 Good morning and welcome to the 29th meeting in 2022 of the local government housing and planning committee. I would ask all members and witnesses to ensure that all their devices are on silent and that all other notifications are turned off during the meeting. The first item on our agenda today is to decide whether to take items 4 and 5 in private. Are members agreed? We're all agreed. We now turn to agenda item 2, which is to take evidence on the national planning framework 4. We will hear today from three separate panels of witnesses. For our first panel this morning, we are joined by Robbie Calvert, who is policy lead from the practice and research officer of the Royal Town Planning Institute, and Jim Miller, who is the chair of Heads of Planning Scotland. A warm welcome to you both. I would like to begin our questions. We've got a number of questions from colleagues, and as there's two of you, we've got a nice bit of time. I think we can relax a little bit, but I'll be keeping us to time, of course. I'd like to begin with a broad overlook. Can you briefly outline your views on the key changes made to the revised MPF4 draft? I'll go first. Quite a significant number of changes have been made to the draft. I think the same essence of the framework is there from the previous draft. A number of those changes, for example, with the national planning policy section, we counted 427 changes. A couple of them are more substantive, but a number of them are smaller editing points about clarity and consistency, which is something that we asked for. We're broadly supportive of the revised draft framework that's put in front of us. The essence is similar to the previous draft, especially with that focus on climate change, the climate emergency and the nature crisis, which is something that we support. If anything, I think that more focus is now on those two particular areas, which is something that we definitely support as well. At a high level, we would support the committee in their report to Parliament for the approval. The framework has been delayed. A lot of that has been out with our hands, Covid and whatnot. A lot of planning authorities, and I'm sure Jim will pull in on this, have been waiting to proceed with their local development plan preparation. We're waiting to have this national framework in place to do that. Having said that, there are a number of issues that we still have, and that's around resourcing the delivery programme. We'll maybe come back to those through the questioning. I'll just leave it there for now. Thanks very much. Jim, what are your thoughts? We welcome the publication of the draft MPF4. We're pleased in the improvements in context and content, clarity, consistency and detail. We welcome the firm focus on climate and nature crisis, just as Robbie has said, linking across all the policies. It's much clearer there, the key focus. Just as Robbie said, we have concerns about resourcing and upskilling. I'm sure you've heard this from us before in terms of initial responses to consultation. The plan brings in a number of new requirements for local plan authorities. It states in the delivery programme that local plan authorities are key stakeholders in delivering the MPF4, but we have strong reservations about the resources and the skills sets that our authorities will have. We have been working furiously behind the scenes for the last two weeks since the plan was delivered to Parliament on 8 November. We had three open sessions with over 200 colleagues, planning officers from across Scotland, attending those open sessions representing 34 planning authorities. It shows the commitment from the plan authorities that we want to get this right. Our key concern is the timing. There seems to be a bit of a race to the finish line here. In inquiring from colleagues in the Scottish Government, the procedures are not in place to allow further change. We would like a short pause to make some tweaks and changes to ensure that we have a document that is more legally robust and less challengeable. Our fear is that some of the policies are in conflict with each other. We will not go into detail in these today. We will give you that in the written evidence to follow. There are concerns that we could find ourselves in appeal situations with these conflicting policies. Thank you very much for raising that issue. I think that that is good to hear. We welcome the written evidence that you are planning to send to us. I am thinking more specifically about the climate and nature crisis. Robby pointed that out. In practical terms, what does the requirement for decision makers to give significant weight to the global climate and nature crisis mean for development, management and development planning across Scotland? Clearly, planning is not a black or white thing. It is a grey area. We have a planning balance. Additional weight to that is, of course, more emphasis. I do not think that that means that it necessarily trumps everything in every situation. In the planning system for the last 20 to 30 years, we have known what we have needed to do in terms of sustainability and climate change. We have not necessarily had the strength of policy framework nationally to support that decision making. There will be some difficulties. I think that Jim has touched on that already in terms of the transition into this new framework, particularly for development management planners. Some concern about what Jim is saying and what hops have picked up on legal challenges. On the climate emergency policy, it is one thing that the Scottish Government has set out in its delivery programme that it will supply guidance for. That will be one of the more immediate pieces of guidance that will get issued. A lot of that will be around the emissions assessment, which is a new part of the policy coming through there, or certainly a new duty on development management planners. Regarding the nature crisis, we are expecting the development of nature guidance, which was also consulted on last year. Going back to the actions part of the delivery programme that the Scottish Government has set out, that has been touted as short to medium term. There is quite a wide berth there in terms of when we would expect that guidance. I think that that goes for a number of parts of this framework. There are many parts of the planning act that need to be implemented to support its delivery and a lot of additional information that is needed through guidance. If you look at the work programme that is set out in the delivery programme, some of that we will not expect in the short term, which is concerning for development management planners in particular. It is going to leave people a little bit in the dark around decisions that are probably going to come forward quite quickly. Jim, have you got any thoughts? I think I'll pick up on just that last point as well. The gaps in when we can expect the regulations and the guidance, which will inform the policies, is a key concern because interpretation will therefore be open to others. I'll give you an example that we already have colleagues being asked by the Department of Environmental Planning Appeals for consideration of MPF4 in current applications. We have already been faced with challenges of how to interpret those policies and have been asked to give evidence to the reporters unit on current cases. Never mind when the plan is actually adopted. We are a wee bit in the back end with that, but I come back to the substantive point, which was how we were placed in terms of climate crisis. I think that, again, what Robbery said, planning has been at the forefront of sustainable development for as long as I can remember, and I can go back to the 76th Circulate Regional Plan when brownfield development was first mooted in my recollection. I think we're comfortable with that. It will simply be the challenges that we receive in terms of interpretation of policy and how we can, as I said already, skill up our officers to address that challenge. I would also say that it's not just that the planning system is wide-ranging. We have the key agencies, other statutory consultees, internal services and the developer side, the applicants. All of those will face the same challenges to ensure that they are on the same page as us so that we can have an effective planning system. We all want to see the planning system delivered and we don't want to have barriers thrown in the way with the challenges on it. I think that's why we said at the outset that if we had time to pause and just make further changes to it, that would do more benefit to all, but I do recognise that if it was open for a further stage of consultation, it would all be open to every bit of challenge. I can understand why that's the situation. We're now going to move to a question from Mark Griffin, who's joining us online. Given the economic turmoil, there's understandably been a lot of focus on economic growth from Government and in Parliament. I just wanted to ask what it seems whether they're confident that the draft NPF4 will encourage, enable and essentially drive sustainable economic growth. Given my development management experience and policies, our range of policies, some are counter to others and it's down to the decision maker and what weight they give to those policies. What the NPF will do is inform LDPs and it's basically up to the local plan authorities what weight and what importance they give to those policies within the key focus of the climate change actions. I think there will be scope and hopefully there will be plenty of scope for local authorities to set their own agenda and it won't be a top-down approach. I'm comforted if you look at the housing figures for example and that's part of economic or sustainable economic growth. The plan has minimum tenure figures and that leaves it to local authorities to decide whether they want to go above or stick to those minimum figures. Is that flexibility for authorities as I think is key to ensure that we have a sustainable system? I think we'll come back to this later on. We've said this all along. A lot of this lies in the implementation of this framework, not just its preparation. If we look at the delivery programme and some of the delivery mechanisms that are touted in that, which I think will be pretty fundamental to sustainable economic growth. That's alignment with, for example, the infrastructure investment plan. I think that that's particularly important to look at some of the newly established place planning and infrastructure advisory group and how they will interact with the next iteration of the infrastructure investment plan. We've said all along that we want a capital investment programme published alongside the framework like we've seen in Ireland. That's not happened. So now we've got to really make sure that this lines up with the next iteration of the infrastructure investment plan but also the street at transport projects review 2 and the national strategy for economic transformation as well. So it's maybe a little bit out of sync with the last two that I mentioned there in that they're already published. They do have action programmes though. So we want to see the next iterations of those action programmes lined up with the delivery programme as set out here as well. I think we'll come back to that maybe in more detail. It is good to see the infrastructure first policy. We would have liked maybe better alignment with the infrastructure first policy in the actual delivery programme or the infrastructure part of that but that could be an important step forward in terms of ensuring that we've got the right infrastructure in place for sustainable economic growth. There is a resourcing part of that and we're yet to see the final regs and guidance of the local development plans which I imagine will be doing a lot of the heavy lifting in regards to the infrastructure first policy. So there's still some unknowns here at this stage but I'll stop there. Thanks, Robbie. I'm going to bring in Willie Coffey with a supplementary on this question. Thanks very much, convener. Jim, you mentioned the local development plans there and so did you. Just then, Robbie, is there a pressing need urgency, do you think, for local planning authorities to review their LDPs particularly where there may be references in the new NPF4 that are perhaps not contained within the current LDPs that they have? Was there a need to revise and review these as soon as they possibly can? It's softly spoken there. I missed most of the question but I think it was. It's on the local development plans. Do you think there's a pressing urgency for the planning authorities to revise these to get them into fit enough local shape because there's provisions in the new NPF4 that would impact on the local development plans? My own authority, if I take that as an example, we have paused preparation of our new LDP awaiting the LDP guidance, which is to come to the delivery programme that will be in the short term. So we took the decision, I think quite rightly, that we have retimetabled our delivery of LDP and moved it back some 18 months or so so that we can take account of the guidance which flows through. There is a requirement for the LDP to align with the NPF until we saw that two weeks ago we would have been in the dark to exactly take it a step forward. We have been working behind the scenes and I'm sure other authorities have as well to ensure that we're ready to go. If you then roll that forward, are we looking at 34 LDPs all coming forward at the same time? When we talked earlier about resources, that very resource implication for our colleagues in the reporters unit when those evidence reports start to flow. So there is a concern about a backlog and a slow down of the planning system and going back to the earlier question of sustainable economic growth, we all want to see that but if we have plans that are being delayed then there is a concern there. I would absolutely agree with the resourcing point there. I think we're also concerned that all the LDPs set off at once and maybe we'll have to manage this in a smarter, more pragmatic way even if that series of LDPs setting off so we don't get 34 evidence reports all at once which will create issues for the planning authorities and for the reporters unit which we're also concerned about resourcing and some of the real-time cuts that they're anticipating over the next three years. But also all the key agencies as well and even the private sector would struggle to respond to 34 evidence reports all at once so it could be the case that we have a trailblazer group here for example and then learning is taken from then and then other LDPs set off as in when we think we can actually have the capacity to do that as an industry. We want to work as collaboratively as possible with the Scottish Government colleagues. We're all professional planners, we want an effective planning system but we're certainly highlighting some barriers that are coming before us and we will endeavour to do our best to address those. I'm not going to bring in Marie McNair with some questions. Thank you, convener. Good morning, panel. It's good to see you here at the committee. I'm just wondering if you're satisfied that the terms such as community wealth building in 20 minute neighbourhoods are now sufficiently well defined and understood to provide a robust basis for planning decision making. I'll pop it to Jim first. I think I'll pick up that one North Ayrshire. My authority is well based in community wealth building. There are opportunities, there are great opportunities for community wealth building within the planning system. It's maybe not clear again with the explanatory notes and the guidance exactly how that's rolled out but my experience in delivering those over the past two years or so within North Ayrshire is achievable and it's deliverable. It's now a policy based in terms of NPF, therefore there's such a requirement where before it was negotiated on a voluntary basis but I'm more than content that the planning system is well placed to deliver community wealth building. 20 minute neighbourhood there is concern in terms of rural authorities and I represent an island authority and what 20 minute neighbourhood means within the rural context but I think again keeping this word like a guidance and exactly what that means for different populations is key to how we deliver that and it won't be one size fits all. There will be 20 minute neighbourhoods within the major conurbations, there will be smaller ones within small settlement towns. As long as we don't get fixated on 20 minutes because 20 minutes is the banner headline, it could be a 10 minute neighbourhood, it could be a 30 minute neighbourhood. The concept is that we have liveable places and that everywhere is walkable or accessible in terms of the 20 minute concept but don't define it as how quick a walk that is then we will get into very minute type which we don't want to be. On both policies I think they've both improved quite significantly from the previous draft. A lot of clarifications have been made that we asked for and some of those have been set out in the explanatory report that accompanies the draft. To go back to an earlier point, I think we will get more detail on both of those in the local development plan guidance and regulations. For example, living well locally in the 20 minute neighbourhood policy and how that was addressed in a rural setting, more detail was added to that in the local development plan guidance. I hope that that will support us through implementing those policies. I think that both of those policies are vastly improved from the previous draft. There are a number of references to infrastructure first approach in revised NPF4. Has that been delivered in practice and what needs to change? The infrastructure first policy, as I understand, hasn't changed a huge amount from the previous draft. There are some clarifications on the intent behind the policy but more detail will be in the local development plans for this policy in particular. I think that they'll be doing a vast amount of the heavy lifting there. How it works in practice, I think that we'll come back to that in terms of the delivery programme and the infrastructure parts of that later on. I think that there's a certain disappointment that there's not a capital plan alongside the NPF in terms of delivery. Certainly the indication is that LDPs should be aligned to the council's capital plan and showing how the infrastructure first can be delivered through the LDP. That seems to be missing to date from the NPF although there is reference to future influence of the infrastructure investment plan. That's not there. There is reference back the way, which seems a bit strange, that it has influenced previous plans and it's not clear to me exactly what that means. There seems to be no new money in terms of the NPF but maybe that is something that's still to come towards us. Thanks Marie and we're now going to move to Annie Wells, who's joining us online. Good morning, convener. Good morning, panel. Every local place plan will have to have regard to NPF 4 but looking at this draft, how confident are you that community bodies will be able to do so and what help might communities need with such a task? For local place plans, the approach that we've adopted within, I'm sorry, being parochial here but North Ayrshire, is to support our communities where we can. But there's a resource implication again for that and it sounds as though I'm buying the same drum every time here but it's true. There'd been estimated cost up to £10,000 to prepare a local place plan and that's not a resource that certainly authorities are sitting on when you look at the number of communities that might want to be served by a local place plan. But we have professional planners within all of our authorities who are there to assist but the devil will be in the detail of how much is required of those local place plans. Not every community will require a local place plan where we have regeneration plans being rolled out just now, part of the Scottish Government initiative for a number of our communities across Scotland and they may take the place of local place plans. So it would be a good way to see how much the demand is for those but we're certainly here to assist. Maybe reiterate that point around resourcing and I think local place plans is a good example of that. That's something that's come through in the planning act but not necessarily through in the national planning framework for it. It's something that is going to be an additional resource burden alongside a number of additional duties that have come through in the planning act. So I think when we're considering about any additional work coming to planning authorities through the NPF4 it's good to frame that within the wider scope of the planning act 2019 and additional work that's coming through there. I think in regards to local place plans we've said it all along there needs to be funding pots for communities to undertake these otherwise we could potentially get in a situation where we're exacerbating inequalities in our country anyway with the well to do, the well off communities with the resource. To support the process of preparation delivering these local place plans and then other communities not being able to. We see that down in England with neighbourhood plans, funding is available for them for example. I think another interesting thing to note from what's happened with neighbourhood plans down in England is that it's been more successful in rural locations than urban. So I can imagine similar patterns happening here but yeah big question over the resource in there. I think in terms of how communities interact with the revised draft as opposed to the previous iteration. I think it is more user friendly. There is a how to guide that's been put in the annex for example and some of the additional information that was kind of upfront in the previous draft has now been annexed. So for me it's easier to work document so I think at least from that perspective it should be a bit more user friendly. Doesn't mean there's not going to need to be resource to support people through this. I think one of the things that Pobbus would like to see is maybe a summary. Maybe in plain English so when we are dealing with stakeholders like with local place plans it's an easier read and it's not just a document for professional planners but I certainly agree with Robbie certainly more user friendly than the previous version. Thank you very much panel and thank you, convener, that's me. Thanks Annie, just on that local place plan piece how will it all fit together? There's a local development plan and that's great that Jim you were talking about how you've paused them. What's the sequencing there and will communities, how do we get communities on board and kind of alert to the opportunity of making a local place plan and then how does that feed into local development plan? Is there a timing on that? It's already out there so we already have communities active in preparing local place plans. Those local place plans will have to align with the NPF so they're very much at the formative stage, evidence gathering what they want to see in their local place and when that starts to come to fruition and it will take a while. I could gues to make 18 months or so but it may take longer than that. It will have to sit in the context of the NPF as well in the same way the LDPs will as well. Right but the plan also needs to sit inside the context of the LDP as well to some extent or totally? If you take what comes first in my opinion, it might be subject of legal opinion, is that with the NPF being adopted it takes primacy in terms of the development plan and every other plan has to follow in line with that. So local place plans are in my opinion no different from that. Right okay and the ones that have been being developed already will need to maybe go back and reconsider some of what they've been doing in light of the idea point. I don't see these being as mature enough at that stage to have to be revisited but certainly they would have to take account and maybe that's why the point I raised earlier to the earlier question was maybe an easier reader summary of the document and a guidance for communities who are not professional planners would assist. I'm just aware locally by me. The town near me has been very busy on what would not have been called a local place plan because those didn't exist for quite some years and very good work that they're doing but now they're probably going to have to go back and have a look and see how it works with the NPF for. Okay, we're going to bring in questions from Paul MacLennan. Yeah, thank you, convener and good morning panel. I was going to ask two questions. The first one was really on talking about the delivery programme and it's mentioned in about obviously the establishment of planning infrastructure and place advisory group. You kind of both touched on that but don't know if there's anything else you want to add on that. The second question was about one of the things as a committee we were quite keen on was monitoring the implementation of NPF for over the number of years. We've seen how much things have changed in the last 10 years so we're keen to monitor how effective it is over the next number of years. Are there any indicators or issues that you think the committee should be paying particular attention to in that regard? This is probably said earlier, the formation of a planning infrastructure and place advisory group and the commitment to monitoring and evaluation are important key elements as far as hops are concerned. We wondered if there was a role for this committee in terms of monitoring the work of that group. The delivery programme references a board and it's not clear from the delivery programme what constitutes a board. It does seem to me a bit reinvent the wheel when you already have a committee who could be there to evaluate and monitor but not being familiar with parliamentary procedures. That might be not competent but it does strike me that there is a role there for this committee in monitoring and evaluating. It does say in the delivery programme it would be revisited here after six months which I think is welcome and then it's annual review exactly what you're going to monitor is a bit unclear because the policies will still be at their formative stage. Maybe you can start to pick up and take evidence on the impact of the policies through applying appeal decisions, through LDP progress. There's a number of areas that could be monitored even within the first six months but maybe I'm giving you too big a job to take that on. It's certainly in discussions within the committee that that was one thing that we were keen to do to make sure that there was on-going monitoring right throughout the ten years sort of thing. You mentioned resource for example and I know Robbie, but I think for example is that one thing. From a Hobbs point of view he talked about it because from one local authority one of the key things that was mentioned was about the additional training that was worked for example the carbon measurement was something that local authorities will need to try and pick up and there's obviously additional training and additional resource in terms of that as well. That was an issue that was raised in terms of that so resource I suppose would take that would be one measurement you would like to see over that number of years as would Robbie probably want Robbie in a second. Are there any other specific things that you would like to see from the Hobbs point of view from this committee to look at? Probably one from your own perspective of the heads of planning but also that much broader measurements within. There is a commitment within the delivery programme for the Scottish Government planners to move from policy development to policy delivery to means strikes. There should be working with local plan authorities in terms of training and upskilling as we said earlier. There is a commitment within there to improve. There's a reference to one of the recent training programmes as an example. I think it was in hydrogen. It's actually a specific reference. So that's a commitment from the Scottish Government to reflect on that. We have the improvement service that we use to upskill planning officers. We're going through a programme of carbon literacy that's just now funded by Hobbs through our own funds. So there's a joint commitment there to training and perhaps that's something that could be evaluated and monitored as we go along. Robbie, I know that you and I have had discussions before on recruitment and resource and so on. I don't know if you want to add anything about the delivery programme and the key measurements that you would want to see as well. I'll start with the delivery programme. I mean, there is actually a resourcing question about the delivery programme itself for yourselves and all stakeholders here. I don't think that was part of the business and regulatory impact assessment that accompanied the revised draft MPF4. I think there is a question about that. I think for the advisory group, the planning infrastructure in place advisory group, there's two really important roles there. And I'd say the first one's one I mentioned earlier about the infrastructure investment plan and having that key influence there. It's something we understand. That's the intent but in terms of detail and I think that's maybe an issue more broadly with the delivery programme that's just not there and how we want to see that working. There is a really interesting little paragraph here at the start of the delivery programme that says, the delivery programme focuses efforts across the Scottish Government to ensure alignment across national plans and programmes. This alignment will be an iterative process building over time. Firstly, that is a really important thing to monitor. I think that there will be a role here for the Local Government Housing and Planning Committee with the annual reporting procedures that you'll put in place is to see not only how is the MPF4 aligning with existing plans and strategies but how new plans and strategies coming on board are taking consideration of the MPF4. I think that that's something really important that we need to look at over time. I think that in terms of the oversight and monitoring bit, there is a brief part of the delivery programme where it discusses some of the key stakeholder groups that this advisory group will interact with. So that's the high level group, that's the key agencies group, the infrastructure delivery group, the Scottish Government. We would add the Local Government Housing and Planning Committee to that, but we would also add the Office of the National Planning Improvement Coordinator, which in the delivery programme is fairly quiet. I think that it is mentioned in terms of oversight, but we think that that could be brought more to the fore. We are waiting guidance on it and I think that that will come in the short to medium term if you look at the actions part of this delivery programme. We see that position and we say it's an office, not one role because it's actually quite a big job to monitor and review the entire planning system. That's why we call it the office because we're basically being clear about the kind of resourcing that it does need and in our written evidence we've linked to think piece that we've done on the matter. We think that that would also have a crucial part of the kind of oversight. I think what Jim's already mentioned about the kind of review of the delivery programme itself coming in the next six months. I'd be interested to hear how the committee will interact with that review, how will you be out of sync with your kind of annual reporting or will there be an opportunity for the committee to get involved with the delivery programme at that six month mark or just before that so that you can have some oversight of it as well. We'd obviously welcome our involvement with that process. Any other indicators, Robbie, that you would like to see? Indicators? You've mentioned quite a bit there already. Yes. I have one more. Clearly, obviously, national developments. So national developments are mainly with the Scottish Government to deliver. I'm a bit worried when it says in the development plan that development plan states that move the funding for national developments still needs to be agreed and factored in. So we have a plan about to be adopted to deliver national developments but the funding still needs to be agreed and factored in. I would query exactly what that implies. It appears it's a work in progress which is not really what we want to hear and perhaps that's something that could be reviewed in six months. Has it been agreed and factored in? I think, Keith, as you mentioned, it's an iterative process. We need to be making sure that it's a living document going through the next ten years, even in the next six months to a year sort of thing. So no, that's been really helpful. Can I just come back on the indicator part? There is quite an interesting section in the delivery programme around indicators itself. So that's section five there but under the spatial strategy and there's also a put forward there. I think you have this issue with, you know, it takes a long time for development to come out of the ground. So policy changes now could take five, ten years before we can really monitor them effectively or not. But there's a table there with some really interesting ideas, you know, Scottish greenhouse gas inventories, journeys by active travel, satisfaction with housing. So it's actually quite an interesting bit of work that's been done there and that's been lined up with some of our outcomes work that we published a couple of years ago now. Robbie, thank you for that. There's new duties that have been added in. In our written evidence, we will be itemising those new duties and where policies have been substantively changed. When we had those three open sessions, one that kept on coming up was suicide. So how spatial planning has to address a policy on suicide is a question mark. I don't want to take up the time to debate on that but there are new areas that have been reduced to the planning authorities which we have concern about how we can actually deliver that. And it raises an expectation within our communities that we can make those changes. If we don't have the tools or the skills or the ways to make those changes, then it lessens the impact that planning could have. Thanks both. Jim, I just wanted to say that I was really impressed. You just said at the beginning that you've already been so busy since this has come out and bringing together all these planners for these discussions and questioning how this is going to work in the sector. I think that's fantastic and poignant that you bring in this piece that planning and how we decide to have our built environment can affect somebody's decision to choose to live. So I think that's tremendous and it would be great to see the planners in general anyway resource properly. I'm going to now bring in Miles Briggs with some questions. Thank you, thank you convener. Good morning. Thanks for joining us this morning. I wanted to ask some specific questions with regards to land supply. And to kick off with, do you think MPF4 as it stands will actually bring forward the future development sites we need to meet our housing 2040 target? I think that that will be down to the individual authorities and I think it's referenced earlier the approach in the housing policies is one where it leaves it to the local authorities to determine what they want to see brought forward. There's no prescription as such within the MPF. It's minimum numbers so if your authority is ambitious and being political again our authority is very much based on growth. We saw opportunities to add to our housing land supply working collaboratively with Homes for Scotland and other stakeholders so that opportunity is still there for authorities to adopt at a local level. The housing policy I don't think has seen fundamental changes from the previous situation, I think more clarifications than anything. I think there's definitely been a shift in terms of the importance and weight put on the allocation of land in the local development plans and again we're expecting to see more colour coming through with the final regs and guidance on that so I'd probably need to see that before I could fully answer your question. I think what we've said previously to that policy is that we want to see sort of clear and consistent approach to housing numbers and I think deriving them locally has been quite a resource challenge for a lot of local authorities so there might have been a variation across the country of how fully that was fulfilled and a lot of that does come down to resourcing. We definitely highlighted the role for the Scottish Government's digital planning task force here in supporting the evidence base that we need for that but we certainly wanted to see the shift more with housing land supply about the methods at which we assess the deliverability of sites and then the mechanisms to review housing land supply so we want to see the conversation move on over that way. Importantly, how can we deliver quality development to in the right amounts so as I say a little bit of colour there to come from the LDP regs and guidance and obviously a big question mark over resourcing the planning system as a whole as well and helping to implement this framework. Thank you for that. In terms of how this has been developed in England, they have a strategic housing land availability assessment looking towards a 15 year availability of land for housing. Now I don't see in terms of MPF4 what that looks like in my own area here in Edinburgh and it's based on brownfield sites, 90% of which have businesses currently on them who have no ideas where they're going to be moved to. Do you think it would have been useful to have that longer term 15 year at least vision of where homes might be built? I have no strong opinion that I think that the system we have with the 5, 7 year supply has worked successfully over preceding years. It might be often the challenge by other stakeholders but from a planning and service perspective I've got no problem with that. The focus for MPF4 is on climate change, it's on net zero so the encouragement of brownfield development is bringing that to the forefront, it's very welcome as far as I'm concerned, it's been a platform of planning over many years and seems to have lost its way in a personal opinion so bringing that back to the fore and reusing existing brownfield sites to me is a far better approach and a stronger approach to bring sustainable economic development. I probably go back to that previous point I made about the reviewing of housing land supply and as we move to a system of 10 year MPF4 and 10 year LDPs as well and how a 5 year housing land supply is reviewed within that and the delivery programme of an LDP I think is quite a critical consideration. Thank you and just finally you both mentioned the expectation of additional information within the guidance around this. I had specifically said I thought we needed some sort of mechanism within MPF4 to review this to make sure that that land is forthcoming. Do you think that that is available? You've obviously pointed towards what we as a committee maybe could start looking at but do you think that guidance should include potentially that? If we take it in the round as we've both said, the delay in issue in the guidance is of concern. The development programme pushes some into the medium term, not exactly clear what the medium term is but if you look at it we regional spatial strategies, open space assessments, play sufficiency assessments, LDPs in particular and all of those have been brought forward in the 2019 act and we don't have the guidance as yet on how we can deliver those. As I say, I think that the reviewing of housing land supply will be predominantly undertaken within the LDPs and having said that sort of back to that question about the delivery programme for the MPF4 and some of the metrics that housing statistics have been listed as one of the elements that we could look at. I think that there are parts of that that could get explored. I'm going to bring in Paul MacLennan with additional questions. It's been raised a few times about policy 27 and about out-town developments in terms of that and probably clarity from developers in that regard. I'm just wondering in terms of your interpretation of that and both of you in terms of that and do you see enough clarity in that regard for out-town developments and where the balance comes in on that. I think that we've heard representations from quite a number of bodies in that regard. It is one of what your thoughts were on that regard probably yourself, first of all. We strongly welcome that approach to reduce out-of-town development in the town centre first principle as we've seen over the last few years with the Covid and the pandemic. The town centres have been very severely hit, so re-addressing that to re-emphasise if you like the town centre first principle is welcome. I think the headline that was made was the banning drive-throughs. If you think of net zero and reducing carbon footprint drive-throughs strikes me as an area where we should be opposed and get people out of cars and into public transport into the town centres. That to me is welcome. Again, to a wee bit of ridicule of whether you could pick up your shopping at the supermarket. I think we all know what it means. We're looking at reducing the number of out-of-town drive-throughs and retail outlets. The media picked up on the banning drive-throughs. It's something that we said in response to the previous draft that we wanted to see a higher threshold in terms of where we would permit the drive-throughs or not. I think it's a limitation on drive-throughs unless they're specifically supported in the LDPs, so just maybe a slight nuance to that. I think this whole policy has been somewhat rationalised. I think that that's more user friendly, including the town centre living approach that we saw in the previous draft, but that's been incorporated here as well. I think that some amendments were made there in terms of trying not to direct residential development to ground floor shops, so we are supporting that town centre first approach. Is there enough flexibility in terms of the capacity for local situations? If an out-of-town might depend on what's the local situation within that, do you think that from a planning point of view, from a planner's point of view, there is that flexibility within the policy that's been indicated to you that would give you that? It's not one-size-fits all, obviously, in terms of each out-of-town development, but I just wondered what your thoughts were on. Does that still give you enough flexibility within the system or in regards to taking individual costs? I think that we said at the start that we welcome the climate challenge that we have and, through the policies, the net zero. If you take that approach, then that should inform how you lay out your LDP. I think that it states that, obviously, we are looking for these step changes and moving away from out-of-town and focused on the town centres, which we welcome. The policy has one change in it. It certainly strengthens in terms of its support of local neighbourhood shopping, and I think lining up with the 20-minute neighbourhood local living policy approach elsewhere in the framework, and that's something that we have support to. I apologise, convener, that I wasn't here before. Do you think that the revised draft MP4 will support or hinder the delivery of the level of renewable energy developments needed in Scotland to achieve net zero? I think that it's very supportive. It introduces, for the first time, a whole range of renewables that are welcome. One of the conflicts that we saw earlier was that there seems to be a policy against development within wildland areas, national scenic areas, but then the renewables policy says that these can be considered in any area. We want to protect, obviously, these wildland areas and national scenic areas. At the same time, we want to support renewables, but the fact that the policies introduced a whole range of them were not simply focused on wind energy now. We can be looking at a whole range of other renewables that are available to us. I understand that one of the policies that has had more substantive change from the previous iteration is picking up on Jim's point. There is now a more permissive wording regarding the delivery of onshore renewables in wildland areas. The intent behind that is to meet energy targets, and I think that the renewable industry would be broadly welcome those changes. However, just to be clear, any development on a wildland area would still be subject to impact assessments, appropriate mitigation, management measures and monitoring as well. That reflects the kind of change in the scale of development that we require to get to net zero. There still is protection for national scenic areas and national parks within that, but that is certainly a policy error that has seen quite a big shift. I would go back to resourcing again, particularly the resourcing of the reporters unit. There is a huge uptick in section 36 applications at the moment that we are going to inquiry. If we are cutting the funding for them as their workload is going up, I can see that being a big problem when we think about implementing the net zero agenda even with a more permissive policy framework in place. I was just going to say what in the wildland aspect as well, and I was just wondering obviously from the questions and the answers that Robbie gave. Do you think that the draft MP4 does address these concerns wholeheartedly? Do you think that we are taking into account wildlands and renewables and giving them the same sort of a footing? I will reference back to the point that I made earlier. I think with a clarity to those policies that could be brought out and we wouldn't find ourselves arguing over which policy is the stronger one. I know what I have in my mind but that might not be with the rest of my committee. The point of renewables is that the planning system is wide-ranging. Planning cannot deliver all of the renewables. If you just look at grid connections, and I am sure that the committee has considered that before, we could be granting planning consents for renewable projects. However, if the grid connections are not there, which is out with their control, then those cannot be delivered. That is just another example of where the planning system can only go so far to make those changes. I will come back to the resource point, particularly in planning authorities themselves. Onshore wind applications tend to be more significant major applications coming through, which require possibly more senior planners to get involved with them. There is a bit of a dearth of that in the industry at the moment in terms of 10 years in senior planners. There is definitely an upskilling there in terms of our existing planning workforce bringing them up to speed so that they can undertake this work. The capacity of internal expertise—for example, landscape officers—are a crucial part of the due diligence when it comes to the impact assessments, such as landscape and visual impact assessments, land capacity studies and what not. The massive area of consideration is the resourcing and the skills that are directly tied in with one another. The final point is just the pending shortage of planners within Scotland. You will be aware of the high-level group's consideration of the future planner project, which estimates some 700 planner shortfall over the next 10 years. Although we are working with the Scottish Government and academia to address that, it is something that we have to fly up with all the new duties that are coming forward to councils and having that level of skill to deliver the policies that we wish to see. I think that you really think that it's really important for us to just really hear. That would be welcome. Jim, I think you— I think that we touched on earlier the transitional arrangements. I mentioned earlier how colleagues are already finding DPAs asking for commentary on policies that haven't exactly been finalised as yet. A chief planner letter—hopefully the committee is familiar with the chief planner letter—would be welcome to give guidance to authorities on how we deal with those transitional arrangements until adoption. How material is the NPF policy in respect to a planning decision making? I have a planning committee meeting in January and I'm already asking the officers to consider the assessment against the NPF. It's just a future proof for me, but it would be better if we had some guidance and a chief planner letter might be the way forward. I've got two final points. I mean, sorry back to resourcing, but one thing we maybe took issue with was the business and regulatory impact assessment, which the kind of summary sort of distilled— Rhan along the lines that planning authorities would save—well, there would be a lot of potential savings from the local development plan preparation process now having these national planning policies. But actually drilling down into the table itself, I think we identified 14 different areas where there's new workloads coming online potentially for planning authorities and we actually felt that might have been a slight underestimate as well in terms of how that was worked through. So I'd just like to reiterate what we've asked for previously, which is a comprehensive skills and resourcing plan to be a part of the delivery programme or at least an exit oration. But my final point would be around the sort of corporate influence of this plan. We're going to have a full parliamentary debate on that. I think that's a great opportunity to put planning to the front of our consideration as a country and to really get MSPs on board about what this framework can mean from the whole country, but there are constituencies as well. Just pointing to the Irish example of their national marine framework. But when that was published, the entire cabinet there set out the relevance of the framework to their various portfolios and we really like that approach. So I'd like to see that come through in any report to Parliament is to really ensure that we get that buy in and we use this opportunity to do that. Also we need to do that in local government as well. I think chief planning officers and the statutory guidance that's to be prepared for that is a good opportunity and that's something we want to maybe see a bit more strongly in the next iteration of the delivery programme as well. Setting out that important link that they provide into the sort of corporate decision making part of local government. I'll stop there. Okay. I'm glad I asked if you had any more to say because there were very important points. I think that's quite interesting about the Irish national marine plan that the cabinet secretary had to say in the chamber I assume how their framework was going to affect their particular areas of work and certainly we have heard loud and clear around the requirements for resourcing and skills development in relationship to this. I just want to say I really appreciate you coming in this morning and it's clear that I see from Jim's copy of the national planning framework they are all with all of the little stickies in it that you have been drilling down deeply. Yes, I know right. These are the things that are going to shape Scotland over the next 10 years at such important work. Thank you so much for chairing your organisation's views with the committee this morning. I now spend the meeting for five minutes to allow for a change of witnesses. We'll now begin our second panel of witnesses this morning and on panel 2 we're joined by Elsa Rayburn, who's the chair of Community Land Scotland. Claire Simmons, who's the founder and chair at Planning Democracy and Bruce Wilson, who's the head of policy and advocacy at the Scottish Wildlife Trust and is appearing on behalf of Scottish Environment Link and they're joining us online. We're joined in the room by Liz Hamilton, who's the director of planning at Homes for Scotland and Mora Gwatson, who's the director of policy at Scottish Renewables. I welcome you all this morning to the session, maybe a long awaited for session. I'd like to begin with a broad overlook. I'd just like to hear your views on any of the key changes that are made to the revised MPF4. It's great to be here. Thank you for inviting Scottish Renewables to give evidence. Last time I sat before you and gave evidence on the MPF4 we were very unequivocal that the draft that was presented then would not help Scotland reach net zero and it would undermine our ability to deploy the amount of renewable energy we would need to hit our climate change targets. I'm now delighted to be able to sit in front of you and say there's been a remarkable turnaround in the document. I would very much like to commend the planning minister and his officials in the chief planners office. They have done a huge amount of work. They've obviously listened very carefully to the feedback they were given and to the expert input that was put into the process. It's our view now that the document that has presented to Parliament probably represents one of the most supportive planning regimes for renewables in the whole of Europe. I would like to be clear that it does not give a free pass to any development in any place. What we want as an industry is we want very much to maintain the integrity and the standards that we have here in Scotland. What we asked for was a set of very clear and ambitious tests that any development should have to pass in order to be able to gain consent and that's what we have. What we had asked for was clarity around those tests where they were unambiguous and again that is the place that we have arrived at. So I would commend the officials who have worked extremely hard on this, the document they have produced in terms of what it says around renewable energy is extremely good. I'm just going to say a little bit more about process because we've got some folks online and some people in the room. So if you want to come in, if you're online, for this question I'm going to ask all of you just because we want to get the foundational views. In other questions we'll try to direct them but also if you want to come in please put an R in the chat and I believe Clare you have put an R in the chat. Good morning everybody, thank you for inviting us again to give evidence. This is one of the most progressive planning strategies since devolution. It's saying things that really matter. It's not just about economy and growth but it says that our climate, nature and wellbeing matters as much. I think the document still needs to be clearer about what is necessary development, what development is important and needed because the focus on nature and climate implies that we've got to be a lot more frugal with our resources including land. It suggests that development does need to be limited. We welcome the clearer language as many people do and I like the layout and the clarity of the policy principles and the outcomes and the impacts and connections highlighted in each of the policy sections. One thing I did notice was that the planning policy 1, which was the plan-led approach to sustainable development, has been deleted. I don't think there's anything sinister about this because it's decided that perhaps it's implicit in the planning system. The planning system is generally assumed to be plan-led and that's what we would strongly support. However, there's now only one policy that contains a reference to a plan-led system and this is the housing policy. It's interesting that in the last two years there have been 115 appeals on refusals for housing development of over 10 houses. We've looked at a sample of those and it appears that around 45 per cent are successful in overturning the local decision. Importantly, most of those were on sites that were not allocated in the plan and roughly half of them were designated green belt or greenfield sites. The number and successive appeals suggest that we don't have a plan-led system but that decisions often undermine other planning policies that have now been given more prominence in the NPAF 4. We hope that the housing policy has been strengthened to avoid the problems that led to the high level of appeals because the test of the NPAF 4 will be whether or not the approach to housing is plan-led. We hope that it won't continue to be driven by the threat of appeals. There was also one small typo that I noticed on page 4, which talks about rather than compromise or trade-offs, and I think it's supposed to be on, but we would recommend that this paragraph is deleted anyway because it says, rather than compromise on trade-offs between environmental, social and economic objectives, that this is an integrated strategy to bring together cross-cutting priorities and achieve sustainable development. We think that this paragraph rather glibly denies the fact that there will be trade-offs, as the appeals have so readily suggested. It's almost ridiculous to assume that there won't be trade-offs and that an integrated strategy is not going to prevent that. There are a lot of conflicting policies. I think that looking at all the policies, there are at least 60 different judgments that a planning officer might be required to make, so I think that that paragraph could be remitted. Thank you, Claire. Bruce, do you want to come in? Thank you, convener. Yes, the Scottish Environment Link really wants to thank the committee for the work that they've done on this, and the officials and the ministerial team as well. We think that this has vastly improved. The layout is much, much clearer, and the equal weight that is given to climate and nature in policy 1 is really, really strongly welcomed. The previous panel were discussing the emphasis that was placed on the climate emergency in this document, and that that is great, strongly supported by the Scottish Environment Link and the Scottish Wildlife Trust. However, we do want to stress that it is equal weight on the climate and nature emergency, and that really does need to be taken account of when reading this NPF4. In terms of other things that we would like to bring out in this session, we would like to discuss slightly the use of will will not be supported. There are a few areas that we think we could tighten up the clarity on there. We would like to discuss policy 4, part G particularly, around the statements around wild land. I agree with the previous contributor that there is strong support for renewables here, but we need to make sure that that is not going to have an impact on biodiversity and nature. There is some suggested rewording that we have for that section. We have a specific question later on on that. Maybe if we have time at the end, if we have not addressed anything that folks still want to bring in, I will try to give us some time for that. Liz, you wanted to come in. Thank you committee for inviting me to come and speak on behalf of Homes for Scotland. Homes for Scotland would like to commend the committee for the work that is already undertaken on NPF4. The revised draft has improved in the original in terms of structure and readability of policies. That is quite clear to see. In fact, I think that this is the draft that we would like to have seen first. In terms of other positives, some of the policies now offer greater flexibility, which I think we will come on to talk about anyway in terms of local living, 20 minute neighbourhoods, which we discussed in the previous session. We recognise the importance of meeting the climate emergency and nature crisis head on through effective use of the planning system. However, alongside that, a balance has to be achieved to ensure that Scotland's housing needs are also central in the decision making process. With a shortfall on the number of new homes built since 2008, approaching 100,000, we remain disappointed that the housing crisis is still not specifically mentioned, particularly when it is within Scotland's control to fix. It is also worth reinforcing the contribution that new-built housing can have to lowering carbon emissions through sustainably located developments in the high performance of new homes. Picking up some of the language that is in the liveable places section of part 1, the national spatial strategy, we are very supportive of that. Some of the bits that jumped out to me where Scotland's population strategy reflects the need for planning to identify the amount of land required for future homes. Planning must also enable the delivery of good quality affordable homes by allocating enough land in the right locations to meet current and future needs and aspirations. That is all good stuff. It is also really positive to see the links now to the population strategy housing to 2040 and other wider policy documents. However, we still have significant concerns about the delivery and implementation of the policies with an MPF4 in order to adequately and responsibly address the housing crisis. What I come back to is the importance that everybody in Scotland has the right to access a home that is safe and warm, that meets their needs and that they can afford. I would like to outline the key concerns. I know that we will probably get an opportunity to cover them, but the key concerns that we have, again touching on the transitional guidance that will come up in conversation, I am sure, will touch on policies 16 and the workability of quality homes, how to maintain and assess that deliverable land pipeline will be absolutely critical. The Markler figures, I would like to touch on that as well in terms of how they have been approached in the Honda system, how it is indeed a demand assessment that sits behind that and then a bit on the delivery plan and resourcing as well, but it feels like that will come up in conversation anyway. Thank you, Liz, and if it doesn't, please make sure we hear what you want to say. Elsa, you wanted to come in. Thank you, convener, and thank you, committee, for the opportunity to comment today. From a Community Land Scotland perspective, very much welcome many of the changes that are in the revised draft. I think it's really positive. It's made a great contribution to balancing different interests. We've already talked about wild land and the need to balance the nature and climate crisis with the need for renewables and for small scale community led development, so I think the plan has done a really great job in balancing lots of those different interests. I think the explicit policy support for community wealth building, community ownership and community led development is really welcome, and I suspect it's probably the world's first national planning framework to specifically reference community wealth building, and that's very much to be commended. So I think the minister and his team have done a great job in bringing all of these elements together in what is a really difficult economic circumstances and with lots of competing interests. There are three specific areas of concern which hopefully will be able to pick up that we still have with the framework, and the first is around rural population and re-population, and I know Susan's point there about the housing crisis, which is extremely pressing in some rural areas, and hopefully we'll get the opportunity to talk about that later in the committee session around renewables and the missed opportunity around specific community wealth building references in new renewables development, and then finally what we're seeing in rural areas in particular around the natural capital driven land markets. There's no reference to some of those landscape scale changes that are happening as a result of those land market changes within the planning framework, but they're having a huge impact on local communities. So again, if you've got the opportunity to cover those today, that would be welcome. Thank you, convener. Thanks very much, Elsa. So that was kind of like the bigger picture. In talking with the minister, he's very, very firm about the idea that the national planning framework, the priority, and we see that in it now is climate and the biodiversity or nature emergency and those crises and how we can tackle them. In practical terms, what does the requirement for decision makers to give significant weight to the global climate and nature crises mean for development management and development planning across Scotland? I open that up to anyone who wants to pick that up, Claire. Hello. I think the question is, do these policies provide enough teeth to give planners the confidence to make bold decisions that will be upheld if an appeal comes along? How will planners and communities know that the reporter has got their backs on decisions that, for example, support biodiversity policies? What evidence will a reporter be looking for in terms of climate and biodiversity to support decisions that may perhaps limit development or prevent a development because it impacts negatively on climate and biodiversity? Given that all built development will generate climate impacts, what's missing and what we need to agree is how need is going to be defined. In order to decide what development is going to be restricted. I'd just like to point to a research paper in ecological economics, which explores the expansionist housing policies, primarily in England. They were modelling how much expansionist housing policies are compatible with national biodiversity and decarbonisation goals. Their model estimates that around 12,500 acres of farmland will be lost per year to urban development in the UK. That equates to the average loss of biodiversity of about 0.04 species per hectare or an average of 5.7 per cent loss in species richness in the areas being developed. With regard to carbon, even the most ambitious carbon reduction scenarios that they ran, including decarbonising new bills and existing stocks, still used 60 per cent of the cumulative carbon budget required to remain within the 1.5 degree C limit. In other words, expansionist housing policies use up huge amounts of the carbon budget and deplete biodiversity. My question is, if the NPF is built out and delivered, how much does the housing policy use up of the Scotland's carbon budget and how will it be assessed and when? Are local authorities required to determine the carbon budget or the biodiversity loss at the local development plan stage? Will it be up to local authorities to compare emissions on retrofitting using empty homes and the reuse of brownfield sites to compare them to new-build and greenfield sites? Do they have the capacity, knowledge and support to do that? How will our planning officers be equipped to make such judgments? In previous sessions, we have talked about employing more ecologists and climate specialists to support those planning officers. Perhaps that is more when we come to the delivery plan, but that is an important part of the process. I agree with everything that Clare's just said. One of the strongest changes that we have seen in the redraft is that there were a lot of sheds associated with biodiversity previously. That has been changed to more predominantly will not be supported. That is a big, useful change. We do think that there are a couple of places that could be tightened up and improved and made much clearer. We have a few suggestions in that regard. We can submit them to the committee if that is useful or I can go through them now. It just depends on whether I went through other changes as well, convener, because there are a few changes that we can suggest that we just think would clear up inconsistencies there. If a decision is taken forward, we think that it will be better to say that it will not be supported unless it contributes. Rather than saying that joint proposals will contribute, we just think that that is a more realistic expectation of local authorities and they will be able to have more control over that. We can submit that exact wording change to the committee, but we think that emphasis rather than shoot around most biodiversity elements to will is very important. We firmly believe that, when it is interesting that Clare mentioned environmental economics, we cannot manage what we do not measure. There is not enough emphasis on measuring our impact on biodiversity. There are lots of great wording around protecting, enhancing and reversing biodiversity loss, but in order to do that, we need to know the impact that we have created in order to have positive effects for biodiversity. I am saying that we have no idea of knowing if we have positive effects for biodiversity unless we do appropriate measurements beforehand. The previous panel that we talked about having budget associated with that costs money, but the benefits are massive and local authorities need to be resourced to do that properly. There is also the point that Clare was raising there around knowledge and expertise in order to implement a lot of the excellent changes here. We do need to have appropriate levels of knowledge and understanding within applying authorities. Let's run through the questions that colleagues have, and hopefully you can bring in those policy specifics at that time. If we haven't, we would welcome them in writing if we run out of time. I think that we have a lot to say on this panel. I also wanted to come in and then Morag. Thank you, convener. I think it's a really interesting question and the sorts of decisions that shouldn't be taken at site development, planning decisions or even at LDP level, but probably more at a national level because we do need to balance these issues. As I previously mentioned, that's been done quite well in the wildland areas where renewables and small scale community-led development will be permitted in those areas. I think there is a balance. We've seen two specific examples, the housing at Steffan and the space hub at Sutherland where there were really critical local developments for communities and the local regional economy, but they were both hugely delayed by not having really clear specific guidance around some of these issues. So I think clearer guidance, clearer national guidance for local planners to enable that balanced decision making, and as has already been referred, more skills within the local authority to support applicants. On that, clearer guidance will be really important to ensure that some of these critical local development projects that support rural economies are not held up for a really long periods of time, while some of these issues are explored. Just picking up on some of the points that the other people have made in this session, I think it's important to note that we shouldn't expect the MPF4 to do everything. It is the national planning framework, and as people have already alluded to, it does need supporting guidance to sit alongside it, particularly with regard to biodiversity and climate. This is something that we have been working with the Government and its officials on for quite some time. Particularly with regard to biodiversity, through the environmental impact assessment process we have a very good and well regarded method for assessing environmental impact and our do no harm model. Now that we are moving into that space of positive enhancement, we don't have a metric for how we evidence that that is happening and that is a shortcoming in our planning. England has brought forward its net benefits for biodiversity metric. However, we have looked at it closely and it doesn't apply to Scotland because many of Scotland's biomes are very different from what you have in England, so the science does not translate across. That is something that we would like to see come forward, because we should be able to scientifically evidence that net benefits for biodiversity are happening. With regard to renewables, we already have a carbon calculator, albeit that it is slightly out of date and needs updating, where for every renewables development that we bring forward we must evidence that it is a net benefit for our climate, that the amount of carbon that it saves is greater than the embodied carbon in its construction and its development. Excuse me, I am halfway through a sneeze and trying to give evidence at the same time, and I'm stumbling. Sorry, let's try again and not sneeze down a microphone, which would not be a very nice thing. What we have been looking at with the climate emergency response group and through the green book process is could such a carbon calculator be applied more generally across developments, but given the varied nature of developments that is not an easy question to answer. In terms of the original question about how might you operationalise our ambitions around climate and biodiversity, those metrics and those tests would be a very big step forward. Just to touch on something that Elsa said that I feel is very important before we move on in the conversation around renewables and community wealth building not being mentioned in the MPF4. Again, I would emphasise that there is guidance that exists outside of the MPF4 around the development of renewables and the need for community ownership and community benefit within that. That actually sits in separate guidance from the national planning framework 4, but in any development proposal you would be expected to bring that forward in line with the good practice guidance agreed between industry and government. The target with government at the moment is that half of all new developments should have an offer of shared community ownership within them, and it is sitting around about 60 per cent of all things brought forward. Just to make it clear that, while things are not in the MPF4, it does not mean that they have not been taken into account. Morrig, when you say that the half should have shared community ownership. Can you say a little bit more about what that would be then? Certainly. The model that we had, which was established when we started doing commercial scale wind farms particularly in Scotland, was that 5,000 pounds per megawatt of installed capacity would be given in community benefit payments. Given that wind farms are getting bigger and so on, a lot of communities wanted to be able to actually invest in the wind farm itself instead of just receiving the voluntary contribution. That is what community shared ownership is, the community by essentially a share of the development and then the income that comes from that, they get a share of those profits. So it is a more complicated mechanism for a community to engage in rather than community benefit, which is just a voluntary payment, but community energy Scotland do a lot of work around that, supporting communities to engage in those opportunities. That is why both things exist at the moment. You would do one or the other, not generally both, but it is about giving communities the opportunity to fully benefit from developments that are happening in their community. I am just picking up on the general point around that. Npf4 is to be clear. It is not saying that the climate emergency and nature crisis policies are there to restrict developments needed. They are to be given significant weight in decision making. Housing is a need that exists and still has to be met and Npf4 is clear on that. I think that we need to be careful about our thought process around where new housing is allocated in terms of brownfield versus greenfield. It is not necessarily one's good and one's bad. It is much more nuanced than that. For example, in fact Npf4, there is a statement in there, a sentence in policy 9, which is the brownfield and vacant derelict land policy, which refers to the fact that it needs to be taken into account that a lot of the brownfield sites will have urban greening, for example, so they will actually be quite biodiverse. On the flip side, a lot of greenfield sites will be much less biodiverse. I think that we all need to be careful about how we plan our future housing. We are not saying that we are restricting where that goes, because we think about a lot of local authorities in Scotland. A lot of them do not have a lot of brownfield land left or vacant derelict land that can be delivered. Clearly deliverability is a key strand, particularly in the housing policy of Npf4. We need to think about the climate and nature crisis broadly in a significant way, but we need to think about where we are locating our homes. What does sustainable mean, if a home is closer to where you work, or if a home is closer to where your family network is for support to bring up a family, for example? Yes, significant ways to be applied, but it certainly does not mean to me that it is to restrict development in any way that is the development that is needed. One of the things that I have been wondering about housing is that we have this model where we have a individual or maybe semi-detached housing, I think about models on the edge of Edinburgh or the edge of the town where I live. I wonder if there is consideration in the housing sector that maybe we need to be having different models where we are going for, even in rural or more rural areas, terrorist housing. We are not using up so much land. It seems to me that, since I have been in Parliament, there is such a challenge around what we put where in the land that we have. There is now this call for our food possibly to be grown more locally, certainly not exporting so much and growing vegetables and things like that. It seems to me that we are all having to give a bit, and I wonder if Homes for Scotland members are considering looking at different styles of housing that they might make available. I think that it has already been looked at in terms of developers already looking at the efficient use of land. They do have a broad range of products, and there are density policies out there already. It is not new, and certainly to meet the needs, there is a broad range of products. It is being looked at, and it will form part of the story going forward for new housing. I think that we need to be careful around some of the thought processes. What I am trying to say is that, in a brownfield site, it can be harder to meet. Some of the policies can come back to some of the conflicts, particularly if you are thinking about going back to local living, 20-minute neighbourhoods, and you are looking to introduce new facilities. For example, schools might be harder to meet. Where is that school going to go? A sort of urban brownfield site versus a greenfield site that can contribute towards new schools, open spaces and retail. I think that we need to take a broader view. To answer your question, I apologise, but it is something that the industry is already looking at in terms of efficient use of land. It is in the industry's interest to do that anyway. Bruce, I know that you wanted to come back in, but in the interests of time, I might be saying that a lot today, this morning, I would like to move on and see if you can tuck whatever you wanted to bring in into another response. We are going to move on to questions from Mark Griffin, who is joining us online. Mark, if you can ask all your questions at the same time, that would be great. There has been a lot of focus and attention by Government and parliaments on economic growth, which is understandable, given the turmoil recently. I just wanted to ask witnesses if you think that there is enough emphasis on economic growth within the draft planning framework. Are you confident that there is compatibility within the draft planning framework? Will that enable and drive economic growth in Scotland? I am happy to pick up on that question, Mark. One of the things that we have identified in the renewable energy industry is that we are a driver of economic activity and our provision of a secure and affordable energy source underpins the rest of the economic activity that takes place within our country. If we are to stay on track to hit our net zero targets in between now and 2030, we will need to deliver about 12 gigawatts of onshore wind. That, we estimate, will generate around 17,000 to 18,000 jobs across Scotland and put about 28 billion GVA into our economy. That is very significant. At the same time, although it is not included in the NPF4, we will be doing offshore wind development. What we have seen through Scotland leasing round for the seabed represents somewhere in the region of £28 billion worth of investment coming into our country. All that electricity that is generated in the North Sea comes onshore. The grid reinforcement that we need to transport electricity to where it is needed is another huge source of economic activity. Between our two grid operators in Scotland over the next five years, they will spend somewhere in the region of £10 billion on grid reinforcement. That is before we get into the decarbonisation of heat and the need for storage to be added to our grid to balance out intermittent renewables. The economic opportunities here are huge. Although that may not come through specifically in the NPF4, what the NPF4 can unlock in terms of renewables and what it can bring into our economy is very significant. The view has not changed greatly from the first draft of the NPF4. It places greater weight and emphasis on the environmental sustainability of Scotland. Not necessarily on the balanced—it is probably the right terminology—social and economic benefits that the NPF4 can bring. In mirroring Morag's comments on the renewables industry, in terms of yes, it is talking about housing that makes the social needs of Scotland equally economic benefits that come from new house building, from indirect and indirect employment, has to be recognised as well. As the balance being struck is the question, I still remain to be convinced as the answer. Some of that will come back to how this document is implemented and whether it can keep up pace with the need for new homes across the country. Follow-up guidance will be very important, particularly around LDPs and how developments will come forward and how that will be tracked. I will come back to the metrics. There is still a lot of work to be done around the social and economic benefits that should come from the NPF4. I understand the pressure on MSPs around the growth and need to establish—to make sure that everybody is in good quality of life and so on. There must be a lot of pressure on MSPs at the moment, but I also do not want to lose sight of what this document is trying to achieve. Last week, 100 organisations, charities and economists from the movement for a wellbeing economy signed a letter urging Nicola Sturgeon to transform the national performance framework into a wellbeing framework in order to strengthen its power and reach. In their letter, they said that a narrow focus on GDP and growth perpetuates the same logic that has delivered decades of poverty, inequality and environmental degradation. I know that the central purpose of the planning system has, up until now, been framed around the pursuit of sustainable economic growth. In practice, that has meant largely facilitating private sector development because governments see that as key to economic growth. This means that development itself has become more or less synonymous with the public interest. The introduction of the wellbeing economy wording in the NPF is hopeful, if only it weren't in the same document that also seeks to promote growth and GDP. Planning priorities are still there to facilitate development and minimise constraints on market forces. It's very light touch in terms of regulation. There's still focus on efficiency and speed of processing planning applications to satisfy what appears to us to be the number one customer, which is the applicant, not communities. If that really leads us to a more equal planet-friendly planning system, we've just got to stop believing that growth and development can be limitless. We have to start being efficient with our land and not supporting policies that allocate overly generous amounts of land for housing and that lock us into unsustainable futures. Replacing our addiction to growth means developing an entirely different set of criteria that will be needed to assess what development is considered in the public interest. I think that we've got a real duty to the next generation to many young people who are terrified of the future. We've got a moral imperative to just get over our addiction to growth. Growth is irrelevant, no planet. I think the framework has made huge positive steps in terms of supporting local economic development, particularly community-led economic development, which is really important for the sustainability of local communities. The big issue that Liz has already picked up on is around housing. I've mentioned the numbers of jobs that we're hoping to create from the renewables developments that are coming online over the next 10 years, but we've got nowhere to house these people. We're not going to see the economic benefits of those jobs in Scotland unless we've got places for people to live, so I think it's really important that we go back and look at the framework and check that it's doing all it can in terms of supporting housing developments in the right areas to ensure that we maximise and optimise the benefits from Scotland Wind and Intog and the onshore renewables that Morax has already mentioned. That will be the barrier to economic growth, I think. The panel will probably expect me to come on and say that there is no economic growth on a dead planet, and that is certainly true, but we need to be looking at the economic opportunity in doing this right with regards to climate and nature. We've got a chance to create a completely green-collar economy here, and people think about that often in terms of new jobs in peatland creation or forestry in woodland. Absolutely, those are massively important jobs, often occurring in rural areas in Scotland. However, there are also jobs for green financiers, green engineers, ecological clerks of work—a whole new industry—and we have to be affecting that paradigm shift if we want to meet nature and climate emergency head-on. I would really encourage the committee and planners to not view that as a binary in its nature and climate. If we are building new housing developments, those have to be permeable to nature. They have to manage water properly. They have to be as carbon efficient as they possibly can be. It is not just the case that housing should have a negative impact on the environment. We have to maximise the benefits of that new development, have carbon and biodiversity in-setting on that site so that we are replacing habitat if it is lost, and we are making those permeable for nature. Absolutely crucial to that is the guidance documents that are going to come out around that. Things like the nature networks. We have to be using those as strategic tools to highlight where nature-based solutions can go in the landscape. The nature network can be a tool that involves local communities and it can help plan, it can help get around some of the issues that Ailsa was highlighting around natural capital investments in the landscape. We need to involve people in those discussions and decisions, and we need to use a strategic tool like the nature network opportunity maps to get that right. I really do not think that we can afford to view that as an economy, or it needs to be everything, balance sustainably, but the environment completely underpins everything that we do in planning arena, the economic arena, the social arena, everything. Thanks for that, Bruce Mark. I think that you have another question. Thanks for those answers. I have a question that I probably direct towards Liz. You raised concerns about the Matlar figures in the earlier draft, I think that you flagged issues again on those figures on the Honda process that informs that. Are you able to outline your concerns to the committee on what changes still need to be made to give an effective housing land supply? The Matlar figures are critical. Yes, they are their minimums. We understand that. We see now that there is an expectation for LDPs to exceed their Matlar, which is good to see. I cannot see where that carrot or stick approach is to make sure that is done or even meet that minimum figure. The first thing that I would touch on in the Matlar figures is the way that they were calculated by local authorities across the country. It is quite an inconsistent approach. That was for various reasons. Some had time or inclination to do more work to examine the figures. To use the Honda as a baseline is dependent on secondary data and on previous population trends to predict the future. However, some local authorities either had the time or were already in the process of looking at their new Honda or had the resource to go out and do some primary research. I go out and identify beyond the baseline minimum, which is in the Honda process. When the local authorities did that, you look at some of the authorities in the Dundee City region, some in Ayrshire. The figures came up considerably. There were also some that did not have time or perhaps did not have resource to undertake more work. For me, the big issue when I look at the Matlar figures, because they are so important to this draft, so critical to housing delivery for the next 10 years, is the approach that needed to be more consistent. For me, there was a lost opportunity, because I can see now with the revised draft that there was an opportunity to change those. You can see some authorities, because they have had a new Honda come through in the time between the first draft and this draft. They have been amended, so it would have been good if local authorities had guidance that you have now got more time to go out and look at your figures. That is the first concern with how those figures are coming about. Of course, there are minimums, but they are now out in the public domain. The other central issue that we have, and this has been raised at committee previously, is the Honda toolkit itself, in the fact that it drastically underestimates the actual housing demand. The need is based on a very restricted view of what that need is, so a household must be overcrowded and concealed to be counted. What it does not include for large swathes of our population, I will cite a few examples now. Perhaps a family living in a home without enough bedroom space, perhaps single people still living at home with their parents, older people in homes that are no longer fit to meet their needs, perhaps too sorry housing, perhaps. They are looking to downsize the properties too big, but they know where to go and they want to stay in the local area. It does not touch on existing housing stock, so I think that it is not fit for purpose. It does set a baseline, and it is clear that local authorities can go above that baseline, but for me the baseline is set far too long. It also uses previous population trends to predict the future, which is a dangerous game to play because we have had an undersupply for the last 10 years, even post recession. Those figures for those previous trends are coming out of that post 2008 period. It is clearly not right that they are then used to predict growth in areas for growth. For me, one of the key points that MPF4 could still do is to look to have a fundamental review to the Honda toolkit. What I was going to propose is that, if any members are actually the committee as a whole for Scotland, I would be happy to facilitate a workshop seminar to discuss where we see the shortcomings and how we address that. We could pull in some experts. There has been a lot of research done on it. I hope that for Scotland I have a tool that local authorities could use. I think that the minimums, as they stand, are less than the previous 10-year completions, particularly in the west. Some of the figures are drastically low, where it is identified in the spatial section that the population is set to decline. We really need to look at the Honda toolkit. I understand that it is up for review. When I looked at the committee report from March from the first draft, it said that the committee asked the Scottish Government to review the Honda at the earliest opportunity to develop a tool that is up-to-date and fit for all areas of Scotland. To carry on that message and offer the Home for Scotland could facilitate that as an on-going workstream. I think that the committee is going to be looking at this later in 2023. I think that Claire Simmons would like to come in. If I can ask everyone to start keeping their answers a bit more succinct, that would be really helpful, because we've still got quite a few questions to get through. I just want to be clear that our aim is not to prevent housing development, but what we want is more emphasis on housing need and being efficient with the amount of land that we use. The approach has been on providing enough land to allow developers a surplus so that they can pick and choose what sites they wish to develop. Our concern is that the amount of land allocated in the Matla is too generous and undermines the effectiveness of the plan and more progressive policies on climate and biodiversity. One of the key things—we can send you some more written evidence on this—is that the high Matla figures mean that local authorities have to allocate more land for housing than is really needed. There's a lot of in-built flexibility. It's already got 20 to 35 per cent in-built flexibility. We think that a realistic Matla could be something more like 1,117 units, not the 202. There's been a huge uplift of about 78 per cent. This comes from a mixture of things, but it's about the fact that there's sort of ignoring the projected population falls, but there's always uplifts and quite ambitious projections on population increases that don't necessarily take into account the latest census figures. Is the Matla going to be reassessed according to the latest census figures that might take into account things like Brexit and the cost of living and so on? We would ask that new population data from the latest census will be adopted into the Matla figures. I'll send more information about that to the committee, because I understand that we're representing quite a different view, but we strongly feel that the Matla is overly generous. I'm now going to move on to questions from Mourine McNair. I'm keen to continue with the same-line equations that I used in the previous panel. I'd like to hear from Liz first and then anyone else who would like to come in after that. Liz, are you satisfied that the terms of such as community wealth building in 20-minute neighbourhoods are sufficiently well-defined and understood to provide our best basis for plan decision making? You touched slightly on the 20-minute neighbourhood earlier, but you might want to expand further. I think that there has been improvements in the draft for both of them. Community wealth building is something that Homes for Scotland has been discussing with local authorities specifically, because we can see it coming. We saw it in the first draft and I suppose what we've been doing is trying to get our own heads around what does it mean. In fairness, local authorities are probably doing that as well. Jim touched on that earlier. North Ayrshire was the first to implement a strategy. In short, the new revised NPF for as much more detail as to what it means. I think that there was a bit of a confusion over community benefits versus community wealth building. Community wealth building seems to be more around local supply chains, local employment, keeping wealth locally. I think that our understanding has improved as an industry, but we've still got a bit to go. Local authorities do as well. I'll just say exactly what that will mean and what is expected of us when we submit an application that has to take a license of community wealth building. I'm not sure that the guidance is quite there yet. It's quite a new policy movement, but it's much better in the new draft, but there's still more learning to be done around it. I'm just touching quickly on local living 20-minute neighbourhoods. I am happy that the new policy seems to provide more flexibility, particularly around recognising the difference in context. It was touched on in the previous session that 20 minutes, let's not get too tired up on the number. That means different things in different places, rural, suburban, urban. I think that there's a bit more flexibility there and that the proof will be in the pudding as to how it's implemented. That might be something that we keep an eye on going forward in terms of a metric. For me, it's sustainable planning, which isn't a new concept. We've just given it a slightly different name. Thank you. Anyone else who wants to come in on that? Elsa wants to come in and then Claire briefly, and then we'll see who else wants to come in. Elsa. Thank you, convener, very quickly. I think community benefits is a term that's well understood, but community wealth building probably less so. The framework would benefit from a clearer articulation of what that is. Liz has just outlined some of those elements about keeping wealth locally through jobs, supply chains, ownership, local ownership of assets, et cetera. That's particularly for the private sector and developers, who I think are catching up with a policy that is quite well embedded now within national and local government. Thank you. I just wanted to mention that the policy is being made on the requirement for a statement of community benefit. At the moment, there's no requirement for community input in that. It's interesting how the house builders are equipped to know what is best for each community in Scotland. Is there any disbenefit for balance? I think that this is more stuff to be done, more statements to be written and, to be honest, it just allows a bit more opportunity for more propaganda on behalf of the view of the authority on me. I'd rather say that there was significant community input into those statements. Thanks, Clare. Morag, do you want to come in? We, on behalf of Scottish Renewables, have been sitting on the groups that are looking at the community wealth building bill and how that happens and looking about clarifying those definitions. I would agree with Liz that we've certainly come a long way in the MPF4 document about making it clearer what those needs are, but I'll go back to my earlier point that we can't expect the MPF4 to do anything and I would expect it to be fully supported by guidance coming through elsewhere. It is absolutely unequivocal what it means. We have been putting forward the example from Onshore Wind, where we have an obligation to consult with communities as part of our development process and looking at what can be learned from that to feed into that community wealth building process. There are numerous references to the infrastructure-first approach in the revised MPF4. Has it been delivered in practice? If not, what needs to change? I'm keen to hear from others on their view on that and previous witnesses have mentioned about the resource implications. Sorry, pop it back to yourself. I would reiterate what we have said previously. It is a laudable policy. Infrastructure-first on paper is the way it should be done. The concern is still that when I read the new document and the new policy, it has not changed much. I am not saying that, as we mentioned in the capital investment plan, I am not saying the guidance on regional spatial strategies because the infrastructure does span local authorities. The concern is that it is not in there to be a blocker to development, but if it is not planned right, then it could be. The intent of the policy is a good one, but there needs to be more work done, particularly in the development programme as to how it all comes together, including statutory bodies. How do local authorities work with statutory bodies? How do we, particularly for housing, if there is that pipeline so that we can see ahead for the next 10, 15 years? How is that incommunicated to other bodies to make sure that infrastructure can come through on time in that pace? The policy is a good one, but there needs to be a lot more behind it to make it happen, to get it delivered. Thank you. Anyone else? Bruce wants to come in online. Thanks. I'll just keep it very brief. We were slightly confused about the wording here. It's policy 18 on infrastructure first. It sets out the test of planning obligations that currently sit within a circular. The circular that is quoted is a shortened version, so it's slightly misquoted. We're therefore a little bit confused about what has more precedence here, the circular or the NPF-4, so I think that's just a wording that needs tightened up slightly within the document. Thank you for those comments. Do you want to come in on this? My points were very similar to Liz's. Great. Thanks. Is there anyone else online? No. Okay. Great. Thanks, Marie. I'm now going to move on to a question from Annie Wells, who's joining us online. Good morning, convener again. Good morning, panel. It's a very similar question to ask the last panel. Every local place plan will have to have regard to NPF-4. In looking at the draft document, how confident are you that community bodies will be able to do so? As we heard from the last panel, I asked them what support might be required to assist communities, and they said that additional resource would be a requirement with plans taken up to £10,000 per plan. I just wonder if there's some sort of a feedback or an agreement or acknowledgement or anything different if you would like to answer any of those questions. Okay. We've got Clare, Ailsa and Bruce online. They're quick on the buzzer there. Clare. Thanks, Annie. Great to have the local place plans in place, but I guess we're rather more concerned about whether local development plans will be able to have regard for the local place plans, to be honest. One of our concerns around the LPPs is that if local development plans allocate large tracts of land to say housing and house builders are busy buying up land and negotiating options on land with local landowners, we're wondering what land is going to be left for community ambitions. With a lack of information on options, how a local community is supposed to know what land is earmarked for housing. We support the idea of a register for the options. It's not clear how much house builders own, but we haven't done the calculations. If England has anything to go by, most of the land around major cities and towns is already owned or held under option. We've got anecdotal evidence from farmers in Scottish urban edge semi-rule locations that most of them have optioned their land already. How are communities supposed to deliver their own ambitions if they don't know what that land is being already proposed for? Local place plans are a great opportunity for local people to get much more engaged with the planning process in a way that they perhaps don't with local development plans. They need resourcing. They are intensive in terms of both planning officer time, which we're obviously thinking about here, but they're also extremely resourcing in local volunteer time, and we shouldn't ignore that when we're thinking about the development of local place plans and how we help resource that. There have been occasions where there's not been that many local place plans yet, but there have been occasions where they've been ignored in planning decisions. We need to ensure that those local place plans are given their due weight in the new local development plans. Of course, they can also be aligned to wider community plans in terms of developments that communities want to see brought forward. They're a really useful part of the process, but they need to be strengthened both in terms of resourcing and also the value they're giving in the planning application process. My points are very similar to Claren Ailsa's. I might just add that the long-awaited guidance around nature networks will also be very helpful in this process as well. It helps inform local groups about what nature can happen, where, within their doorsteps, it gives them a tool to get involved in the climate and nature emergency, which can often feel quite a removed conversation. That applies equally to urban and rural as well, so I'd like to agree with those points that were made previously and add that in. Local place plans are a big opportunity for communities to proactively plan the settlements and to reach out to developers who may have an allocation in a local plan to speak on a proactive basis about what that new development can bring to an area. I think that what we need to be careful of is that they are reflective of that community as a whole. How do we reach out to the people who currently do not feel engaged in the planning system, or know as an opportunity to engage, and then make sure that, across settlements in towns and villages, there will be some communities more geared up for this than others? How do we approach that on a consistent and fair basis? I see that there has been an opportunity, as a development industry, to engage with those. I see them as a good proactive tool for communities to use. Most of my points would have reiterated what has already been said. In the interest of time, I'll leave it there. We're going to move on to questions from Paul MacLennan. A couple of things I think for me. One was around the delivery programme. I wonder if you had any views on that, obviously, with the companies of the NPF4. The second part of the question was really talking about, and I think McKinney touched on it. Some committee members have talked about it as well as about one of the key things the committee were keen to look at was in terms of monitoring the implementation. And looking at indicators going ahead to make sure that there was a live document. I'm just wondering on the delivery programme and on the indicators what you'd like to see, and I'll probably come to yourself, Liz, then Morag, then kind of open it up to the panel behind that. Liz, you're first of all. Thanks Paul. The delivery plan at the moment, it is the first iteration that we've seen of it, but there wasn't a delivery plan with original draft. For me it still lacks quite a bit detail on how the financial and practical interventions to deliver on brownfield and vacant air like land, that's still missing. It's also in the details at the back all of the guidance documents that still need to be published to back up some of the policies. For example, the LDAP regs and guidance, which will be critical to understanding how the housing pipeline will work, housing land audit guidance, which again will be critical in determining that deliverable 10, 10 plus pipeline. Planning and climate change guidance is still to come, which again will significantly weight on the climate emergencies. For me it's a start, but it very much needs to be tracked. Coming on to your second question about metrics, that was my first point. I think that in the short term we should be looking to the delivery programme and saying what documents are still to come to make sure that NPF 4 is delivered and implemented with policy intent. It is to be reviewed in the first six months and then annually thereafter. I think that that needs to be the basis really for metrics. In terms of other metrics, quite broadly speaking, in the short term we absolutely need to keep an eye on planning applications, planning decisions. We have not touched on it yet in this session, but there is a lack of transitional guidance that has come with NPF 4. I think that there was a reasonable expectation from our own industry that that would come alongside the document, particularly with the amount of applications already in the system awaiting determination. With local authorities and with the DPAA, in the short term we absolutely need to track decision times. In the longer term it needs to track housing delivery, housing numbers and in-time matlars will become critical. It should be tracking how the new LDPs are progressing because NPF 4s are now adopted early next year. The new LDPs are following on to that and the first ones will not be adopted until 2027. It is now critical that, although the system has been paused for quite a long time, the LDPs are coming forward. As we know, that will cause some resource constraints, particularly within the reporter's unit, as has already been mentioned. I think that there are a few thoughts. I probably have more. In terms of picking up one of the positive things about the delivery programme, the planning infrastructure and place advisory group is in place. We would very much wish to be involved with that. For me, it is a start, a delivery programme, but it needs to have a focus now to make sure that it is implemented. You mentioned the transition arrangements and I think that that was raised in the first panel. That is going to be coming through and through. The evidence would have taken a thing that someone obviously needs to look at as a committee. More accurately, from your point of view, just to say the same question again. I would completely agree with Liz that the new LDPs are coming forward. I can understand that the NPF4 has changed significantly between drafts and now the delivery plan has to do a bit of running to catch up. It is heading in the right direction, but it is not as developed as we would want to see. Again, I would reiterate Liz's point about the speed of implementation here. In terms of the monitoring and what to be monitored going forward, the climate change committee obviously provides independent advice to the system. It has administrations across the UK on what is needed to meet net zero. As a framework that is supposed to enable the meeting of net zero, we would definitely want to see the NPF4 monitored against that. Again, we would expect to see biodiversity targets coming through the Parliament in the near future and to be measured against that. A couple of things to pick up on that have come up in conversation already, but I think that that is going to be going forward. One is not that would be a very key place for us from a renewables perspective to want to see monitored. The first one is around wild land. As it has been alluded to, there has been a change of policy around that. Just to be clear what that means in practice, it does say that you can now develop commercial wind farms and renewables in wild land. However, there are some big caveats to that. 49 per cent of wild land sits within national parks or national scenic areas, so it could never be developed for renewables. Once you include everything that has a designation on it, for example, a site of special scientific interest or something like that, or that is a loch or a river, obviously not suitable for renewables, that, once you take all of that out, you are only left with about a third of the wild land in Scotland. Then you have to get into, well, is the wind regime sufficient? Is there a great connection? The amount becomes smaller and smaller. It is not a case that simply now all wild land can be considered as a site. It simply says that around a third of it is now a possibility that could be explored, but we do need to make sure that that is actually coming through in policy. There is one other thing that is a deep concern of ours around how the NPF-4 has been written that we will need to be monitored very closely, because we have identified a key conflict in the policies. In policy 11, it identifies very clearly the need for grid enforcement to our electricity grid to be able to meet net zero. I should make it clear to the committee how grid works is a very unique thing in planning. In Scotland, there are two grid operators. There are SSE networks in the north and there are Scottish power energy networks in the south. They are natural monopolies, so they are regulated very closely by Ofgem, and what they can and cannot build is regulated very closely. They have to operate under two parameters. One, they must provide connections to people to the grid, but it must be at lowest cost to consumer and it must maintain the stability and integrity of our electricity system. There is what is called the pathway to 2030, which is where they have done a very clear plan on what grid connections are going to be needed as we go forward towards 2030. SSEN transmission networks have highlighted that the majority of ancient woodland in Scotland sits within their area and they have done a very detailed map of the grid reinforcements that they are going to need to do and they cannot find a way where they can do it without it impinging in some places on ancient woodland. Currently, we have the policy in MPF4 policy 6. Clause B development proposals will not be supported where they will. Part 1, resulting in any loss of ancient woodlands, veteran trees or adverse impacts on their ecological condition. We absolutely support that policy, but we are going to hit up against this conflict. I should make it very clear that, as an organisation, SSEN transmission networks have a biodiversity net gain strategy. As an organisation, they have committed that every project that they do will result in a gain for biodiversity. An example of where this kind of conflict has come up in the past is in Argyll. I need to look up the specific name of the grid reinforcement because there are many. Apologies. It was the grid reinforcement that they did around the west coast, where they worked with the Argyll Coast and Countryside Trust. What they were looking at was a grid reinforcement that ran from Inverary to Crusag, that impacted on Scotland's Atlantic Rainforest, which is a very precious resource. They could not have an impact there, so what they did is that they paid for a woodland officer, they paid for outdoor learning opportunities, they paid for the use of local supply chain, health and wellbeing improvements and they did mitigation planting as well. The area of woodland was expanded beyond the impact that it would have had. That is something that we are going to have to monitor very closely because, as an industry, we are absolutely committed to that biodiversity target and we are absolutely committed to the preservation of ancient woodland, but enable people to be able to access electricity. At some points, those grid reinforcements are going to come in contact with that. That is something that we would want the committee to pay very close attention to, as if we have accidentally created an undermining of one policy by the other. I will stop there. That was something that I was going to erase, so thank you for bringing that up. We are discussing delivery plans and monitoring, but we went into specifically the ancient woodland bit. Bruce has indicated that he wanted to come in anyway, so I will bring him in now so that he can speak to that point but also pick up Paul's questions around the delivery plan and monitoring. I am frantically writing down questions to address here, so I will try to address a lot more. We agree that there is a slight concern over the wording and what takes precedence. Biodiversity net gain cannot really apply in those situations because it is completely irreplaceable habitat. Nature is not fungible. You cannot necessarily just take one bit of nature and replace it elsewhere. We need to think about that. It comes back to my point about metrics as well. We need to make sure that we have accurate metrics to work out that if we have a situation where it is completely unavoidable, that we are replacing with significant net gain. That is the only thing that would take us to the spirit of the NPF and its commitment to addressing nature and climate crisis. I hope that that addresses that point. Within the delivery plans itself, there is the introduction of the new planning infrastructure and place advisory group. It is really important that we have appropriate levels of environmental expertise on that group. It can be very easy to overlook those things within expert groups. Mark was talking about economic benefits. We will have to upskill people with new skills to tackle the nature and climate crisis. It is important that that group has appropriate expertise on it. There is a really important omission that we have spotted as well here. Page 13 of the delivery plan references documents, plans and strategies to cross-reference. There is no reference in there that we can see whatsoever of the Scottish Biodiversity Strategy to refresh what is happening at the moment or the environment strategy that is current. It is important that that is included to make sure that we are paying proper regard to an activity that can have tremendous impact on biodiversity and the environment. There is also one of my colleagues who has spotted an omission for historic environment within there. The documentation in that regard has to be included there. I think that that is probably most of the points that we want to make with regard to that. Sorry, I am trying to make sure that I have gone through. Sorry, there is a point. The nature networks guidance is not included in the development plan. We think that that is very important as well. I think that that was all the points that were raised there, Paul, unless there was anything else you had. Thanks, Bruce. Just before we go to Clare Simmons also, Morag, I was going to ask a question after Paul, but Morag already brought it in, which is about wild land. Bruce, did you want to, because with John Muir Trust got in touch with the committee with concerns about policy 4, that it doesn't offer protection? Morag has been able to speak to that. I would like to hear from Scottish Government. Thanks for giving me the opportunity on that one, because I was hoping to come in on that. It is quite ambiguous, this specific part of policy 4. We think that it creates a bit of legal uncertainty. John Muir Trust has provided really good briefing document to the committee about this, but we think that it presents a bit of a false test as worded. It needs to be conditional on whether it can support meeting renewable energy targets. We would assume that all renewable energy development would in some way support renewable energy targets. We also think that that is potentially quite a moving target and that it fails to anticipate a time when it will actually be reached. Specific wording suggestions have been supplied by John Muir Trust in there, but that is the main points that we are making with that briefing. Thanks very much for that. Clare was going to come in next on Paul's questions on the development plan and monitoring. Just before you give that, I was just coming back to the point that you made about the wellbeing economy. I have a specific interest in that as well, convener of the cross-party group. I was keen if you could expand a bit more on that, because there is a national performance framework that is being reviewed at the moment, and there is a wellbeing economy monitor framework being delivered as well. Just to take your comments to that context as well and where you can see NPF4 fitting in with the other two reviews that are going on just now. In terms of the wellbeing economy. I guess that it is in terms of the point that you cannot have GDP at the same time as a wellbeing economy. To strengthen those national performance framework metrics and the way to measure that, to align more closely with the wellbeing economy and not to put so much emphasis on growth. That is essentially it in a nutshell. The broad issues that you are talking about are the delivery plan and indicators that you would like to see. I will have to follow up on that. I guess that some of the indicators are a bit tricky in terms of climate, because some of them are about reductions in carbon and how do you monitor loss of biodiversity and so on. The point that I want to make about monitoring is really about having a play system, because it is so critical to communities who do not have a right of appeal and who are asked to do their own local place plans to get involved in the local development plan that these local development plans are adhered to. The planning act did come up with the requirement for a statement of conformity to be written, which means that planning officers are required to state whether or not the application is in keeping with the local development plan. In terms of ensuring that we have a plan in that system, monitoring those is crucial. We have just done a bit of work with the new planning law clinic in Robert Gordon University and doing some research that is supported by Neil Collar, who is one of Scotland's leading planning lawyers. The preliminary look at that suggests that those conformity statements are extremely variable. There is lacking guidance on them, and they are not currently at a very adequate tool in terms of measuring whether or not we are conforming with the local development plan. I think that that is really important because the initial results seem that material considerations rather than the development plan is what is forming the planning decisions. The other thing was about planning portals and the technology on how we might improve them because that came out of the research very strongly, the difficulty that the students had in accessing and navigating these planning portals that were quite plunky, some of them. Finally, in terms of testing, I think that the test of this plan and whether it is working will be on what developments go ahead and are people looking at what kind of developments are the outcomes. It is about focusing the monitoring on outcomes and revisiting the sites. Are they delivering what they are supposed to deliver? What impacts are they having? The Kilmacon decision at the moment has gone to appeal where the development is contrary to the local development plan. There is a surplus of housing. It is going to impact on nature quite significantly there. What decision is going to be made on that when it has noticed the intention to approve this development? Is that in keeping? That is the test, in my opinion, as to whether or not this plan is working. That is all for me. Thanks very much for that. I want to note that we have gone over time, but it is important that we have the space to get all these views out. We have our final committee member with a few questions. Miles Briggs. Thank you, convener. My questions follow on from Paul McLean. It is quite clear from what we have heard that the devil is going to be in the detail with regards to the guidance and transitional guidance, I think, especially. I just wondered in terms of your view on MPF4 and transitioning the planning system as it stands now and how it potentially will stand. And current planning applications in the system and what that looks like, and specifically maybe with regards to the housing crisis. I think that is a missed opportunity not to have that on the face of this, but I just wondered in terms of where you think that that could be lost in translation potentially between now and MPF4 coming in. I don't know who will start that. As I said, the number one concern at the moment in the short term is the fact that there is no transitional guidance that we have seen so far and that we are aware of being issued alongside MPF4. It is a legitimate expectation that that would have been done because we see it when other consenting regulations change, for example building warrants. There is no line in the sand. At the moment, there is no line in the sand. Anything that is in the system right now be that with local authorities in terms of planning applications awaiting a decision or with the reporters unit when this is adopted, as it stands, will need to be reassessed against MPF4. When those were submitted in good faith and a lot of time, effort, resource has been put into these by the applicant and local authorities and reporters unit, MPF4 might have come even before the draft because applications are not quick to come through the system. It is a big concern from our side as to what that is going to do in terms of decision times, certainty. For me, there needs to be a line where, if something is in the system already, it is determined through the current system. That is a short term concern which is a significant one that needs to be addressed by the committee initially. A longer term, I am not seeing much in terms of transitional guidance for the new LDPs as they start to come through the system because we are going to have a scenario where we have an MPF4 getting adopted now and it is going to be 2027 before we are seeing the new adopted LDPs that will fall into line with this new document. There needs to be guidance there to make sure that these applications that are coming through are keeping up pace. I do not know what I hear from others. We are not alone in terms of the public sector. The public sector equally is calling for this guidance. It is one of the main disappointments that we have not seen this guidance coming forward. Does anyone else want to come on that point? This is something that we have looked into with our legal members. Our understanding is that as soon as the MPF4 is in place, the decision should be based on whatever is the framework at the time that the decision is taken. I reiterate what Liz has said that if there is an application in train that has been structured on the previous guidance, the restructuring could be quite burdensome on both sides for the applicant and for the authority who is doing the decision making. The quicker we get MPF4 in place, however, the general opinion of our members is the quicker we make that transition and the less of a problem that becomes. Our nightmare scenario is that we end up in this twilight zone between documentation where nobody is quite sure which one we are working with and that ambiguity and uncertainty cause far more problems than a rapid transition from one to the other. Bruce, do you want to come in? Very quickly, as well as the need for new guidance, I have already said a lot of times that we really need to get that nature network guidance out there to help local authorities strategically plan where green and blue infrastructure is going to go and all the nature-based solutions that can provide. We have just seen extensive flooding across the country. If we are to fight that with nature-based solutions, we need to plan that on the landscape. Without that guidance in place, I do not think that local authorities are going to be able to do it very easily. The other point is that some of the existing guidance that they are already is not coherent with climate and nature. As well as the new guidance, we need to also, I am sorry to say, adding workload, some of the old guidance is just not appropriate in the context that we find ourselves in the climate and nature emergency. That is helpful. I wanted to ask and maybe sound like a broken record on this, but, as an Edinburgh MSP, I am really concerned about the emphasis just on brain field development, which is unlikely to be forthcoming here in the capital. There are businesses, very viable businesses currently on these sites, and they have had no communication or no real conversation over what the future with MPF4 looks like for them. I just wondered in terms of MPF4, what issues do you think there are still needing to be addressed around that pipeline of land, coming forward for all the commitments that are in this plan to actually be achieved, especially around the housing crisis? I think that what we asked for in the first draft was a fix to where a pipeline is under delivering, because if it is under delivering, something has to happen. At the moment, there is still no mechanism to fix an under delivering pipeline except to bring in longer-term sites and sites that are beyond the 10 years in LDPs, but generally speaking, they are in that bracket for a reason. So what if they cannot come forward and plug that gap? At the moment, without the guidance, the LDP guidance is not clear if there is a fix. I really hope there is a fix and we want to engage with Scottish Government further on that to discuss how that might be done, but it is a big concern that if we are under deliverings, for example, a plan review, what would trigger that and could that just be a housing section of the review? The other part is, so we are talking about under delivering, big concerns there if that is happening, if and when. It is also not clear if there is an over-delivering pipeline, then there is the ability that further land can come in, but it is quite clear in policy 9, as it now is the brownfield and vacant and derliked land policy, that that cannot be greenfield. But, as I said before, what if there simply isn't any other brownfield vacant and derliked land sites there to come in? Then what do you do? For me, there are scenarios that have not been worked through, so as it stands, I can't legitimately say that policy 16 will deliver the homes that we need. Equally, we still don't have a clear definition of what a deliverable site is. The MPF4 is very clear, and we are supportive of this, that sites must be deliverable. As a clear man there, sites aren't deliverable, they are de-allocated, so sitting behind that, we need a very clear definition of what that is. What does deliverable mean? There is now a short, medium, long-term pipeline of sites in a post-10 year. Again, we have not got the definitions yet as to what that is. What sites should be in short? What do they need to have in terms of planning, consent, infrastructure? It is critical that the guidance comes forward to explain how this is going to work. The danger is that you get to year 5, 6, 7 of an LDP, it is not delivering where is the fix. At the moment, it is not clear what that fix is and you could almost say that I will be premature with MPF4 looking at policy 16 without the guidance alongside it. That is a fair statement to make. Again, alongside the lack of transitional stuff, this is up there with one of our key concerns. We are hoping to see more of a solution coming forward. That will be critical. The delivery programme is clear that the LDP regs and guidance are still to come but we have not seen them. We have seen a draft, we have not seen the guidance that sits behind it so we are not clear how this will work in practice. In just touching on your brownfield greenfield point miles are brownfield sites in Edinburgh, we can allocate brownfield but if they are not deliverable if they put current uses on them then we shouldn't be allocating them because they are not going to come forward. We shouldn't always assume that that is the most sustainable way to plan for settlements because what we are doing in the Edinburgh example is removing a lot of existing businesses away from the city and I am not clear how that can be judged as sustainable for anybody. Again, it is much more nuanced than in sort of brownfield good, greenfield bad but big concerns there and it is something that I would be keen to continue dialogue with the committee on. I am going to take a slightly more philosophical view of this one and I think that this is indicative of what was going on behind MPF4 of that fundamental mind shift that we need to make for a net zero world and just thinking about the words that we use in terms of greenfield, brownfield, there is often the subconscious assumption that any kind of development is inherently bad that you turn a greenfield site into a greyfield site where the biodiversity is gone and it is less desirable and less attractive and so on and I think that that is the mind shift that we need to make here. Development is inherently neutral and what the MPF4 should be doing is pushing developers to prove that what they will create will be better than what was there before that it will be positive for communities, it will be positive for our climate, it will be positive for biodiversity and for me that is more of the approach to all the things that Liz has said are contributors to that. It's a very tired joke in our planning system that we have a tendency to name things after what we destroyed to create it so Orchard Road and Meadow Bray and we need to change that so after the development as there will be on our site there will be a restored peat bog that is flourishing with more biodiversity than there was when we started and that philosophy should be carried across all development. Thank you for that. That comes to the end of our questions on this panel and I just thank you for being with us this morning, sharing your views, it's been really important conversation and I think it needed that little bit of extra time to really draw them all out so thanks for that. So I now suspend the meeting for five minutes to allow a change for witnesses. We now begin our final panel of witnesses on the national planning framework and on panel 3 we are joined by Dr Caroline Brown who is the assistant professor of environmental planning and healthy environments at the Urban Institute at Heriot-Watt University Welcome and Professor Cliff Hague who is a chartered town planner and chair at the Coburn Association and has been a long morning but I think it's such an important conversation that we're having and I'd like to begin with the same questions that I asked previous panels just would love to hear briefly if you could outline your views on key changes that have been made in the revised national planning framework and maybe Caroline you're smiling at me so I'll tease you first. Thank you so much Carina thank you for inviting me back I think as others have commented the revision to NPF4 has brought some greater clarity and consistency in language which is very welcome and I think the high level principles about the climate emergency and the nature emergency also emerge much more clearly in this version, in this revision so I think there's a lot to be very positive about the clarity of language consistency is very helpful and I think another thing that I really valued and noticed was embedding of the qualities and diversity also within some of the policies so talking about the need to plan and design for diverse needs within cycle active travel for example so I think that's all fantastic there's a couple of misses for me that I wanted to draw your attention to one is about the first spatial principle in the very beginning of the document in part one the just transition which unlike the other five principles does not seem to be explicitly very spatial and I don't think that NPF4 articulates the way in which that just transition principle should be translated into a spatial policy so what does that mean it says things a little bit about process but not very much about spatial distribution that was my first miss and my second miss was on health and there's a policy called health and safety I forget exactly which number about 23 I was going to say 22 at 23 and that's mostly about risk and harm minimisation it's actually important but I think the title of that policy and some of the language within it could be expanded and it crosses with the six principles of good places because number one in those six principles at the end is about healthy places so I think health could be expanded to be much more about enabling wellbeing the salutogenic model of the environment and how it supports health the risk reduction pathogenic model minimising air pollution and so on so that was my second miss that I think the draft didn't quite articulate I'll stop there I think we'll come back to some of the other things Thanks very much and I think I've just got a new word salutogenic I think I can imagine what that means Cliff Thank you for inviting me I really do welcome the MPF4 and its ambition I welcome a congratulatory team who has produced it and the politicians who supported it and that's because it puts the climate emergency and the biodiversity emergency clearly as the overarching concerns having said that and given those congratulations I think we also need to recognise that there really isn't much choice in terms of that only really now vested interests and ideologs will not recognise that these are actually more significant issues than the planning system has previously treated them and I'm very conscious that there's actually quite a lot of international interest in MPF4 again other places other countries grappling with the same sort of issues and how you actually use the planning system to deliver on these global priorities so I think there's a lot of good stuff that said I think there's still a risk that will fall short of the aspirations and in a sense this is the easy bit to write the overarching strategy and to strike the high notes and as people have been saying during the morning there's a lot more work that will be needed in terms of spanning out the detail how we actually deliver in terms of the details and just some of the things which could still be tweaked in the policies and it's echoing some of the things that Caroline was saying embedding gender as an issue I think in the policy on play which is number 21 recognise that the needs of girls older girls are not really recognised in there and basically I might seem as an odd guy to be talking about the needs of older girls but my understanding is they'd like to hang out in places with their mates basically and so that puts an emphasis on safe public spaces as a really key factor housing I think the debate still is dominated by the housing land issues in a week where we've seen issues with the quality of social rented housing in a tragic case down in England I think we need to see social housing as essential national infrastructure and this also feeds into economic side of things because it's crucial that there's available housing for care workers for NHS people whole range of key workers whose needs are not well addressed by the current debates about affordability the really obvious thing if you take affordability based upon average incomes meaning incomes it really misses the point because you should really be looking at the model income because very high incomes distort what the average is so you're actually factoring in misleading information into that definition now I know there's a working group on this but that's the kind of thing we need to look at and the quality of existing housing I'll be very quick with just two or three others policy 20c protects regional and parts from development incompatible with use these habitats and character I think that should also apply to urban parks urban parks are really really important in terms of the health and wellbeing agenda they're important in the mobility and it's just as important to protect those spaces from development that's incompatible as it is with the national parks health and safety policy 23 again I think it needs to give more emphasis on conserving existing urban green spaces there should be a clear presumption against loss of green space on health and wellbeing grounds and finally and then I'll hand back to the questions community well-pony discussion in the previous session some interesting data just came out yesterday I think from who owns Urban Scotland showing that most of our retail centres are actually owned by offshore companies so that's the exact opposite of community wealth building it's community wealth extraction so I think that in terms of 26e business and industry and 27a town centres there should be a requirement to demonstrate a contribution to community wealth building to embed it through the system I'll shut up there and check questions thank you very much for those answers and please don't shut up because you know you're bringing in new things from you this morning which I think is really important and Cliff you already began to touch on climate and climate and nature crisis and I asked the question in the previous panels and I think it's maybe more of a kind of planning question I think phased a few folks in the last panel but in practical terms what is the requirement for decision makers to give significant weight to the global climate and nature crisis mean for development management and development planning across Scotland I think I just broadly endorse what Planned Democracy was saying earlier this morning that there needs to be clarity the planners need to feel that when it goes to appeal the reporters and government decision makers have got their back on these sort of issues because these issues will be contested there's no doubt about it I mean everybody's in favour in general terms of saving the planet it's just don't do it to me so there will be times where it comes to crunch at appeal there's a concern I think from practicing planners about getting into appeal situations which are very resource demanding and it must be seen that there is real support for these as priority issues and it needs embedding as well through the training and so forth again as other people have been saying earlier and I think it also needs reflecting in the monitoring and I could say more about that later if you want I completely agree that I think we discussed this in the last session about the need for the language to be clearer so that developers are clear about what wasn't allowed and what they couldn't push on and local authorities have the support then to refuse applications and confident that they wouldn't lose on appeal and have costs awarded against them I think there is still a need for clarity I think we're much closer than we were because it's much clearer that significant weight must be given and there aren't those kind of accept emissions must be reduced accept where they can't be that's gone so that's really helpful but I think it's still going to be that test of in practice are local authorities confident enough to refuse significant developments because they've waited for that as a deciding factor Thanks very much for that I'm going to move on to questions from Miles Griffin Miles Griffin's it's been a long morning merging my colleagues Mark Griffin who's joining us online Thanks Cymru similar vein to the questions I've asked the previous panels there's been considerable emphasis on the Government on focusing on economic growth and I just wanted to ask witnesses if they're confident that that is compatible with the approach to planning that is set out in the AFT-NPF4 document Thank you The principle of the NPF supporting development is still there and of course development is one of the things that is synonymous with economic growth so I don't have any concerns that this is going too far in regulating against development and not supporting economic growth I am one of the people that was very critical of the previous kind of sustainable economic growth kind of fudge so I'm a bit happier I think with this version which does prioritise the environmental principles and the environmental goals but it still allows for growth it doesn't legislate against that at all so I don't think there's a problem I think similar thing the sustainable economic growth definition that we had failed to mention either resources or conservation neither of those two words came in the definition which made it a rather peculiar way of approaching the notion of sustainability but I think probably more could be done actually with NPF4 and particularly when we come to the regional spatial strategies in terms of delivering different types of growth I mean I think we're all in favour of growth and wellbeing as long as it's in an appropriate form and I did actually run the draft past a colleague in South Africa an academic there and he did actually feel that it was light on the productive places side but I think some of that is because it's tucked into the what's now the appendix on the different regional strategies I think just to take one illustration I think we need to look at what the spatial dimension is of things like circular economy and what are the spatial catchments for key growth areas in recycling and where do you locate them and how do we progress them through the system so I think more probably does need to be done but really shining a spatial analysis angle on it and grasping again the potential of community wealth building is contributing to economic growth by recycling the investment and returns rather than seeing it extracted okay that's an interesting point on that I think Mark you're done with your question Gell okay we're now going to move on to questions from Marie McNair thank you good morning panel it's the same line of questions from the other two panels Dr Brown they'd like to ask if you're satisfied to the terms such as community wealth building and 20 minute neighbourhoods are now well defined and understood to provide a robust basis for planning decision making it's really keen to hear your views on this as others have commented previously I think we've come a long way from the previous version so it's much clearer what we mean here and I notice also that some of the language around 20 minute neighbourhoods has kind of been drawn back underneath the place principle rather than as the headline it's also helpful allowing us to kind of think about and articulate the nuances of different contexts so the as someone was saying earlier the urban, the suburban, the rural, the island contexts are really important and having policies which are flexible enough to allow planners and practitioners to interpret that in those contexts I think is really helpful so I think we've moved much closer I don't think community wealth building is there yet I think there's still lots of questions around that and as we've seen in previous discussions people are saying this is quite a new concept in industry it's quite a new concept in local authorities so I think there's always room for more elaboration and particularly on that quite new use of language quite new idea so 20 minute neighbourhoods I think is much clearer because there's a lot more work around that a lot more understanding but the community wealth building is clearer than it was but still room for further elaboration and that may come in separate documents rather than within the NPF itself thank you there's needs for follow-ups and advice and research I think 20 minute neighbourhood remains a little bit more problematic than perhaps Caroline suggests me again I said there's international interest in what's being done here and I got an email last week from distinguished German special planning Professor Klaus Kunsmann saying look I've just seen the Scottish MPF4 and what it's saying about community wealth building I've got a blog on this that I've done in German but I'll translate it into English if you want and can you publish it on your websites so that's what I did and what Klaus argues firstly that it was a kind of political ploy in Paris by Anne Hidalgo to mobilise support but more fundamentally that he argues that there's a risk that because similar people live in similar neighbourhoods that you kind of trap people trap poorer people in poorer neighbourhoods and wealthier people in wealthy neighbourhoods and the more that key resources are concentrated in the neighbourhood the more that social divide exists I think what Klaus takes for granted because it's based in Dortmund is that you're in a large urban agglomeration I think that risk is greater in the bigger cities perhaps bigger than any we've got in Scotland than it is particularly in the small towns for example where there is only one school one secondary school where people are more likely to share facilities but I do think that needs looked at and similarly what happens if one of the key local facilities isn't there how serious is it if there isn't a local health centre compared with say a local secondary school so I think there's a number of issues still to be teased out on this and the context of local authority austerity it's a real question mark about sustaining those essential services that can knit together the 20 minute neighbour in the ways it's seen so I'm supportive but I do think that it needs quite a lot of work and every place is different you know it needs some sophisticated local understanding to deliver it to good effect thank you for that and the last question obviously was about the numerous references to the infrastructure first approach in the revised MPF4 and just to ask really has it been delivered in practice of what needs to change infrastructure first makes a lot of sense one of the critiques we've got of the previous system is it's been kind of infrastructure second or third or maybe later and so it's integral to a planning approach but then going back to where we were it does mean there has to be confidence in the local development plans that they have to be bold, they have to be leading documents, plan led documents and not things that are then overturned on appeal and the that also needs though the co-ordination of the infrastructure providers and the different sections of Scottish Government I should have said I very much liked table one I think what people call in the matrix I thought that was really good not least because it connected with the sustainable development goals and carried things through it seems to me that I would say this as a planner wouldn't I that planners can see that everything affects everything else I just hope that we can get to a situation where the sectoral providers whether it be health, transport, environment whatever we can also see that everything affects everything else and you need a plan to put it together and I think one of the acid tests will be how you can actually make that infrastructure first idea work across the system through the different types of plans we now got with regional spatial strategies I'm still not totally convinced about the city region deals how far they really tie into that rather than into a couple of priorities of really key big players you know I think there's a lot of alignment still to be done but at least the MPF4 this iteration more than any of the previous three is trying to do that and I give credit for that Thank you doctor so lots of lots of things that Cliff has already said I would agree with and I think infrastructure first I remember that we talked about this last time as well I'm really supportive of this but I'm also really supportive of the infrastructure-led development and there's a question there about whether or not the resource is there to deliver infrastructure ahead of development so particularly doing that longer term planning thing where we're saying we're going to be expanding this settlement on the eastern edge and we're going to put in now those corridors for the public transports bus links and for the site and walking infrastructure and we're going to put that infrastructure in even though the houses in that area aren't going to be there for maybe five or ten more years and I think there's still a question about the ability of local government and the Scottish government to do that and to deliver it so infrastructure first is a really important idea but I think we still haven't yet seen it being delivered convincingly in practice and we do not see in Scotland infrastructure first infrastructure-led development in a way that some other countries manage to do so still some questions for me about the one Thank you Some interesting points there and definitely big questions on that infrastructure-led development I think that's an interesting perspective We're now going to go online with Annie Wells Thank you I'm going to go back to the sort of a question asked to the other panels which is about the every local place plan and it having to have regard to NPF4 Now looking at the draft document how confident are you that community bodies will be able to do this but also from the last panel is how do we reach out to these community bodies and where there's communities that don't have any community bodies where I come from I come from quite a deprived area in Glasgow we don't have that community cohesion or bodies that are there to do that so how do we get communities involved in this that's to either first I think that the best way to get communities involved is to have a threat that always puts people on the streets and into public meetings but more seriously the planning system does remain quite daunting to people I'd have to declare interest as being a patron of Paz planning A Scotland as was so I think Paz has done a good job of trying to provide facilitating support but it again needs backing and also from the point of view of being chair of the coban association again I'm very ambitious here in Edinburgh even in Edinburgh where there's obviously a lot of resource and expertise within community groups that a lot of groups still do find the system difficult to negotiate and we get loads of people phoning up the coban association saying X, Y, Z happening can you help and very often it's too late because they get involved at the point where the application is there at the bottom of the street but it's already gone through the local development plan and the NPF process but also as a small charity we're now finding life very difficult our energy bills have gone up our staffing costs have gone up cost of living crisis means that our membership has been steady but we haven't really got the capacity to provide the help that we could provide if we had a bit more resource there that we could draw upon so I do think that local place plans need to be resource they need to be able to tap into the expertise that is in communities and find ways to make that effective in terms of connecting with the issues on the ground so I think there's two elements to this one you started off with is about the way in which the local place plans interact with NPF4 and I think NPF4 is a lot clearer than it was and it's a lot easier to understand but I think the idea of there being a simplified laypersons version I think would be really helpful to distill this even further down and that would make it easier for local place plans of communities on the ground to see how what they're thinking about in their place would link through to the principles in NPF4 so I think there's some technical, practical work to be done about NPF4 and how it links up with the local place plan but I think this other question about getting community involvement is also predicated on the purpose of the local place plan and being able to convince people that there is something to be gained in the community from buying into it and something to be gained which is not just saying no we don't want that housing retail park, nuclear power station or whatever it is to pop up in that part of our neighbourhood but it's actually much more positive about the future and I think that's the trick that we need to master I don't think we're there a requirement for resourcing and skills development in local authorities and without reach whether that's coming through PAS or another organisation into communities to help them to do it but we also can't force communities that's the other thing so we have to it's a little bit of a tightrope to how to communicate that and support it for communities that want to do it and get to a place where we're able to articulate the value of it, what are they going to get out what's going to be the upshot for them and something that's much more positive than just stopping this bad thing that they're worried about I did think there's a leadership role here I think we need to have high profile statements that this is a change in the way the planning system is going to work we're about climate change net zero biodiversity and this is really going to be reflected through the system and I think if you start talking in those terms and pick your monitoring indicators as well as a key list you can begin to turn around this image that what we've got is a process driven bureaucratic system that is impenetrable for the ordinary person and that is really dominated by the KC's and the big investors and if we can begin to show that through using the planning system with the local place plans you can actually enhance your local biodiversity using the planning system and the local place plans you can explore the concept of community wealth building and see local benefits from it I think you could begin to change the way that involvement is seen I find that very helpful thank you both and thank you there's an opportunity for some well-skilled community facilitators around that it's very interesting how to pull community wealth building through local place plans exciting work to be done we're now going to move to questions from Paul McClellan thank you I'm going to ask the same questions that I asked the previous two panels it was on your views on the delivery programme obviously are companies, NPF4 including the establishment of the planning infrastructure in place advisory group and one of the key things the other question was really just asking about are there one of the key things we were keen to focus on was in regards to monitoring the effectiveness of NPF4 so are there any indicators that you would like to see as part of that Professor Hague first of all it really follows on from what I was just saying I would scrap the stakeholder group of applicants why I would do that is because I don't think the primary aim of NPF4 is to speed up the rate at which planning decisions are taken I'm not saying that doesn't matter I'm not saying that we should slow down decisions I'm just saying that's not climate change that's not net zero that's not biodiversity so why do we prioritise that going back in the previous question when you start saying that the key stakeholders are applicants where does that leave everybody else a message you're on the outside so I would suggest that we have a citizen stakeholder group but they're serviced by some expert professionals by the people who can actually talk serious science on carbon reduction by the people who know what the impact is on biodiversity and feed that in and help then interrogate the annual data that will be provided by the Scottish Government I'd also go for some hopefully eye catching summative headline indicators so for example for sustainable places could we look at something like the area of peat restored in the last year you know tell people that the planning system is about protecting peatlands because that really matters could we for liveable places look at the number of buildings demolished in the past year and hopefully see that declining because we know the most sustainable building is an existing building could we talk about the percentage of new buildings new developments that have got sustainable urban drainage systems that's approved so that we begin to see the way that the planning system is influencing development for the good I've already mentioned the issue around affordable housing could we see that as a key indicator of the system that we increase the number of affordable housing I'd also like to see something on homelessness on productive places percentage of empty town centre properties hopefully going down the number of facilities approved in development proposals for all forms of renewable low carbon and zero emission technologies and so on so I think you know if we get a select group of indicators and I know how feeding through citizen groups you know we could we could begin to change things not just run it forward in the way we have done in the past it's quite a complicated question isn't it I think on the delivery plan as others have said it would be useful that we had this separate document and it set out a lot of the plans around different groups and monitoring and things it does look terribly complicated and quite resource intensive and I suppose Cliff's alluded to the fact that perhaps there's room for changing the focus of that the make up of those those groups and are they doing are they reflecting the things that we want them to reflect so that's the first thing as others have said in previous panels I think there are loads of questions about the resource available to deliver this and I think that also needs to be part of the monitoring so to look at the resources that are being put into the implementation of the national projects for example so how much is being delivered how much how much budget has been allocated and what has actually been delivered on the ground and in line with what Cliff was saying that actually helps tell a message tell a story about what the national planning framework is helping to deliver on the ground and I think that would be really helpful to know I think there might also be some value in doing some work looking back at what has previously been delivered by NPF3 and that national level planning so that's one part of it so we've talked about the delivery bodies and the monitoring in here the groups in here we've talked about the resourcing and I think staffing people have talked about the number of planners I know there's work on going around bringing more people into the planning profession I think that would be an easy something to monitor to see actually are we having do we actually have more planners within the Scottish Government to do these things and implement this new revised NPF4 and then there's a series of questions about the monitoring of the impact and the difference and I think Cliff's given us some really nice ideas there the delivery programme also has some indicators in it but I don't think they quite get at what's changed and I think this is also a really tricky question without having some clear baselines about what the current carbon intensity of housing developments is as opposed to the future carbon intensity of schemes coming through the system and I think that's quite hard but I think again there's some room for thinking about that so biodiversity would be another one again as kind of a high level objective of NPF4 you know how do we measure impact of the new policies on developments that are coming through the system and are consented under the new arrangements versus things that were consented in the past but I think there's also something about only focusing on development that comes through the system and what the old ones look like and what the new ones look like but we also need to look at these wider measures of place and quality because NPF4 sets the agenda for those as well so it isn't just about new housing and new retail it's about those other improvements and again can we create any indicators which capture that community level there's been quite a bit of work around 20 minute neighbourhood potential and maybe that would give another opportunity for a baseline about what the current potential is and then in the future are we actually seeing more areas with greater potential for 20 minute neighbourhoods because these policies are having an effect so I think that's enough that's been very helpful for that sorry but one quote at a national level monitoring will initially focus on reviewing appeal decisions and reflecting on the progress of new LDPs in the local development plans system young people concerned about the future of the planet and not going round saying let's monitor how the LDPs are progressing let's monitor the appeal system that there matters for the bureaucrats if you wonder why people see planning as bureaucratic it's because of sentences like that it's because this is the inside game that's being played rather than looking at what we're really trying to do I think our challenge obviously is to monitor just so many things that you've suggested and go deeper beyond that and that's the role of this committee so that's been very helpful so thank you so we know where we're going we've got four well we maybe got four more questions but I'm going to pass over to Miles Briggs thank you convener I'll try to cut my name to just two I wanted to ask in terms of both the climate and nature crisis it's quite clear from your opinion that's been captured within MPF4 do you think in relation to the housing crisis that should also be very much on the face of the plan as well yeah I do but let's define the housing crisis it's a crisis of homelessness which doesn't get a mention and it's particularly a crisis of affordability and there are special differences in that as you've already mentioned the Edinburgh situation so yes it's there but you have to get serious about what we mean by affordability you have to rethink the notion that build to rent about making housing more affordable I mean if you had £10,000 to invest would you put it in build to rent if you thought rents were going to become more affordable or if you thought rents were going to continue to escalate so I think that that's quite a crucial point also I think we need to recognise hopefully hearing Edinburgh that we are going to reclaim a number of probably thousands of houses that were lost to investors in short term less which were done as we know without the change of use and the new control zone that's now being stated but yes I would say particularly social housing as essential infrastructure because you need it for social reasons but you also need it for economic reasons you know you can't get people affordable housing close to work who are on low incomes you begin to have knock-on effects in labour supply etc we all know in the economic system so it's not an either or but yes I would support that idea what he said definitely we talked last time about short term less and some of those things unintended consequences of things happening in the world particularly in Edinburgh but in other bits of Scotland as well we know the islands are very affected by some of that so there's always room to do more and to echo some of the thoughts of previous speakers NPF4 can't do everything so NPF4 sets the colour policy context for housing but it's not responsible itself for housing delivery and having good social housing provided for by paid for by local authorities in Scotland is another mechanism for helping to resolve this so there's always always a lot more to do and there's a lot of nuance around housing that maybe isn't reflected in here in the fullest extent but we have to also recognise the limitations of what NPF4 can do that's helpful I would like to go into lots of detail about data sets but I don't think we've got time to do that necessarily today but it'd be helpful to get your opinions beyond this on where that currently is within NPF4 my final question was returning to something you raised earlier Professor Hague with regards to gender because I was interested and I think by and large many of the comments we've received as a committee point towards what is often a male dominated industry and then decisions taken not necessarily taken to account other views basically especially with regards to street layout lighting, things like that that's been raised with us several occasions so I just wondered do you think the policies in the revised NPF4 will actually deliver on a built environment that meets the needs of women, children and disabled people? Again I think it's a start on where we're at but this is again one of the areas where it needs continuing leadership it needs people saying these are material considerations these are things that we're taking seriously and it needs to feed into the training and so forth as well but it's a step in the right direction and there are other inequalities that also need to be tied together on that I could say quite a lot on this and I mentioned at the beginning that I thought one of the changes has been to thread equalities into specific policies in a much more effective way than in the previous version so I think that is a really helpful thing but we have to be clear that the responsibility here is on the planners and the professionals within the system to implement the policies it's not on women in the community or disabled people to come forward and say what is wrong and what needs to be fixed so I think that's a really important thing I think there was in one place something about women I can't remember but I'll have to look it up but there was one moment that I thought ah we have to recognise the current inequalities and address them and I think this goes a little bit further than what's in here so for example if we look at active travel we know that men are cycling twice as much as women in Scotland and why is that and we know from research that women are more risk-averse and they feel that the current cycle infrastructure does not meet their needs and that might be because some of the things on offer are off-road paths I can just thinking through Holyrood park here there's some lovely off-road paths that women tend not to find attractive and safe particularly on a dark afternoon or at night so the women are forced to make a choice between a personal risk so personal safety risk versus traffic safety risk and that is something we have to understand and address in our design cycling by design does quite a good job on that so that has been revised but designing streets is still outstanding and the revision to designing streets needs to address these things more clearly to explain how existing patterns of development affect particular groups and then the sorts of designs which overcome those problems for women for people with disabilities for people with different types of needs whether that's a mobility impairment or a visual impairment or whatever so I think we're still looking for some of that guidance to catch up with where we need to be so I think it is really helpful what's in here but we still could go much further and just on children I really liked the policy on play and one of my kind of asks in relation to delivery and perhaps monitoring is looking at designing streets and how that articulates how to build play into new streets so the policy is really clear that new developments, new neighbourhoods new streets should make play accessible for independent mobility for children and make it accessible but we need to have the guidance and the exemplars in there so that out in the world so that practitioners can see what it looks like and then deliver it Thanks very much Miles and thanks for those responses I'm going to now move to Willie Coffey who's been patiently waiting Thank you, convener Good morning to you and I'm really glad that you've widened the discussion out some of the issues that concern me as a local member and have done for many years I suppose I was very hopeful that it would be solved within NPF and I'd like to get your views on whether you think they are Professor Hague, you talked about things like derelict buildings and empty shops and offshore retail owners and the inability perhaps to reach out to those bits of society to get them to play their part that's very much a hope that I had for NPF that we would be able to reach some of that stuff and in our town or village in Scotland you'll see examples of that all over the place urban dereliction and decay abandoned shops, abandoned land absentee owners absentee shareholders whoever they may be and I thought to myself was the role for NPF for addressing that big issue because that's what matters to my citizens in my constituency and you talked about maybe we should have citizens stakeholders and solutions to that so could you give us some views about whether it was too much to expect to NPF4 to address that and what could we do additionally to help NPF4 to reach that sort of problem in the urban setting? Yeah, I think it probably is too much to expect NPF4 to repopulate the town centres of small towns across Scotland it is a national strategy and it is set in the framework as it says but I think that the issue is best tackled at local level I think that NPF4 sets the direction it raises the issues we've already been talking about this morning which are helpful I did some work when I was chair of built environment for Scotland on a particularly smaller towns in Scotland but in every case virtually I think there was a challenge in the town centre and you have to understand those local situations you know how key is the father local traders which properties are owned by local companies firms and which are owned by branches of global investors because one thing that struck me was that where you've got a local owner who's renting renting it out to a shopkeeper or whatever there were much more realistic about rent levels in some of these places than what you got from the decisions that were being taken by an algorithm in middle sex or something so you also need to see just what is the condition of the nature of the buildings but crucially the public sector still has a really big role to play and one of the difficulties that we've hit over the last 10, 15 years or so is the loss of key public buildings like district courts which tend to have a prominent building in the centre of course the loss of the old town halls going back to the 1970s but still felt and more recently the relocation of some council offices to new build in some cases edge city sites leaving behind property in the centre which then becomes empty and again this run down effect because these are prominent buildings town halls were making a statement about how important the town was so there weren't little side things so I think you've got to have some sort of agency at local level that will do the legwork do the trade connecting try and come up with feasible strategies explore where the scope for new investment it's not going to be easy because we know e-retailing the cost of living crisis there's a whole range of things that are going to be hard to overcome but unless you've got that sort of feet on the ground with the local know-how the vision and the ability to network across different stakeholders it's going to be even more difficult but if we can do that I think it could be really transformative I agree with lots of things that Cliff has talked about and I just wanted to mention the Scottish Land Commission's work because they've done lots of stuff around derelict land and some of the things that they've proposed there about which would give local authorities tools to actually acquire assets and bring them back into use and bring them back to development and of course I think this issue also intersects with the policies around community wealth building and obviously communities of assets transfer so those possibilities for communities to acquire those sites and to turn them from bank or whatever it is into some community hub there's quite a few examples of that and I think that's a really positive part of this so to see the support that's in NPF4 in the policy but the tools itself are not delivered by NPF4 I think there are some other tools that sit alongside if they don't already they should be coming forward through some of those other initiatives like the ones that the Scottish Land Commission have proposed one of the advantages of decline is property becomes cheap so it becomes easier to get in so we really need to try and look at how you can use easy in easy out cheap accommodation as a basis for start-ups and tapping local entrepreneurial capabilities fostering that leading it but it does demand this willingness to actually think beyond are we going to approve a planning application within eight weeks it's that very issue that I find is really difficult to answer if an old building perhaps in a town like Comarnham for example has several purposes over many years and perhaps there's an application to use it in some new purpose or other that we might collectively or elected members of the citizens of the town might not agree with planners feel impeded in changing the mind if it's already provided for that particular change of use how do we inject that kind of sense of we think differently about what the town should be and what that building should be used for don't see it in there and I don't think having discussed these issues with local planners that they feel they have the ability to do that so who should do it should it be here citizen stakeholder group pushing from the bottom up or should it be some other mechanism I'm trying to get to Ice plan which might help you I think there are these other policies around community assets and community wealth building and also 20 minute neighbourhoods which also could support the alternative community visions for what a place could be and what buildings could be used for so no we don't want this bowling alley or whatever what we want is community hub where people can do this and this and this I see have seen several of those sorts of things coming forward so community groups saying we need a hub we need something that can be used by families in the day with small children that older people can come and keep warm and have a coffee and a nata can be used for after school activities or evening classes these sorts of things I think there are policies here which could support that the mechanisms the resources for doing it are perhaps the missing part of the jigsaw so I think MPF4 kind of enhances the potential value of all existing buildings because of the net zero commitment and the thing I said earlier the existing building is the most sustainable building so in principle it should give a high priority to finding new uses for existing buildings having said all that the downside is it can be very complex and you need a coherent business plan there's only so many community hubs you can keep going and the tragedy is that enthusiasts can get drawn into something with what seems like a nice idea and they're going to run a cafe or whatever it is but it really needs also a coherent business plan behind it or else you just set in some people up to fail so it's again we need these kind of dynamic local actors and I think they can be from different situations there may be planners, there may be councillors it may depend on the local situation you know in the end my Scandinavian friends talk about souls on fire and that's what you need somebody who's daft enough committed enough thinks outside the box enough to make something happen and what we need to do what councillors need to do and what planners need to do is to be engaged with those people and supportive and sympathetic and I'll go back there's a lot of expertise in communities in many of them it's not evenly spread but I mean I find with the Colburn you know we've got people on the Colburn who know more about some things than people in the council do right now we need to find ways to bring that type of expertise into a more positive relationship with local authorities across Scotland thank you so much for that I love that phrase that souls on fire we need many more of them local in across Scotland thank you for that question so that brings our questions to the end and I just want to say thank you so much for joining us this morning actually we've moved into the afternoon and for opening up the conversation broadening the topic and we'll be continuing our evidence taking on MPF4 next week's meeting where we'll hear from the minister for public finance, planning and community wealth and I'll now suspend the meeting briefly so our witnesses can leave the third item on our agenda today is to consider a negative instrument the assured tenancy and private residential tenancies prescribed notices and forms miscellaneous temporary legislation Scotland regulations 2022 as this is a negative instrument there is no requirement for the committee to make any recommendation on it members will note that the delegated powers and law reform committee reported the instrument to the parliament on the grounds that it failed to comply with laying requirements in terms of timings however the delegated powers committee was content with the Scottish Government's explanation of the reasons for this breach so any comments on the instrument our members so no comments our members agreed that we do not wish to make any recommendations in relation to this instrument agreed we agreed at the start of this meeting to take the next two items in private so as we have no more public business today I now close the public part of the meeting