Item 6 - Appendix 1
West Dunbartonshire Council · 14 June 2023
Back to Planning Committee — 14 June 2023 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
Page 1
Local Living and 20 Minute Neighbourhoods. Planning Guidance - Draft for Consultation Respondent Information Form Please Note this form must be completed and returned with your response. To find out how we handle your personal data, please see our privacy policy: https://www.gov.scot/privacy/ Are you responding as an individual or an organisation? Individual Organisation Full name or organisation’s name Phone number Address Postcode Email Address The Scottish Government would like your permission to publish your consultation response. Please indicate your publishing preference: Publish response with name Publish response only (without name) Do not publish response We will share your response internally with other Scottish Government policy teams who may be addressing the issues you discuss. They may wish to contact you again in the future, but we require your permission to do so. Are you content for Scottish Government to contact you again in relation to this consultation exercise? Yes West Dunbartonshire Council 16 Church Street, Dumbarton 0141 562 8794 G82 1QL Matthew.spurway@west-dunbarton.gov.uk Information for organisations: The option 'Publish response only (without name)’ is available for individual respondents only. If this option is selected, the organisation name will still be published. If you choose the option 'Do not publish response', your organisation name may still be listed as having responded to the consultation in, for example, the analysis report. ITEM 6 - APPENDIX 1
Page 2
No
Page 3
Questionnaire Question 1 How helpful is Part 1 of the guidance to further the understanding of local living and 20 minute neighbourhoods in a Scottish context? Additional information for question 1: Part 1 - Local living, the benefits of local living and 20 minute neighbourhoods. Part 1 of the guidance explains that local living and 20 minute neighbourhoods in Scotland have the potential to contribute to global, national as well as local goals around climate action, decreased health inequalities, improved local economy and improved liveability/quality of life. It explains how local living and 20 minute neighbourhoods can be a means of tackling the interrelated environmental, social and economic challenges we face in Scotland through the alignment with policy context, the place context and the rural and island contexts. More information can be found in part 1 of the guidance document. Very helpful Somewhat helpful Not at all helpful Please explain your response explaining what else could be helpful The first section of this part, “The benefits of local living and 20 minute neighbourhoods”, provides a good overview of what the local living or 20 minute neighbourhood approach is intended to achieve, and in addition provides a series of key resources to help define and support these objectives. West Dunbartonshire Council agrees that a local living approach can contribute to delivering this wide range of benefits. It is suggested that this section could however be strengthened by providing more of a grounding in this evidence, in terms of data and research, which show how these benefits are supported by a local living approach. It is suggested that reframing these benefits as objectives, would help to focus conversations on local living and 20 minute neighbourhood approaches on the outcomes they can deliver rather than assuming that benefits will be realised no matter how the approach is undertaken. This outcomes focus would align the guidance more with the Place and Wellbeing outcomes. In relation to the policy context, it is suggested that a greater account could be given to how local living and 20 minute neighbourhoods have been set out in the Scottish Government’s strategic documents, such as the Programme for Government, as well as how it has been embedded within the other wider policy initiatives listed. In general terms there is a link between policy 15 and a number of other policies within NPF4, further acknowledgment and explanation of this link would be beneficial. In particular the guidance includes a lot of detail which relate directly to Policy 14: Design Quality and Place. It is accepted that all policies will be considered in decision making, but this lack of differentiation between policy 14 and 15 confuses and detracts from the
Page 4
understanding of local living and 20 minute neighbourhoods. Part 1 alone refers to ‘The Place and Wellbeing Outcomes’, ‘The Place Context’, ‘The Place Principle’, ‘The Place Based Framework’ and ‘The Six Qualities of Successful Places’. Whilst it is acknowledged that all of these ideas provide positive direction, it is suggested that further clarity is needed in using these ideas within the context of preparing development proposals and applications as well as the planning decision making process. The comments under Public Service Reform are also supported, but again could be strengthened by giving a direct reference to the Place Principle and the role that public services have in its implementation. It is suggested that the subheadings under Place Context would fit within the policy context section. The Six Qualities of successful places could be captured under the policy context as these are part of Policy 14 of NPF4. The section in relation to the Place Principle would fit more appropriately under the subheading on Public Service Reform, as this appears to be what that section is a reference to. While it is accepted that the unique circumstances of Rural and Island communities require consideration in relation to local living and 20 minute neighbourhoods, West Dunbartonshire Council considers that the challenges of delivering of local living for communities in urban and town settings should not be overlooked. A section on Scotland’s unique geography could make more reference to the fact that local living approaches around the world have been focussed on urban geographies, and then explain how this policy approach differs to take account of the more diverse nature of Scotland and how it could apply to urban, town and rural contexts. It is noted that there are graphics which illustrate how this could look within this section of the document, these could be expanded and what they show explained in a more structured way. This could go some way to explaining, the “where relevant” clause of policy 15 and how this could be approached by planning authorities, which include accessible towns or urban areas, when applying the policy in development management decision making. Whilst Part 1 pulls together multiple positive resources and ideas, it is felt that more clarity and rigour is needed to actually outline how they are linked, and how they refer to a specific Scottish context.
Page 5
Question 2 Please refer to the Local Living Framework Diagram on page 19 of the guidance. How helpful is the framework diagram in encouraging flexible, place-based approaches to support local living? Additional Information for question 2: Part 2 of draft guidance - local living framework diagram 20 minute neighbourhoods are one method of achieving 'local Living' and the benefits that flow from it. The way in which 'local living' works will vary from place to place and should evolve, over time as a result of place-based activity with communities and across sectors. The local living framework diagram was developed to support and encourage the type of flexible, place-based approach when considering the daily needs in a place that supports local living - whilst avoiding tick box approaches. More information can be found in part 2 of the guidance document. Very helpful Somewhat helpful Not at all helpful Please explain your response explaining what else could be helpful The local living framework seeks to connect local living and 20 minute neighbourhoods approaches to the existing place standard tool themes. It is likely to be helpful to structure conversations around local living this way and the Council supports having place standard conversations as an approach to getting a better understanding of how a place works. It is considered that taking this approach will be extremely challenging at the level of whole authority plan making. While the benefits of having detailed conversations about a place are recognised, we are not resourced to undertake this at a place by place level so that every area of the planning authority has this level of engagement. It is acknowledged that the Local Development Planning Guidance indicates that place- based studies which are underway can provide evidence to inform the development plan preparation. The Local Development Plan Guidance also indicates that authority wide considerations such as the spatial strategy and land allocations should be informed by this approach. It is also unclear to what extent this approach could be used when assessing a planning application. It is agreed that we could ask applicants to demonstrate this, as suggested later in the guidance, but that would be onerous for anything but the largest scale of development. It would be helpful to have more clarity within the guidance about how the Local Living Framework would be applied to development management decision making. Without providing more guidance on how this can be done based on information that is already available to planning authorities it is unclear how Policy 15 of NPF4 can be implemented. The Council agrees that a number of daily needs will remain constant, but would suggest that the list in Policy 15 of NPF4 should be reflected in the guidance. Development management planners will require to use the policy in decision making, so the link should be clear. Development of an accessibility tool at a national level, or
Page 6
reference to map based approaches would be welcomed, and would be in line with the shared data resource which is being developed by the Scottish Government’s Digital Transformation team. If it is intended that the list from Policy 15 is indicative and/or not exhaustive, this could be explicitly clarified within the guidance. Prior to outlining the framework diagram, Part 2 refers to the ‘Place Standard Tool’ as well as ‘The Place Standard Design Version’. Whilst its value is acknowledged, it is felt that further clarity is needed as to the application of multiple tools / approaches. There appears to be a bit of a disconnect between encouraging a collaborative process with local communities while focussing on the Design Version, which is aimed at professionals.
Page 7
Question 3 Looking at part 2 of the draft guidance: how helpful are the ‘categories’ and ‘key considerations for local living’ that are captured within this part of the document? Additional Information for question 3: Part 2: Categories and key considerations The ’categories’ - Movement, Space, Resources, Civic, and Stewardship, and the related key considerations support the local living framework and are detailed in part 2 of the guidance. They provide detail on the important issues that should be considered and where appropriate, addressed for successful local living. More information can be found in part 2 of the guidance document. Very helpful Somewhat helpful Not at all helpful Please explain your response explaining what else could be helpful The categories and key considerations are useful in capturing multiple ideas that should be considered in design of places. These would be useful, for example, in helping to inform conversations with existing communities to prompt ideas of how places could be improved. West Dunbartonshire Council is very concerned that the level of information being suggested is far more detailed, and resource intensive to collect than the plan making cycle would allow. It questions whether this is proportionate to expect at a local authority wide level when preparing the next local development plan. It is recognised that the Local Development Planning Guidance states that “planning authorities are not expected to collect this information as primary data” however this should also be clear in the Local Living and 20 Minute Neighbourhood Guidance. It is noted that the Local Development Planning Guidance puts forward a number of different authority wide interventions which could be applied in Proposed Plans, it would be helpful if the Local Living and 20 Minute Neighbourhood Guidance made more reference to how these should be evidenced at an authority wide level. It would be helpful to differentiate which of the key considerations are spatial, data based (quantitative) and which are experiential (qualitative). It is noted that this differentiation was included in the Climate Xchange research, but has not been carried through here, nor is this captured in the additional information included in Annex A. Inclusion of this detail within the guidance could make it a material consideration in assessment of planning applications and give certainty while the first Local Development Plans under the new system are emerging.
Page 8
Question 4 How helpful is the proposed 'structured approach' for use? Additional Information for question 4: A structured approach to delivering local living. Part 3 of the draft guidance offers a structured approach that can assist with delivering local living. Three 'key steps' are detailed that can be repeated for incremental change. These are: 1. understand context - understanding the context of the place through the use of quantitative and qualitative information 2. collaborate, plan, design- developing collaborative models of working to inform place-based planning and design processes 3. implement and review - aligning investment, developing delivery capacity and supporting new ways of working More information can be found in part 3 of the guidance document. Very helpful Somewhat helpful Not at all helpful Please explain your response explaining what else could be helpful The approach set out does outline a general process for bringing forward a 20 minute neighbourhood approach, acknowledging that this will require to be tailored to individual locations and circumstances. This is a reference back to NPF4, which could be made explicit. More direct reference to the formal requirements for preparation of local development plans, would be welcomed, although it is noted these broadly align with the cycle as presented and further detail is provided within the Local Development Planning Guidance. As a strategy, local living and 20 minute neighbourhoods offer an organising principle which will create a fundamental shift in how local development plans are prepared as well as decisions on allocations and applications will be made. The change that this will require within the first cycle of local development plans prepared after the new Planning Act, is a more fundamental shift than is suggested by saying this is a process of incremental change, and should not be understated. In light of the climate emergency and other critical issues highlighted earlier in the guidance it is suggested that the transformational impact of local living policy could be emphasised.
Page 9
Question 5 Does part 3 of the guidance clearly communicate the importance of both qualitative and quantitative data in establishing a baseline for a place? Additional Information for question 5: Part 3 - Ways to support local living and 20 minute neighbourhoods; key step 1 - understand the context Part 3 of the draft guidance offers a structured approach to support local living. Three 'key steps' are detailed that can be repeated for incremental change. Key step 1: Understand context - understanding the context of the place through the use of quantitative and qualitative information. This step explains that gaining a full understanding of the context of a place, at the outset, is critical for forming a baseline and for understanding a place. This part of the guidance aims to communicate and emphasise that while quantitative data is important in this regard, the gathering of qualitative information and the way in which this informs action is equally as critical. More information can be found in part 3 of the guidance document. Very useful Somewhat useful Not at all useful Please explain your response explaining what else could be useful A lot more detail could be included in the section in relation to what spatial/quantitative as well as quantitative data is available, or how it could inform a local living approach. It would be helpful if this followed the structure of the Local Living Framework rather than appearing to contradict it. The balance within this section is good, however the earlier section on the Local Living Framework appears to tip the balance far more towards qualitative data. It is considered that the benefit of the quantitative data to provide a baseline should not be understated, particularly where this can be based on readily available information or data which planning authorities collect. While it is accepted that qualitative data provides the richness of lived experience to help to shape an approach to local living, the importance of qualitative data which informs evidence based decision making should not be understated. It is also suggested that the guidance could give greater consideration to how this approach can be linked to the Scottish Government’s Digital Transformation in Planning programme. Whilst the need to have a detailed understanding of context is acknowledged, there is a concern regarding the resource necessary to implement such processes. In addition, given that individuals are likely to have a unique view of what their 20 Minute Neighbourhood should consist of, how are Council Officers expected to carry out
Page 10
these exercises (in multiple areas) and in turn evidence and define specific interventions? The local context is of course critical. However, there is a concern that huge resource will be necessary to establish incremental minor changes, which whilst welcomed, may not respond to bigger challenges regarding climate change, upon which the whole policy is built. The guidance rightfully points to referencing other datasets such as SIMD and Census Data. Whilst this is welcomed, it is felt that further support should be provided in unpicking the complex relationship between deprivation and place.
Page 11
Question 6 How helpful is the 'collaborate, plan, design' section of part 3 in supporting collaborative practices? Additional Information for question 6: Part 3 - Ways to support local living and 20 minute neighbourhoods - key step 2 - collaborate, plan, design Key step 2: Collaborate, plan, design - developing collaborative models of working to inform place-based planning and design processes. Land-use planning is a fundamental tool for embedding local living and 20 minute neighbourhood principles in our places. National Planning Framework 4 (NPF4) provides a new approach to planning by combining the long term spatial strategy with national planning policies to form part of the statutory development plan. This section explains the context for the delivery of local living and 20 minute neighbourhoods beyond planning mechanisms. Local living requires input from a broad range of stakeholders and a cross sector commitment to collaborative working, informing place based planning and design. It involves coordination across investment plans and opportunities and the bringing together of the knowledge and skills of different organisations and sectors. More information can be found in part 3 of the guidance document. Very helpful Somewhat helpful Not at all helpful Please explain your response explaining what else could be helpful The Council supports the approach set out in the “collaborate, plan, design” section of the guidance. Much of what is set out reflects work which is already undertaken as part of plan making and investment decisions. The additional support that the guidance on local living gives for approaches such as “town centre first” and co- location of services is welcomed. The addition of real projects to illustrate the examples given would be beneficial, and show that some aspects of local living and 20 minute neighbourhoods are not radically different from sustainable planning practices which have gone before. West Dunbartonshire Council is relocating the Dumbarton Library from an edge of centre site, to more multi-functional hub located on the High Street so as to enhance the clustering effect of services within the core town centre area. This aims to support more linked journeys and reduce separate journeys to access town centre services. It is anticipated that allocation of land in accordance with 20 minute neighbourhood and Local Living policy will be a significant shift away from current practices in many areas of Scotland. It is suggested that the guidance could give a greater steer in relation to a measurable decision making process to inform these changes, particularly as these are very likely to be challenged. West Dunbartonshire Council has developed a 20 Minute Neighbourhood mapping tool which can show accessibility
Page 12
to key services from a location. This provides an evidence base for local decision making. The approach of pushing decision making on this down to planning authorities is acceptable, giving support to this local approach, but this message could be further reinforced through the guidance, to give planning authorities confidence to make decisions based on a 20 minute neighbourhood or local living approach. More guidance in relation to interim measures, which would better enable us to implement Policy 15, in development management decisions, prior to adoption of the next Local Development Plan would be welcomed. While this section notes recent examples of successful roll out of similar concepts from outwith Scotland, it would be interesting to have a bit more of an overview of some of these more established approaches. As we prepare our own local living approaches, it would be helpful to understand how international exemplars have informed thinking about the local living approach in this guidance as well as how and why the approach in NPF4 and this guidance differs.
Page 13
Question 7 How helpful is the 'implement and review' section of part 3 in assisting the delivery of collaborative approaches to support local living? Additional Information for question 7: Part 3 - Ways to support local living and 20 minute neighbourhoods - key step 3 - implement and review Key step 3: implement and review - aligning investment, developing delivery capacity and supporting new ways of working. This is the stage at which the action identified in the previous steps could be taken forward or planned for. This section of the guidance explains that while a number of cross government policies, strategies and investments are aligned to support local living and 20 minute neighbourhoods, there needs to be a cross sectoral alignment of knowledge, skills and resources, local knowledge, insights and capacity to maximise the benefits of local living. The 'trip chain' diagrams in this section demonstrate the issues that can arise for local services when decisions about key infrastructure are made and local living is not prioritised. More information can be found in part 3 of the guidance document. Very helpful Somewhat helpful Not at all helpful Please explain your response explaining what else could be helpful Comments in relation to the limited resources and capacity for delivery within this section are welcomed. The Council shares this concern regarding the current capacity (in time) given the scale of the challenge outlined in the guidance. The case studies make reference to positive examples but often there is little reference to how long the project took, or how successful the local pilots (which more closely reflect the approach set out in this guidance) have been in developing a process which is scalable across a whole council area. Without the provision of significant additional resource (as shown is necessary within the Stewarton and Wester Hailes case studies) it is anticipated that it will be difficult for councils to deliver that level of engagement for all of our communities. This is a significant challenge for delivering local living policy in line with this guidance. The Council supports the paragraph, “The concept is also applicable (where relevant) to planning decisions. Planning authorities are expected to apply planning judgement in determining whether or not planning applications are supported, or not, by Policy 15. To assist with this, applicants should be prepared to demonstrate how the proposal responds to its context including the existing settlement pattern and the level and quality of interconnectivity of the proposed development with the surrounding
Page 14
area. Policy 15 also sets out a list of considerations to help establish this, but it is recognised that their relevance will vary between applications and contexts. Over time, local living will be embedded within local development plans, providing a further steer on expectations for applications.” This provides a helpful clarification of the development plan section of the local living chapter in NPF4; this link could be emphasised to add further weight to the guidance and could be emphasised earlier in the guidance in relation to the Policy Context.
Page 15
Question 8 Looking at part 4 of the draft guidance: do the case studies provide a useful and appropriate range of examples of good practice? Additional Information for question 8: The case studies in part 4 of the document are included to demonstrate real place- based action being undertaken that helps support local living and 20 minute neighbourhood principles. More information can be found in part 4 of the guidance document. Very useful Somewhat useful Not at all useful Please explain your response explaining what else could be useful The case studies show a really interesting range of approaches from across Scotland, picking up on all of the different types of area and settlement. It is interesting to see the progress that has been made already in light of the emerging policy context around local living, and indeed how established practices can be adapted to form the basis of a local living approach. This section could be improved by including an introduction to the section which explains a bit more about how the case studies have been chosen, for example highlighting that the areas have been chosen to give a range of geographies based on the Scottish Government’s Urban/Rural classification. This could also indicate the range of different project scales and planning processes which are covered. The projects chosen appear to represent a wide range of scales also, but it would be helpful to indicate this within the summary box. This could indicate where the case study covers single settlement/community approach; a whole council strategy; or a local pilot. The case studies do cover different scales, but highlighting this, and making sure there is a balance between them, would be beneficial. It would also be helpful to highlight which planning processes are being supported through the case studies. For example, highlighting if a case study is looking at process change; preparation of the local development plan; supporting Local Place Plans; preparation of a development framework; informing the development of a single site; supporting funding applications; or supporting the determination of planning applications. Again there is a good range of processes covered but this could be highlighted more clearly and there are key processes which will be informed by NPF4 policy on local living which are not captured in the case studies. It is accepted that while local living is an emerging practice, there may not be case studies for every process, however West Dunbartonshire Council can provide examples of where we have used a local living approach to inform the preparation of site briefs and development management decision making; as well as supporting the preparation of funding applications. As previously noted, the Stewarton Case Study is an interesting example. However, in using this, and other case studies, more clarity should be given about the amount and type of resource and time needed to deliver such a project. In doing so, one can plan accordingly in trying to establish how this approach can be applied across a council
Page 16
area. It is noted that the Wester Hailes case study, highlights this by indicating that Place Based Investment Programme funding had been used to buy in professional support to deliver the Local Place Plan in line with 20 minute neighbourhood principles.
Page 17
Question 9 Looking at the impact assessment update report: do you have any views about the initial conclusions of the impact assessment update report that accompany and inform this guidance? Additional Information for question 9: The impact assessment report update relates to the draft guidance on Local living and 20 Minute Neighbourhoods, produced to support the fourth National Planning Framework (NPF4). Local Living and 20 minute neighbourhoods are included within the policy framework of NPF4, adopted by Scottish Ministers on 13th February. The concept of local living and 20 minute neighbourhoods is intended to support places where people can meet the majority of their daily needs within a reasonable distance of their home, preferably through active travel modes or by public transport. NPF4 was the subject of extensive consultation and parliamentary scrutiny and an Integrated Impact Assessment (IIA), involving a number of statutory and non-statutory assessments, was prepared for NPF4 and is available on the Transforming Planning website. The policy intent and outcomes for Local Living and 20 minute neighbourhoods were included within this assessment process. Therefore, the impact of the policy has already been assessed and this updated report summarises key content relevant to local living and 20 minute neighbourhoods gathered as part of the previous impact assessment process. Additional content on the impacts of the draft guidance has been added where relevant or necessary. Read the impact assessment update report. Yes No Please tell us here Business & Regulatory Impact Assessment (BRIA) The draft guidance sets out a very resource intensive approach to understanding local living and 20 minute neighbourhoods, which has largely been based on focussed collaborative placemaking at the scale of a single community. Replicating this approach across a local authority area, has significant resource implications, which have been overlooked in the guidance and understated in the BRIA. The Council disagrees that this places no additional burden on the planning authority. The approach set out in the guidance is fundamentally based on local authorities taking their own approach to the guidance. The Council questions how this achieves the outcomes as suggested by the preferred option in the BRIA, because the alternative, not-preferred, option of doing nothing, also states that not preparing the guidance would result in council’s taking their own approach to the NPF4 policy. It is considered that this highlights a weakness in the guidance which focusses on how to develop a 20 minute neighbourhood approach, rather than how to apply the policy in NPF4.
Page 18
Equalities Impact Assessment (EQIA) The Equalities impact assessment provides a lot of interesting information about how people with a range of different characteristics can be impacted on by local living proposals. Much of this information and the data which it is based on could have been highlighted within the guidance itself.
Page 19
Question 10 Please provide any further comments on the draft guidance document in the box below. West Dunbartonshire Council welcomes the publication of this guidance which describes the positive aspects of living locally; the wider aspirations of this policy and points to toolkits which can be used delivering local living and 20 minute neighbourhoods across Scotland. The Council has pushed forward with developing a 20 minute neighbourhood tool which gives a quantifiable metric for measuring accessibility of a range of different uses across the local authority area. In anticipation of this guidance the Council hoped for a clarification in relation to how current processes and outcomes can be taken in light of Policy 15 of NPF4. In particular, the Council was seeking greater clarity around how 20 minute neighbourhood approaches should be used to inform the allocation of sites in the next local development plan, as well as how to use the information to inform development management decision making. The response to this is that “Planning authorities are expected to consider how the guidance can be applied in a proportionate and place-based way and to use their discretion in deciding which components of the advice are relevant to their processes.” The Council accepts the support that this gives in relation to shaping an approach tailored to our own circumstances, as well as the range of toolkits that the guidance presents to assist in developing an approach. While these toolkits have some helpful suggestions, there is a concern that they have to date been applied at a local level for a focussed conversation about an individual community. As stated above, the application of this is at a local authority wide level to inform a local development plan, is significant resource challenge, and the guidance does not offer examples of how the approach has been taken forward at a local authority wide scale. It is noted that further guidance is provided in the Local Development Planning Guidance in relation to what should be taken into account when developing a spatial strategy and identifying land use allocations, in a way that supports local living and 20 minute neighbourhoods. The Local Living and 20 Minute Neighbourhood Guidance would benefit from providing the evidence base to support these authority wide proposals or giving greater indication of how these proposals can be evidenced by Local Development Plans at an authority wide level. In relation to Development Management, there is very little guidance about how developers and officer should apply the policy before local approaches have been brought forward, in the Local Development Plan or otherwise. The Council hoped that this guidance would provide a more robust approach to help support decision making. Whilst it is acknowledged that the Scottish Government cannot prescribe specific criteria, the decision to place this entirely upon individual councils seems somewhat unfair. The range and complexity of decision making that is necessarily of a huge scale, and will likely be challenged from various parties. As noted, the scale of the challenge in delivering 20 Minute Neighbourhoods and Local Living is huge. It requires a shift in direction across multiple processes within the development of the built environment, and across multiple sectors and stakeholder groups. As such, the ability to think, respond and plan at a scale that is comparable to the task is necessary. To then place the responsibility on individual councils to develop their own approach sits at odds with this. There is a concern that 34 different
Page 20
ideas about what 20 Minute Neighbourhoods and Local Living is, will result in a disjointed national approach, and in doing so, will result in the inability to respond to the scale of the task in addressing climate change and the wellbeing of the population.