"…linking infrastructure with planned development is the most significant challenge for the Scottish planning system at this time…"
That was the conclusion reached by the independent panel appointed by the Scottish Government in its 2016 report Empowering Planning to Deliver Great Places. Returning to an "infrastructure first" approach was one of the panel's recommended solutions.
Infrastructure lies at the heart of the recently published draft NPF4 and is essential to the delivery of its environmental objectives, for example, through the concept of 20-minute neighbourhoods. But will the framework and its new suite of policies enable the step changes required in planning, funding and delivery to tackle the infrastructure challenge?
Development Planning
Changes to the plan making process are key to the infrastructure first approach. While the 2019 Act took some of the necessary steps, much remains to be done, particularly in fleshing out the procedure and practicalities for local development plan making. Regulations and Scottish Government guidance are yet to be produced.
Policy 8 of draft NPF4 captures the key requirements for LDPs. Unsurprisingly these include the need for a robust evidence base (infrastructure capacity, condition, needs and deliverability) to inform the plan and its spatial strategy. LDPs should then set out the infrastructure requirements identified, including delivery responsibilities, mechanisms and related developer contributions.
The evidence base is expected to be scrutinised as part of the new "gate check" process.
Planning authority engagement and effective collaboration with the key agencies and other infrastructure providers will be critical but it remains to be seen whether established reactive ways of working can adjust to the extent required. Some providers are concerned that the information expected from them simply won't be available at this early stage - pre-plan and pre-spatial strategy (chickens and eggs). But an infrastructure first approach demands a different way of thinking and working.
Also responding to recommendations from the independent panel, LDPs should align with other relevant infrastructure plans and policies, including the IIP, NTS and STPR. The sustainable travel and investment hierarchies are specifically flagged, and reference to these is peppered throughout draft NPF4, including the development management policies (see below).
Development Management/Sustainable Travel
Inevitably, infrastructure is the subject of a number of other policies in part 3 of draft NPF4, including those dealing with blue and green infrastructure; digital infrastructure, and heat and cooling.
Policy 10 on Sustainable Transport will be of particular interest to developers. In fact, much of its content is familiar from the current SPP, but applicants for planning permission will have to address various additional requirements in transport assessments or reports, including consideration of the NTS2 infrastructure investment hierarchy.
However, despite the policy drafting being largely transposed from the SPP, there are some specific drafting issues (deliberate or otherwise) which should be reconsidered. For example, criterion (c) requires that developments likely to generate a significant increase in the number of person trips should improve accessibility and safety for all modes of travel.
Similarly, criterion (h) (developments which increase reliance on the private car) largely mirrors the existing text of SPP paragraph 287, albeit with a more detailed specification of requirements, but the omission of "or" between the listed bullet points leaves the meaning unclear. Arguably the NPF policy is actually less onerous for developers as relevant developments may only fall foul of the policy where all the bullet points apply.
Policy 10 is critical to the delivery of a number of NPF objectives with a focus on decarbonisation and is likely to be considered alongside policy 2 on Climate Emergency. The application of both policies to development proposals of significant scale and the relationship between them will no doubt become a battle ground for land promoters, applicants and objectors.
Infrastructure Projects
Much of the interest in draft NPF4 focuses on the proposed national developments. The list is interesting not just because of the inclusion of certain eye-catching projects, such as the Urban Mass / Rapid Transit Networks in Aberdeen, Glasgow (see my previous blog on the Glasgow Metro project) and Edinburgh. But also because of the general approach taken.
Some of the developments are site specific and clearly defined in nature. Others are described as "Scotland Wide" with no specific locational requirement (such as Blue and Green Drainage Solutions – generally focused on the City areas of Glasgow and Edinburgh), while others have a specific location but are widely cast in terms of development type or class (such as Dundee Waterfront).
As a result, the categorisation of some developments as "national" by applicants may well be up for debate when projects come forward.
Aside from the national developments, NPF4 will of course influence the prospects of new infrastructure projects. The greener the project, the stronger the policy case is likely to be. Some uncertainty persists over the future of various current Transport Scotland roads schemes. Whatever the final outcome, similar roads projects going through the consenting process in the future will have to work hard to align themselves with this new policy framework.
This is the third blog in our current series discussing draft NPF4. You can read our previous blogs on housing and renewables.
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