses can thrive and innovate, and that supports all of our communities across Scotland to access opportunities that deliver local growth and wellbeing".
The Report of the Advisory Group on Economic Recovery 'Towards a robust, resilient wellbeing economy for Scotland' states that a wellbeing economy is one "that generates strong economic growth with the concomitant creation of quality jobs, and that does so with an unequivocal focus on climate change, fair work, diversity, and equality". Failing to define what amounts to a wellbeing economy at national level creates scope for widely varying approaches at local level, disagreement over interpretation and ultimately delay in determining planning applications.
And how an applicant or a local authority will be able to demonstrate that a proposal is contributing appropriately to a wellbeing economy is far from clear. Take a new start up renewables company looking for approval of a warehouse within walking distance of a town centre which will create jobs for local people, use local suppliers whilst contributing to a greener economy – they may tick the wellbeing economy box easily. But how would an application for a new build office for a firm of solicitors be considered? Does the end user have to demonstrate that they have appropriate policies in place to deal with diversity, equality and climate change? This would involve a definite shift from considering land use to considering land user. Whilst planning has always focused on use of land, social and economic aspects have influenced policies and application of planning legislation over the years but considering the end land user has never been a key part of the planning process.
Development proposals will be supported on allocated sites only if environmental impacts have been assessed and are acceptable. This ticks the greener economy requirement but there is no guidance as to what is acceptable other than 'net economic benefit should be taken into account, in the context of Scotland's ambitions for a wellbeing economy.' This appears consistent with a downgrading from the current guidance in Scottish Planning Policy on the importance of economic benefits in determining planning applications.
Green jobs
Within specific action areas across Scotland support is indicated for different types of employment and business uses. Many of them focus on the growth of green job opportunities.
But what exactly is a "green job"? The Office of National Statistics article 'The challenges of defining a "green job' gives an indication of how complex the definition is. There appears to be a general recognition that it is a job in those sectors of the economy that contribute towards the fight against climate change. However, there are numerous jobs where part but not all of the work is 'green. How will they be treated? Is there a need to demonstrate a positive net impact on the environment and perhaps more importantly, do we have the skills required to fill these green jobs?
As with many aspects of draft NPF4, the aims of the economic policies are commendable but as it stands, the feeling is perhaps more one of malaise than wellbeing. The Scottish Government needs to flesh out the detail so there is clarity for applicants and planning authorities on how developments contribute to a wellbeing economy and what will be considered to be a "green job". Only then can NPF4 get a clean bill of health.
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