 Good morning and welcome to the fifth meeting of the local government housing and planning committee in 2022. I would ask all members and witnesses to ensure that their mobile phones are on silent and that all other notifications are turned off during the meeting. Our first item this morning is consideration of whether to take items 3, 4, 5 and 6 in private. Item 3 will be an opportunity for members to consider the committee's approach to further consideration around understanding barriers to local elected office. Item 4 is a chance for the committee to consider its approach to the Good Food Nation Scotland Bill. Item 5 will be a chance for the committee to agree its approach on new standards of fire alarms in all homes in Scotland. Item 6 will be an opportunity for the committee to agree its approach to scrutiny of the building safety bill legislative consent memorandum. Do members agree to take items 3, 4, 5 and 6 in private? If anyone online does not agree, you can put an N in the chat. The second item on our agenda today is taking evidence on the draft of the fourth national planning framework or MPF4. This is the fourth of five evidence sessions. The committee will be holding on MPF4. The focus of today's session is on local government issues. On the 22nd of February, we will hear from the minister and I would like to welcome councillor Stephen Heddle, environment and economy spokesperson, Calyn Lindsay, policy manager for the environment and economy at COSLA, David Dune, interim chief officer of strategic place planning from Aberdeen City Council, Craig Isle's service lead, planning and building standards from South Ayrshire Council, Pam Ewan, who is the head of planning at Fife Council and also is the chair of the heads of planning Scotland, Sarah Shaw, head of planning neighbourhoods, regeneration and sustainability at Glasgow City Council, Ian McDermid, who is the executive manager of planning from Shetland Islands Council and Jane Tennant, who is the chair of the Royal Town Planning Institute, Scottish Young Planners Network. Thank you all for joining us today and we are going to move straight to questions. Witnesses, if you wish to respond or contribute to the discussion, please add an hour in the chat box to indicate this. I just want to also say that there's quite a few of you, which is really fantastic. What we tend to do is direct our questions to one or two people initially and if you feel that there's really something really important related to that question that you want to highlight or bring into the conversation then please do join in. But if something has already been said just because of time we've got 90 minutes on this then you know can keep it, move on to the next things and I may have to at some point also cut you off so please I hope that's okay. So the first question I have is that we've had concerns repeatedly raised by witnesses around the vagueness of language within the draft NPF4 and I'm keen to hear if you share those views and specifically what language needs to be improved or revisited to ensure NPF4 delivers positive concrete outcomes for our local communities and I'd like to start with Pam Ewan because of your responses already in writing and then maybe go to Jane Tennant and Sarah Shaw. Good morning, convener. Yes, I met the heads of planning Scotland as the representative organisation for senior planning officers from Scotland's planning authorities, often referred to as hops and this as you mentioned was one of the clear challenges with the draft that we set out in our interim response and we've raised concerns about the fragility of the draft policies as currently the musts and it was subtle often subtle differences in wording that's absolutely critical to how NPF4 is going to be delivered and you know one of the things that we've raised is if government considers that to address climate change needs a real step change in how our places are developed how they grow then NPF must require such policy change really with no ambiguity we have to remember that we're debating a draft and it's rare if ever that a draft is produced of such a complex document and it gets it right first time that's the whole point of this debate and and the engagement that is on going but the policy wording is too loose and it's too imprecise and it won't stand up to rigorous and forensic legal challenges and it'll really weaken the opportunity to drive change through the policy intentions which are evidence in the draft NPF4 so collectively hops believes we need to strengthen confidence in the planning system and make sure that those policies are robust we don't end up at lots of appeals and legal challenges and we note that both solar and the law society support those aspects as well lastly there are lots of words i won't go through them all but there's lots of words that need to find what's good green jobs what's high quality what is great places and there's lots of people who've given evidence that they've done in that heads of planning will be very happy to continue to work with government to help work through some of those finer points thank you very much for that and that was really helpful to get some specific examples like good green jobs yes indeed what what does that actually mean can i bring jane tenon in thanks can be now yeah i'm jane tenon i'm the chair of the scottish young planners network the young planners are those who are in the first 10 years of their career post qualification and it would be for us that to take this plan forward into its towards the end of its timescale i would echo much of Pam's points with regards to ambiguity and challenges like legal challenges over wording particularly in terms of wording such as significant or unacceptable what is meant by the significant or unacceptable i think some thresholds required to be built into that particularly when you talk about the carbon lifetime carbon like a threshold is required maybe like a framework of what's required over the next five years and then sort of five to ten years what are we looking at in terms of that being significant and also things like community wealth building whilst we can read the theory and understand it there's a couple of problems in potentially the next subjective application of these objectives and their further legal challenge off the back of that so we do need to make sure there's criteria and thresholds built in thank you very much for that and once again really grateful for your specifics on that and just lastly Sarah Shaw on this if you want to come in hi yes thanks Sarah Shaw head of planning in Glasgow city council i think again echoing what the previous two speakers have said i think there's certain particularly certain some of the newer policies in npf4 particularly require some clarification and clear wording as Jane has mentioned the the climate crisis the policies which have been introduced on that where it talks about significant emissions and acceptable impacts that's extremely vague and as these are new policies and these are new policy areas which planers are going to have to apply we need particular clarity on that i would also say some of the policies relating to the nature and nature crisis and natural places there is quite a number of areas where it talks about protecting and identifying networks and again acceptable impacts net biodiversity net gain but there isn't really any guidance on that and we would have welcomed some overt linking of the nature scotland guidance which is coming through to give that status otherwise every council will be applying these in an individual way and there will be inconsistency across the board but generally there are some of the policies are quite precise but there are certain areas which do need firming up and will obviously be making a more detailed response to those particular areas thank you very much sarah a new raise another issue that's been brought up to us which is the whole piece around linking this framework to the other existing policies i think graham day would like to come in with a supplementary thank you come here just to be absolutely clear and for the record is the plea here that in every instance in the draft the use of the word may in this context should be replaced by shall or must or are witnesses suggesting there may be some areas in which retaining that vagueness would be welcome anybody in particular you want for that okay so we can bring back in Pam on that yes convener unfortunately i don't think it's as straightforward as that what we need to do with an mpf4 is really look at what are the fundamental policies that we're really saying as a country we really need to deliver these there's no ambiguity and if that's when government decides those are those policies i've used the example of addressing climate change then that's where we don't want ambiguity that is that we require them or they must deliver them where you have a should you will have debate now planning is subjective by its nature and for each development that comes forward for each local plan when you look at it then that's the essence of planning weighing up different factors but i think what heads of planning is saying is there are some policies in there that we would really expect to be require or must or language like that it's difficult it's not easy because what we're really asking for is that balance of clarity and certainty not just to planning authorities not just to the planner that's sitting with the planning application in front of them wanting clearing concise national policy and how to interpret it but also for communities and to grow further confidence in the planning system for our investors across Scotland as well thank you pam and i think steven had the wants to come in on this as well yeah thanks very much i respond directly to mr base question the answer would be no we don't believe it should be a blanket for anything of every should to must it needs to be a more nuanced approach on that and by way example referring to Pam's initial comments about addressing the climate emergency for policy to climate emergency all developments should be designed to minimise emissions over its life cycle in line with the decarbonisation past pathways set out nationally yes that's one where the code should be strengthened to a must to give the local authorities a firmer position to tackle the global climate emergency but the the counter example would be something like policy five community wealth building no we're massive supporters of community wealth building but we feel that the should should be remain there because we support community wealth building but not all areas are covered by it or have the ability to access it so it would be a blunt instrument in that case and indeed the upcoming community wealth building bill means that the relationship between planning and community wealth building will need to be carefully considered and explored there so what position would be to support the Scottish government in the review of the wording of the Scottish planning policy to identify the cases where it does need strengthening and i think that's consistent with the the the position advanced by hops thank you very much for that very specific very good to have those examples i'd like to i'm going to move on with another question but steven i'm going to direct to initially to you and this is around the kind of consultation timescale so there's been quite a bit of concern around the fact that you know we're consult consulting at the same time as the government and gathering the feedback from stakeholders and so in light of this i'd like to ask you to expand on these concerns and the feedback on how you would like consultation to take place as a final plan is developed i have to be honest and say i don't have a clear answer to that i mean the we're finding in our own sphere the i suppose pressures in responding to the consultation currently on going on the the framework were so far we've only provided a a holding response and we're developing the more nuanced response through our committee structures indeed we'll be addressing that this Friday at the environment economy board and subsequently at the cost of leaders before the end of march when we need to respond i suppose the the question that's might be inherent in this is around the npf for as it develops and whether there's a need to to further consult on that and the i think my colleagues in hops and rtbi would probably have a more nuanced response to that thanks yes and with that pan i'd like you mentioned the fact that this is a draft stage and this is the consultation and it is a process but if you if you've got any further thoughts around the fact that there is this dual consultation i appreciate hearing from you thank you i mean hops considers the you know the consultation process today it's been very collaborative i think it's been appropriate and very proportionate and there's been lots of opportunities throughout to participate even before the draft has come out so there's been a lot of work and a lot of wide-scale engagement before that you know your person question is you know should there be further consultation and i think that really hinges around whether whether Parliament considers there should be a significant shift in any from any of the draft policy that's currently before us and then further consultation i think heads of planning would consider would be reasonable it's important to get the wording right heads of planning would rather if there was an additional few months added to the process and getting it right now rather than moving forward with like the previous conversation policies that may be ambiguous and at the end of the day that will it'll save more time it'll save appeals it'll save court cases which only go to slow investment and absorb often unnecessary resources so getting it right is important and we've got that opportunity to do that now and as i've expressed heads of planning we'll be very happy to continue to work collaboratively with government on that great thank you very much for that i'm now going to move on and bring in questions from Paul McClellan thank you convener and then can i refer members to my register of interests i'm a seven counselor on east low down council it just really takes band on the point that the convener mentioned in the first couple of questions and it's really just around about the different sections of the npf4 national special strategies and some of the comments we've had so far is that they don't carry through to national planning policies and there seems to be a disconnect so i suppose it's really just a question around about that one day share that concern and if so i mean are there any examples but also what would be the best way to try and make sure there is that connectivity and Pam will probably come to yourself first of all if that's okay and probably i'll say that after that but Pam to yourself first of all thank you yes i mean it's a lengthy document it's a pretty complex document when you start to start to read it and it is important to get that up front part i think there's the opportunity to make the up front part of the document a bit more concise a bit shorter because the policies are the fundamental aspects of how that will help for instance determine planning applications across across the country so there are areas where it just needs to be pulled pulled through in a bit more detail and some of those read across of the documents isn't clear with with sorry with special specific priorities flowing through an example that comes to mind is around the heat and energy and how you know those early intentions ambitions are coming out pretty strongly and how does that flow through into the into the policy a colleague previously talked about the nature crisis as well how that can refer to nature scotland's documentation so all of these cross references to documents because at the end of the day from heads of planning perspective if you're the case officer sitting with a planning application in front of you you need that clarity you need that precise and it's down to the wording of what is in the document but i also think some of the the cartology needs to also be improved some of the the very schematic maps and we need to look at you know how will that detail be taken through into local development plans and where appropriate regional spatial strategies some of those overlapping areas are actually quite confusing you know that there are some council areas in in south ayrshire for instance where it doesn't cover the one council areas how do we get that clarity and moving it forward the discussions we've had in heads of planning it's really important to remember that those styles were appropriate for national planning frameworks up to now but the fundamental changes this will be part of the development plan and this carries much much more status so that clarity and definition has to be built within that. Just on that before I probably bring Sarah in after that in terms of the national planning policies that does that need reviewed more broadly or does it just reviewed almost piece by piece I suppose policy by policy or does it need a much broader broader review in terms of that you know and I know we've had the review planning just a couple years ago but the connectivity as you said is really important because it's what we're moving forward on to so in your opinion and I'll open it up to the panel as well do we need a much broader review of that or is it just almost policy by policy to make sure there is a connectivity right across the policy sphere I think it's policy by policy you know heads of planning consider that overall the scope of NPF4 is about right we support the direction of travel and we support the ambitions particularly related to climate emergency nature crisis net zero but to achieve that really the point the key point we're making here has got to be clear it's got to be concise and it's got to be deliverable the one aspect that we are disappointed in is that the draft delivery plan wasn't published alongside the draft NPF so we're really debating a new part of the development plan in Scotland without the clarity and how it will be delivered and a capital programme is fundamentally essential as as revenue so I do think it's about I certainly don't want to give the impression that a lot of the policies are wrong they're heading in the right direction it's about tweaking it it's about the nuances that we've talked about and we're very happy to sit down and give support and give resource into helping shape those up into their final final form thank you for that can I bring Sarah and if she's okay and then open up to the floor beyond that yeah just again to I think fans mentioned this already but the the front end of the document is quite wordy and there are many many layers of the special strategy elements are divided up you know into principles and also then the action areas and I think we feel again as as Pam has said some of the action areas the definitions are are quite loose and the central urban transformation area for example covers a very very wide range of different communities different cities and smaller communities and how that how that's kind of taken forward into the the vision for those areas has taken forward into the policies isn't entirely clear for example you know the elements of vacant and derelict land and some of that is the ambition that obviously is to reduce vacant and derelict land across Scotland and it's possible that there could have been more of an overt recognition that this actually could have been a national development certainly within the Clyde mission it's recognized as being part of one of the elements of the Clyde mission but it's not particularly the delivery of how that will be achieved then it doesn't necessarily come through the rest of the strategy and it maybe could have been more overt and I think generally it's quite wordy that that front end of the document is quite difficult to kind of follow the logical flow through some of the ambitions which I don't think any of us disagree with at all but how that can be achieved through the policies and I think there could have been a bit more clarity in that and some of the parameters of some of the mapping again has been drawn quite quite narrowly so for example Clyde mission is very narrow corridor along the river and if it's really to tackle vacant and derelict land in the west of Scotland it would have been it maybe needs to be widened out and the scope of that development national development could be widened out and there's some there are other examples as well but I think generally you know it is that that front end that's probably more confusing in the way it reads and and maybe the thrust of that needs to be clarified. Thank you Sarah. And Craig would like to come in on this. Thank you chair. Just two points on that just to reinforce that this document is actually a working document it's not a strategy document and it will be a document that will be used to assess every single planning application that's determined in Scotland. I think that's where the precision of the policies is really important. I'll be familiar from my householder to a wind farm and we need to make sure that that's absolutely correct from there and that's where I think the policies require to probably be split down more to reflect more some of those areas from the very broad brush I think and that would be a concern in relation to that. Just in relation to the spatial matters and being particularly selfish of from a west of Scotland Ayrshire point of view, the central urban transformation area covers right through the central belt but also lifts down the coast towards some of our settings down at Gurdban and such like and puts them into the same category as Glasgow and Edinburgh and the map also includes the Isle of Arran as well which I think is probably well as in North Ayrshire probably doesn't relate to the same issues that Glasgow and Edinburgh and the central belt have in themselves so there's things like that that need clarity and again it's a working document if we have applications in those particular areas the boundary lines are unclear just as to where that zone is particularly as it runs through the middle of the earth district you know it's impossible to tell where our settings actually sit on those on that line when if you're looking at the map on page 31 it is members it lifts down the coast there and that is unclear as to whether some of our settings sit slightly inland in that zone or whether they're not in that zone and that will be vital when it comes to assessing an application at the end of the day which is what this document as I say is for. Thank you chair. Thanks Craig and David also wants to come in on this. Thank you chair yeah I think to to sort of echo the points that have been made previously but I think the action zones and that spatial strategy are probably the part of the document that we would struggle with most for example if you take the northeast the action zone identifies energy transition as being the sort of key aspect moving forward but that seems at odds with and this goes back to the point that Pam made about the read across across all of Scottish Government's documents but it's at odds with for example the city region deal or our own regional spatial strategy or our current strategic development plan in terms of understanding the importance of diversification and moving away not just being solely focused on energy and even the previous national planning framework was very clear that you know food and drink particularly in the northeast given the fishing industry and the agricultural industry is particularly important so I suppose I struggle a little bit to understand what the role of the action zones really is and if you follow that on in terms of some of the actions that come out of that like the reinvent and future proof city centres that would appear to be focused as Sarah made the point earlier very much on the on the central belt but obviously Aberdeen having a substantial city centre and a regional city centre you know we would have thought that that policy would apply and that kind of feeds back into Craig's point about the importance of this document in terms of actually determining applications so what policies apply what policies don't apply and I think that that is something that we need to get we need to get right that front section of the plan in that in that context I think as I think Sarah mentioned could be could be streamlined a bit and could be sort of focused on a little bit more to ensure that it covers the right areas and excludes as as Craig has mentioned the ones that aren't appropriate Ian it's actually very good to hear these more specific issues around the action zones that feel like just kind of swaths of colour on a map of Scotland and I'm actually curious if we weren't going to do action zones what would be a good way to map out different areas in Scotland but Ian if you want to pick up on Paul's question yes thank you very much community there's certainly an area that's been concerning us in Shetland I've been speaking to Orkney and the Western Isles as well and these action areas do cause a bit of concern so widespread geographically in the north and west coastal innovation area and although we have some things in common even where we we are in common there's quite a degree of difference I suppose so there's things like transport links are very important very extended transport links there's a huge cost to getting off the islands and even the problem we're getting from our outer islands to our local services here on the mainland part of Shetland and we have a lot of differences in terms of things like settlement patterns which obviously impacts on land use planning policies and how we implement the national planning framework some areas where our population declined but Orkney's population is increasing some of us have difficulty naturally recruiting to vacant post there's skill shortages across all sectors in places like Shelma of 100 per cent employment nearly although one thing I think all of in common is difficulty to recruit to the planning service jobs so I think we're all really struggling to see how the benefit I suppose of these action areas how they tie on time with the regional spatial strategies and the links into the local development plan and to give you an example you know Orkney and western islands could possibly fit them more comfortably into the northeast transition area while we're looking at actively planning a just transition from oil and gas to a net zero future so we're thinking about the future of Solon Vogue here in Shetland or Scat of Low in Orkney and it really maybe ties more into what we're what's the national planning framework is trying to achieve in the northeast of the Aberdeen area so I think although the action areas look very good and they sound good I do worry they create a lack of certainty when we get down to local development plan level local authority level and this has been highlighted before we could make development management decisions particularly difficult thank you thanks very much and paul you want to come back in yeah I mean I think in terms of that eating it probably just quite nicely into the next two questions I've got and you can you just touch on that one one is the local authority planning departments have sufficient suitably qualified staff and funding to deliver the desired NPF for outcomes and I think I know what the answer is going to be from this and I can see the right smiles already in this so there will probably be a few people to answer this and also how can we then best attract people into the profession in the coming years and I probably go to Jane first of all and then open it up probably to Stephen and then open it up to the floor is that but Jane probably herself as well obviously just been in the industry a certain period of time so I'll open that up yeah thank you um yeah I would echo much of Robbie Calvert's points that he raised in the second session um and that the rtpi have estimated some costs in terms of taking this forward um so they estimate that to undertake the core statutory functions of the planning system is going to require about 68 million over the next parliamentary term and whilst the this essential resource can be met with an increase of fees there's still 24 million that needs to be funded from the Scottish budget over this next parliamentary term this equates to approximately 40 net revenue increase for the planning system over the next five years but in terms of budgetary asks for the annual increase of local government block grants it would equate to just 0.01 percent of the total scottish budget um we do have additional duties we've got regional spatial strategies local place plans costing for that that the rtpi estimates about 3.7 million that that's with and that's with the parliamentary term and further in terms of actually getting people into the industry whilst the rtpi does a lot of work and the Scottish young planners network goes out to universities planning schools etc we do need to do a bit more work in that but there's also the charter town planner apprenticeship scheme which the rtpi estimate would cost about 10.4 million over the next parliamentary term and it's in this point i would like to develop a little bit more because the recent study showed that only around 9 percent of local authority staff are under 30 years old which means we're kind of top heavy as a profession and the replacement demand for that is particularly high given the number of members that they have here in scotland which is around about 2100 and we're looking at sort of need to replace sort of 500 600 planners over the next sort of 15 years which is ultimately like in a quarter of what we have and young planners want to deliver on the ambitions of the mpf for we think that the ambitions are there and largely a lot of the work needs to be done in terms of climate emergency etc however we do need a well resource system and we also need clarity in the mpf in order there are tools in order to deliver this that's great to get it down to numbers of very very helpful as steven head all wants to come in and also pam you in yeah thanks very much it's a it's a very pertinent question and i'm very pleased that the rtpi have led on this and providing research around the current state of the planning system work for for the local government point of view i mean the ressortiness the kind of the practically the existential question because in the last settlement we were of course delivered a 317 million pound real terms cut which has been ameliorated by 120 million pound adjustment recently which means that we're just a quarter of a billion pounds down or 50 pounds per person in scotland so in the local government in general is suffering a resourcing crisis and the planning system in particular is suffering a resourcing crisis both in terms of the ability to deliver the service and this is why we advocate moving quickly to full cost recovery in order to do that but also to develop the service because we have a recruitment problem in that we need to recruit over the next 10 to 15 years of order 700 new entrants into the sector and they don't get trained overnight this is a number of years to become a skilled planner and also because of the impact of NPF4 in refocusing priorities towards a just transition to net zero we're going to require to re-skill the workforce in general so yeah absolutely the resource implications to this process must be considered as part of the impact of the framework. The book of recovery is you know it's part of the solution but it's not necessarily the solution we need to understand in a more holistic form how the planning service has to be resourced and indeed this is something that's a major topic regularly at the high level group on planning performance which I co-chair with the minister and our colleagues in hops and RTPI are represented. Thank you Stephen and Pam and then Craig. Thank you a very pertinent point indeed in terms of resources and are we resource to deliver the intentions and aspirations of NPF. We have a proposed application fee or statutory fee coming forward as hops understands and that will very much be welcomed by hops however this is likely to fall very much short of full cost recovery that has been sought by heads of planning for over a decade now and that's compounded by the reduction of a third of planning staff since 2019 and over the same period in real terms a budget reduction of 43 percent and with a demand that Jane and Council Herald have talked about of 400 planners forecast needed into the sector in the medium term it's really difficult to imagine how the planning system and planning authorities can deliver the government's NPF for aspirations without full cost recovery and proper resourcing and there's perhaps never been a more exciting time to be a planner and working in the planning system but the flip side of that is there's never been a more important time to get that proper resourcing in place. When we look at the draft we've talked about some of the complexities this morning of the draft NPF and when you look at those complexities that requires additional work for planning authorities it requires additional work for promoters of sites as well you know it's not just planning authorities or planners working in local government and that's on top of the 49 union funded duties that came to planning authorities through the 2019 act so on the ground and the front seat of planning and local authorities and others working across the system we need to be able to resource that work and we also need to be able to upskill in terms of the talent we've got and the skill set that we have. I would like to just bring in that this is a fundamental issue for heads of planning and we've been having the discussion there's two aspects there's the money side and we've been having the discussions with the minister on that and there's also the people side this gap as a profession and you question related to both. I'm pleased to say that heads of planning recently very recently it commenced to study on future planners through with the Royal Town Planning Institute and supported by Scottish government and that's looking at recruitment it's looking at retention and it's looking at the promotion of planning as a career in planning authorities and those are the challenges that need to be addressed but there's opportunities that need to be created as well. So as chair of hops I really can't stress enough the critical need to properly resource planning authorities and that's now it's not in three seven years time or wait for to wait another decade the planning fees that are proposed to come forward is actually addressing a backlog of resourcing issues and what we want to look forward to is how do we help implement mpf4 as the government intends to do. Thank you Pam it's good to hear you say that it is an exciting time I think that that's absolutely true to come into planning and I would encourage many young people because it is such a critical critical role and Craig would like to come in. Just I suppose drilling it down some more practical level of what we are required to do one of the driving forces of the changes to the planning system is about getting the community involved in it that's been touched on earlier the local place plans the local place plans are to be done by the local communities with assistance of the planning authority is the way that that's been shaped up so in the south Easter we have 29 community councils so each of them could bring forward a local place plan with the expectation that the planning authority would be able to help them and bring that plan forward and we would need to incorporate that plan into our own on-going workload of our own for the our own local development plan which would come in we will be looking to prepare at the same time following the NPF4 coming through so just on a simple basis in the moment we are preparing a our policy sessions are set up to prepare a local development plan this an additional task will be potentially unless in all would but potentially could have the supporting sort of 29 communities and of varying degrees of abilities and expertise and resource in the preparations of their own plans that's really where we would want to do that as much as we could that the communities are a hugely important part of the whole process but that needs to be resourced that's bodies on the ground and I suppose supporting from there and that's the sharp end if you like of the big statements about resources and bodies that are required it's for tasks like that which are completely new tasks to the system from there thank you chair thank you craig that that was great you actually have answered some questions i've been wondering about you know that level of detail is very helpful and i know how much it takes because i've been involved in my own communities not local place band but a kind of local planning initiative i'm going to move on and bring in graham day with questions thank you community i think this is specifically in the first instance addressed at palm you and hopes in written evidence had suggested that to deliver on the ambitions of mpf4 it would require a significant culture change i wonder if palm you and could expand on that and perhaps touch on whether she thinks a culture change might extend to perhaps the attitude of councils towards planning because i think there's a reference a few moments ago to budgets having been cut by 43 percent well such a budget cut would be well in excess of any budget change between in the settlement between the scottish government and councils i wonder if there needs to be an attitudinal change as well within councils towards the significance of planning as a service thank you thank you for your question i think we've talked about culture change across the planning system for many years and indeed that a lot of that change has has come through what i think is fundamentally important to this is is the role of planning is the role of the planning service in place leadership and involving and collaborating and working really closely with communities to help them have a bigger say than they've ever had about how their places should change and create a touched on the local place plans so there is that culture change to do that but there also needs to be a culture change in respect of how does any player involved in delivering the ambitions and the intentions of the national planning framework actually raise their game change how they design a place how they engage with the community and how they bring that forward to the local authority so i don't think this is just about local planning authorities or indeed councils i think it's about all the players that are involved in delivering great places across scotland and we shouldn't forget that we already deliver really good quality places across scotland there's lots and lots of development comes coming forward all the time is creating really good quality places but for hops what this MPF is really saying is let's make a step change in some areas let's go up a few gears i've touched earlier on climate and climate addressing climate change whether that's an absolute must that that must happen so i think there are a lot of things there about the cultural change and i've touched before about the skill set and the need to skill up up skill across many that are working within the planning system because it's not just planners we all will have lots of people in a council that are involved in the planning system whether that's education transportation waste health environmental health you know across a whole of these areas we'll have colleagues within our councils working working towards that and steven herl would like to come in as well yeah thanks mr day for that question and good to see you again you are suggesting that the planning services received a disproportionate cut that doesn't match with any cut that might have been directed towards local government but i mean i should note that this 42% figure is since 2009 so it's over a more than a decade and it also reflects the amplifying effect that the directed spend or the direction of spend from Scottish government has on the services where local government still has a degree of discretion i mean local government cuts any service where heavy heart and we would like to fund every service fully and we'd like to develop every service to provide better services for our population but the reality of the situation is that between 60 and 70% of all local government spend is directed by the Scottish government that leaves a very little discretion regarding the remaining 30% to 40% and of course the regrettably these services are the services that you're going to see experience in the the brunt of the cuts and i always say if anybody wants to know the effect of cutting the funding for local government look at the state year roads because that's a discretionary service and that's one of the areas where we regrettably have to cut the spend and absolutely where we don't want to cut the spend no this is a it's not a kind of matter of a culture change it's a matter of a change in attitude towards local government and the funding local government to allow us to adequately fund our services and this is especially in the time when we're trying to deliver a complete transformation of the world that we live in and moving towards net net zero the idea that we can achieve this transformation while receiving a quarter a billion pound cut to local government is optimistic to say the least and we really need to get real as far as the funding of local government is concerned if we want to be able to deliver the step changes that we all want and we all have to achieve thanks mr headall you want to come in with more okay i'm going to move on now and bring in paul no sorry bring in mark griffin who's joining us on blue jeans mark we'd like to come in with your question yeah thanks camera good morning quite a lot quite a few of the witnesses have touched on the ambitious nature of the mpf4 draft i'm i just wondering what people's views were on whether that needs to be accompanied by a capital investment plan to realize those ambitions and perhaps come to palm first thank you absolutely i've touched on already that heza planning were disappointed that there wasn't a draft delivery plan published alongside the draft mpf4 to to really allow us to have that thorough debate we understand that scotish futures trust is taking forward that work and we've reached out to them to work collaboratively with them to to look at that in detail but it has to be delivered infrastructure first is one of the things that comes through the draft document and timious delivery of infrastructure is really fundamental if we're going to deliver the strategy a funding mechanism that provides upfront infrastructure is needed whether that's new school capacity local energy systems green networks walking cycling ways whatever it is and in particular in areas of lower land values so the mpf has a much a much much more of a focus much more of a direction in terms of the redevelopment within our town centres and brownfield sites but where those sites aren't viable commercially to bring forward then where is the capital programme that allows public sector to come in and intervene to so those sites are delivered for the benefit of of those communities and it's important that a capital programme looks across other plans and strategies when any fact mpf4 should be the spatial expression of scotish government policy and direction and should be very clearly linked to other plans and strategies some of which will need to be updated because they're not quite aligning with this so the capital programme is absolutely essential i would also just raise though it's not just about capital it's also about you know understanding what the revenue i'll use the word consequences lightly but the revenue consequences of new development and growth and the pressure that puts on local councils so it's actually understanding both the capital and revenue implications of the mpf4 and setting out clearly how that is going to be driven forward and i think there are good examples there's good examples in england just now there's a lot of debate in england there's really paralleling this but beside that they're driving forward a capital programme and as i understand similar work has been done in ireland so we would very much call for we've got to understand how this plan can be delivered i always say writing a policy document probably doesn't feel like like this the chief planner writing a policy document is the easy bit actually delivering it is the hard bit and the capital is essential to that thanks pam and i see that craig and david also want to come in on this question around capital investment plans thank you chair yeah the sorry and answer the question yeah i think it's really important in ayrshire and not just south ayrshire but all of ayrshire we have infrastructure problems with the transport network in terms of the roads and that really needs investment to be able to take that forward however it's not mentioned in mpf4 and it's also not mentioned in another consultation document which is on going at the moment the strategic transport project too and as you'll be aware for funding to be brought through for these matters they need to have a policy basis for them to be justified at that stage when they're coming through so there's real there isn't that connection between the real issues on the ground perhaps in the wider areas and outside the central belt from the document which needs to be reflected and that's where it comes back to there's an absolute must for that capital investment plan to help drive the projects on the plan forward that infrastructure first is a it's an appropriate way to go forward however the developers of the house builders don't have the the finance behind them to be able to fund those things up front they require investment from central and local government to be able to take that forward to do those works to take it on thank you chair thank you and david thank you convener so i suppose just to pick up on two points i would echo craig's point on on stpr2 and i think the importance of weaving that as with other strategies that we mentioned earlier through the document to give it this sort of policy support in terms of as applications come forward for for those developments but i think just going back to the earlier point about infrastructure in relation for example to brownfield development historically Aberdeen has got a very limited supply of brownfield in comparison to other areas of scotland and our land values have historically been been much higher albeit i would say in recent years that that has probably changed but we've had to put a number of initiatives in place to encourage the development of both brownfield and i suppose the other challenge that we would have being some of our historic buildings which are difficult to get back into use but particularly in the city centre to try to encourage their reuse for for residential again reflecting some of the direction of the new mpf but to give some some examples we have a 25 percent affordable housing requirement right across our administrative area but we have waived that requirement for development within the city centre to try and encourage and support developers who want to use those buildings or those sites and then on top of that we've looked at the development viability on a case by case basis and waived other developer obligations where required but i think the important point and it goes back to the the sort of infrastructure delivery is that fundamentally those costs don't disappear you know the costs from those for those schools for that other infrastructure it doesn't disappear it just falls on the public purse to to pick it up at local government in the first instance so i think is palm mentioned earlier i think a delivery plan to actually look at this the proposals and the policies within mpf for and actually allow parliament to make a considered decision on those policies in terms of what the likely implication is at a local and national level in terms of funding so i would echo the point that i think the delivery plan is vital but i think we also need to to look at some of the policies in the round as well thank you thanks very much david i'm going to move on and bring in miggan gallower with her question thank you convener and good morning panel before i ask any question this morning i would like to refer members to my register of interests as i am still a serving councillor in north lannogshire and i would like to touch on 20 minute neighbourhoods this morning as they are a significant feature and they run throughout all sections of the mpf for document so i'd like to ask the panel how do you think 20 minute neighbourhoods can be delivered in practice and particularly in relation to rural areas as i know that a couple of contributions from you have indicated that this might be quite problematic and if i could start with craig please and then Pam thank you thanks chair i think 20 minute neighbourhoods are basically good planning and i think that is what is about us but bringing forward the appropriate development in the right location and i think for me the brownfield developments are vital for us to be able to if we can get them brought forward that will by the very nature of them they are probably located in a a within a settlement and within a reasonable distance from other facilities because they've probably been a factory or whatever in the past and so for me that's about bringing those elements back into it but essentially it's about good planning it's about that linkages of the the transport is a vital thing we haven't quite touched on that this morning but the sustainable transport is a is a huge factor in being able to make the good neighbourhoods work and from there and i think the essence of i think all the planners who've probably read the 20 minute neighbourhood idea i thought yeah that's just good planning and i'd like to i'd really stop at that before i ramble on to other things thanks chair thanks and then Pam and and also it would be great to hear from ian on this from you know shetland perspective as well thank you yes i mean just building on what craig talked over in 20 minute neighbourhoods is not a new concept as a planner we have been working on that for a long number of years and it is good planning the challenge comes and this is really what's at the essence of your question the challenge comes on you can't just apply that across ross scotland i think what has been sought to try and be achieved through the draft mpf is writing it in such a way that it is flexible to apply at the local level because all our places are different so the concept and the theory of 20 minute neighbourhoods is laudable and has been in planning practice for a long long time the challenge comes in the difficulty to deliver and sometimes that's about the reality of whether it's delivering a shop in a community that doesn't have one well that actually gets the heart of behavioural changes society in the way we look leader lives and it's a chicken and egg if we don't create the places that encourage people to walk more to shop more local and to live local which is the theme that's coming through npf then how do we start to really fundamentally address address those changes but in some areas that might come back to that requires public investment public incentives to make those the components that are some of the components of a 20 minute neighbourhood actually deliverable so the theory and the concept wholeheartedly has a planning support it but i think we need to really work through how do you deliver that in rural areas and also how do you retrofit it i think often these discussions are about how do we apply npf for looking forward when new development proposals come to us but that's only a very very small part of scotland's land use change a very minor part of scotland's land use change but how do we retrofit and what's the role for public sector in bolstering and creating 20 minute neighbourhoods thanks pam that's great that you're bringing in the whole retrofitting part because that seems to get missed off on the conversation and that's critical i think for our way forward ianna i don't know if you would like to come in with a scotland perspective that would be great yes thank you yeah i'm the bane of our lives that the the phrase 20 minute neighbourhoods came in if i've had a pound for every time someone says it takes me 23 minutes to walk around that you know it's like no it's not about the number of minutes really it's about the concept but it's catchy and it catches people's attention and that's because that's important too i know discussing 20 minute neighbourhoods with my colleagues in the western isles and i know that they do have a concern about the relevance to rural and island communities i kind of look back at the the bit we're talking about earlier about the area actions action areas and the spatial strategy and it does talk in there about island and coastal communities and we need a bespoke and flexible approach to the concept of 20 minute neighbourhoods for example by identifying service hubs in key locations with good public transport links point that craig was making earlier on and i think you know that flexible approach is something that we've been doing you know we need to adapt the 20 minute neighbourhoods to our particular circumstances i also would echo the points that palm and crane make earlier that planners have been doing this kind of thing for a long time and in shetland we've been working to these principles but why their names and our local development plan as it exists at the moment we have zones that prefer development and which aims to be a lot of what's in the 20 minute neighbourhood concept we've got the nav redevelopment site which is actually mentioned in the npf as well and that's an on-the-ground example of how we're trying to implement these kind of policies about living locally so i do think developing for communities and not commuters is applicable to every part of scotland and not just on urban context thanks thank you for that it's good to hear that perspective i'm going to move on to a topic minimum all tenure housing land requirement so and i think i'll start with pam and then bring in sarah on this initially so how do you think the minimum all tenure housing land requirement will work in practice is it clear enough and will it direct new developments to where they are needed and a supplementary that's kind of come up through evidence sessions is do we need to be rethinking how we do housing in scotland in general so pam thank you when i think firstly heads of planning welcomes the concept of quality homes and supports the move to more flexibly for a more flexible and locally based approach to the minimum all tenure housing land requirement housing land requirement is always a key debate whether it be through national planning framework structure strategic plans of the past and local development plans but councils and local elected members know their area best and this allows for local consideration as to whether and where those minimum targets should be increased so through the local development plan process and working corporately across the council councils will give constatial consideration as to whether those minimum targets should be increased to meet the needs within those areas they may look at it from a policy approach perspective of for instance a particular town centre or more flexibility around if there's particular elements of brownfield land they want to see coming forward so heads of planning is comfortable with the approach that the Scottish government have taken they have involved planning authorities and who have worked closely with housing colleagues in councils on the approach that they have they have taken so we support and principle the approach that's been taken in national planning framework in terms of your question about does this approach of the minimum tenure direct housing to the areas I mean that needs to be looked at in the round because that will we have to look at what the other policies are of the national planning framework I've mentioned brownfield I've mentioned town centres but there will be appropriate greenfield sites that will need to come forward as well where those are sustainable and it's about ensuring that there's a there's the depth of choice of sites and quantity of sites that are deliverable and either have the necessary infrastructure available or that there is a programme there to we've talked about infrastructure first a programme there to bring that infrastructure forward so we're comfortable the sets of planning with the approach that's set out in national planning framework for and we think that we can take that forward across all of our local development plans and gives that local flexibility to the elected members to making the decisions on those local development plans that actually know their local areas best. Thanks very much and Sarah I don't know if you want to come in on on that as well. I think from a Glasgow perspective specifically we felt there could have been an opportunity to be maybe potentially more overt about whether we want particular existing trends in terms of housing investment to continue within Scotland or whether there was an opportunity to be more overt about trying to rebalance that. There's certainly a description about you know there's a prediction that the housing requirement in the west in the east of Scotland would be much stronger and that's reflected in the housing land figures that's given in NPF4. I think we felt that there could be an opportunity for this to be to be determined more locally at the at the city region level. Potentially there could be an opportunity to rebalance and to try and attract further housing or to push further housing investment towards the west of Scotland again picking up the vacant and derelict land and the capital investment that would be needed to to do that but this could be actually an ambition of NPF4 to do that and I think we feel that the potentially policy the policy nine to do with the the housing land tenure requirements would be is potentially not it's a very complex area it's about in a very dynamic area and potentially it doesn't that policy doesn't really convey that complexity and there are certain elements as well that are possibly still it could be defined more more precisely for example whether the land requirement in NPF4 means land for a certain number of houses or for a certain number of houses to be delivered so there'll be a bit of debate about that because again this is the sort of thing that ends up in appeals and court cases and potentially again there's some definitions within the policy which talk about short medium and long term deliverable housing land pipelines again there isn't a definition of that and I think we will need some further clarification so again this doesn't end up getting scrutinised in in courts and appeals and that we all know what we're talking about there. Thanks very much for that that's good to get the Glasgow west coast perspective. I'm going to move on and bring in my colleague Willie Coffey who's joining us virtually. Thanks Gideoners good morning to the to the panel I want to develop a discussion a wee bit on how and whether NPF4 deals with vacant derelict land that Sarah mentioned just a moment ago but also derelict in abandoned and dirty filthy shops that blight their high streets. We've got a lot of good work going on in a lot of town centres across Scotland where communities and councils doing a lot of work to improve areas and towns that we can do but many of my constituents often tell me what can we possibly do about the extent of the empty and abandoned shops that blight the high street that are principally well and mainly privately owned. So my question maybe to Sarah first to admire her colleague Craig Isles is what can we do about this should NPF4 strengthen those powers or do you think that there are sufficient powers at the moment on the planning laws in terms of immunity notices to deal with issues like this. So it'd be obliged initially for Sarah and maybe Craig's response to that please. A couple of aspects to this firstly I suppose is partly there's an aspiration in NPF4 and I think across Scottish planning authorities to actually bring more residential uses into town centres so there is a possibility there of repurposing some of these vacant sites. Again that does depend rather on the market and I think what you're talking about is more of a direct and the council do something directly to influence this in terms of enforcement talking about immunity notices. One of the issues is that the councils do have powers of direct action to serve immunity notices in various situations but the problem is they don't have a budget often to do that direct action because then it has to be the costs of that action have to be clawed back from the owner of the property and that's not always very practical. So there are issues practical issues there about the councils taking direct action it's not necessarily so much about giving them legislative powers it's partly about giving them the resources to do that but I think also I think the whole concept of repurposing the town centres to make it much more multifunctional less focus on purely retail for example and will help hopefully help and that there are practical issues obviously in converting shops to housing and that's not always going to be possible but that kind of aim will certainly help towards it. There is a mention I think in the NPF about you know this idea of bringing city centre or town centre living to be more focused and I think there was a policy saying that you know shopfronts or frontages residential frontages ought to be active still active frontages and I think that's really important in a town centre and similarly it's also important for retail and other uses in the town centre to have active frontages and I think we need to make that clear as well. Thanks Sarah and who's the other sorry for willy or craig yeah craig and then also Cal and Lindsay would like to come in on this and then we'll move on. Thank you chair. Mr Coffey raised a very pertinent point there are certain challenges and we all want to see we know how our high streets are changing due to the Covid and the online shopping and such like and how retailers are reducing their footprint in the high street. That does lead the problem of how we then tackle that going forward and purely from a point of view of the from an enforcement side if you like I think the amenity notices are limited in what they can do in terms of dealing with a shopfront that may be dirty vandalised and perhaps because some you know you can see in and see all the mess of it inside there's very limited you can do from an amenity point of view to from the planning process to deal with that. The other side of it is when you move on to the more extreme situations of vacant and derelict buildings and in south here so we have a very prominent one in the station of hotel I'm sure the member will be aware of that and where we have an absent landlord he's not a British national and it's a very difficult process to try and engage with that individual and he doesn't wish to engage with the council and trying to resolve the issues there and we'll have a dangerous building issue there which is costing the council in terms of making that building safe for the public. So when you follow that through that the process is there for the council to actually act on these things there's a notion that we could use our compulsory purchase powers well to do something of that we have to have a master plan to take it forward which obviously is time and resource to be able to take that matter on we also have to as part of the legislation you have to require to have the funding available to be able to carry out that master plan now obviously the as has been discussed this morning councils have limited resources in terms of these matters and to take them forward so that's where the real challenge comes in and that's perhaps where funding comes from central government innovation to vacant and derelict land should perhaps look at that and there may be a need to look at the legislation in terms of the compulsory purchase powers a number of these and stepping away from the larger scale projects like that the the short units and such like will be owned by investment companies who will have no interest at all in those high streets they're merely a line on their balance sheets from there and actually getting them to do anything with these buildings is very very difficult and the conversion of those buildings into other things and probably because of the nature of how they've been built as a shop makes it very difficult to change them into other things so if we're reinventing the whole process here I think the compulsory purchase process is something that really needs to be looked at and investment put into that whole deal with vacant buildings vacant and derelict land if it's back into the previous question in 20 minute neighbourhoods the all the things that a 20 minute neighbourhood has are all in our town centres and in our local communities at the moment you know if you're doing up your burnfield sites in your vacant and derelict buildings you're already fitting back into retrofitting into those areas and I think that's an area that should really be explored further. I'm going to bring in Calum and then we'll move on to questions from Miles Briggs. Thank you convener my are in chat box with that same relation to the previous point on minimum all tenure housing land requirements and if I could just very quickly flag the point I know we're pressed for time and this is an example of where timing has been quite tricky particularly for coswood foam firm position and it's an area that our members have flagged some concerns mainly about the principle of target setting for local government however we've also seen today that hops are quite supportive of what's been put forward and unfortunately we've not been able to to put that position of hops to our members to offer them the reassurance and with different timing we may have been able to present a firmer position so just to flag that to you. On the members question of vacant and derelict land I would support everything that hops have said today and it can often be about resources and uses as much about resources as led to little powers and things like the regenerates capital grant funds have given us good examples of what can be done when the capital is there to address examples of vacant and derelict land. I think it's also an example of where stronger policies could and strengthen the wording of some of the policies could be beneficial too to go back to that point made at the very beginning I think it's policy 30 which seeks to address this area and we feel strong wording there could give local authorities better tools in order to deliver the ambition of the framework thank you. Thanks very much and good to hear from you this morning so we haven't gotten you in sooner in the conversation I'm going to bring in Miles for questions. Thank you convener good morning to the panel thanks for joining us this morning and we've already touched upon infrastructure and I wanted to ask specifically with regards to the draft with MPF4 which states that we want an infrastructure first approach to be embedded in Scotland's planning system so I wanted to ask the panel specifically what should an infrastructure first approach look like and do you think that the MPF4 in its current draft can help achieve that and so I'll maybe bring in Pam and then if anyone else wants to comment on that could you put an R in the chat thanks thank you well I've already expressed heads of planning view that we consider that infrastructure first approach is really essential and actually we've been talking about this for a long long long time and we often look to mainland europe to look at the examples there of really good examples and of course there are examples across our own country as well but where is particularly fundamental and I think coming out through the discussions this morning it's not necessarily about having the legislation or the statute in place what's missing in a lot of this is where's the funding where's the actual the capital resource and often the revenue resource in terms of having the people behind those projects but where's those upping of those resources to deliver in our town centres to bring forward those brown field sites and where you have large growth areas I know that in my role as head of planning in five council where you have these large growth areas it's the funding streams to sometimes it's about a timing gap you know and it's about actually making sure a development that's coming forward is viable and sometimes a new school needs to be delivered a very early stage because of capacity issues or a particular piece of transport infrastructure so it's really thinking through an early stage an NPF what is the NPF saying what is it directing and where's the capital programme behind that that is going to deliver that infrastructure first programme and what we've touched on today is it doesn't sit in isolation it's a strategic transport policy review it's about the economic review it's about local heat and energy strategies it's all of those bits of the jigsaw as I often think about it how do those all knit together to deliver a place in a timious way and in a way which gives the best opportunity to create a quality place for our communities thanks Pam Stephen would like to comment in as well thank you very much I think Pam's essentially made the point house is about to make that the inunderstand and what would form an infrastructure first approach we need to understand what are the infrastructure requirements and investments associated with the other plans and strategies that we wish the NPF for to align to and we have good alignment with some strategies the kind of the drive towards net zero has been mentioned but the specific example that Pam raised about the heat and building strategy I mean we believe that decarbonising heating buildings is going to cost approximately four billion pounds you know to achieve that I mean that that's clearly a fundamental part but we're moved towards the net zero and understanding the infrastructure investment that's going to be associated with that and dialing that into the the NPF for this you know just just one example of the cut across to other strategies that we probably feel needs to be be strengthened more the I mean STPR2 has been mentioned I mean it's mentioned the 10 times throughout the document the natural transport strategy it's mentioned eight times throughout the document so that's great there's some kind of recognition of these strategies but the heat and buildings gets no mention and indeed the national strategy for economic transformation which we are eagerly awaiting at the end of this month and it's going to be fundamental for direct and policy it's not mentioned and indeed the programme for government is going to be fundamental for this as well so it's more a question than an answer it's how do we assure the adequate mapping of the strategies that's driving our investment and our public policy and make sure that it's coherent with the NPF for. Thanks Stephen and Craig would like to come in but I just wonder Mars do you want to develop your question a little bit more please thank you convenient I wanted to drill down a bit specifically into some of the competing pressures of competing strategic outcomes and specifically I suppose to look at renewable energy we know the targets which the country set itself for the production of renewable energy so I just wondered in terms of your council areas as well whether or not you think NPF4 as it currently is drafted will help deliver that renewable energy and some of the competing demands we know exist around for example restoration of peatlands how will that be taken into consideration so quite a wide question but I wanted to sort of look at through the world of renewables how NPF4 will meet those targets. So Craig I don't know if you want to come in and pick that up if renewables is relevant to your part of the world in South Ayrshire I think it is and peatland probably too. Yes thank you if I can just at one point on the previous element there I was just to mention that on the delivery of infrastructure house developers don't have the fund and the finance behind them to pay for these things up front they are required to pay for it on a sort of cash flow basis as we are selling our houses so that's just why we need that sort of central funding for the delivery of these matters in terms of how it fits into renewables and does NPF4 do anything for renewables I think South Ayrshire and East Ayrshire in the recent gallery of all varies significantly in terms of land resource for renewable energies and our areas are under significant pressure from those in the communities in those areas are tolerating a great deal in relation to the wind farms which are getting larger and taller by the the weak applications that are coming in I think there is the as far as I understand infrastructure has been put in place for delivery of these matters there's certainly enough areas for the wind farms to be brought through and I know there's a huge amount of Scotland's renewable energy comes from that's a certain Scotland area that covers those two authorities I think there is opportunities through the those wind farm applications for peatland restoration projects in and about the areas there and they tend to be in those localities where they do have peat areas which have been degradated over the years by the famine techniques and such like I think that's something that can be should be brought forward as a benefit for those schemes and there should be some realm across funding for those wider areas for the address of the drainage issues and such like which drain out those peats and make them less effective as carbon sinks and I think that's it's not having been involved in it when I was in East Ayrshire it's not that complicated it just requires a wee bit of resource and and taking it forward and agreement of landowners to take these things forward so it's definitely deliverable there and I think that's something that could be that should be promoted thank you chair hopefully that answers the question thank you craig and I'm just wondering if anyone else maybe Ian would you like to come in on this renewable piece that Mars has asked about yes and thank you yes an interesting one is that we've got a very large wind farm being constructed at the moment in shetland a lot of local opposition to it and one of the issues was the impact on peat you know does the was the energy or does the carbon emissions from the peat that has removed outweigh the benefit of the wind farm in terms of renewable energy and it's still raising still raising issues on a daily basis here I think the policy itself as it said in national planning frame it does give the right direction and as always with planning it's going to be about that balance and I don't think you can actually say one development is definitely okay and one isn't based on this policy it's when you get into the nitty gritty of the environmental impact assessments for example that you know we will be able to focus in on whether the development is acceptable or not I do think there are some parts of that policy that are maybe a bit too open ended for example one of the one of the bullet points in there is supporting a fragile population in a rural or island area that's fairly open ended and I could I could see you could justify a whole range of developments on peatland areas using that that bullet point alone so possibly needs to be a bit of fine tuning in there but I think it's definitely pointing the development in the right direction and highlighting the need to protect peatland carbon rich soils and habitats and as Craig said a lot of it and what I'm seeing at the Viking energy development is the equality of the restoration of the site is an important factor and that's something that's you know assessed and developed through the planning conditions and monitoring of the development thanks thank you Ian and I'm just going to come back to miles for another question thank you can be just just finally in terms of national planning framework being the opportunity to to really ask in demand of all councils really that that we meet these targets do you feel it's going to help you achieve that I suppose is my key question because I think some of the more difficult and challenging points we'll see for example the production of larger scale larger size wind turbines is something many communities will come to yourselves with objections in but meeting the targets which we've set out in terms of renewable energy is really being put to planning departments so I suppose turning that question round is do you then feel you'll have the tools to be able to to help deliver that and and across Scotland that's a national mission which this is going to be tasking planning departments to achieve and what would you like to see to to make that process easier and we know that a lot of these applications end up being called in by the Scottish government because of some of these challenges so I just wondered where your views were whether or not this planning framework has helped to make that easier or more difficult for yourselves I see that Jane would like to come in on that question thanks convener it was more in relation to the last question but also kind of in terms of the targets as well I know there's been a lot of focus in the conversation thus far on wind but I think from my environmental management background I think it's primarily about a mix and that's a mix of types and a mix of scales decentralising a lot of our energy to like neighbourhood or district level through either heat and power and heat pumps etc there's a variety of ways that we can meet these targets and I just it's not all about wind although that is one part of it certainly thank you Jane and Pam I'd like to come in on Miles's follow-up question thank you thank you for my heads of planning perspective we've also looked at there's a lot of consultations from government just now all largely coming out at the same time and one of the ones that we have looked at was around the the wind strategy and the ambition of government perhaps national planning framework needs to provide a bit more evidence I haven't seen it there of what is the capacity of Scotland to accommodate that level of wind turbines that's been seen as the aspiration and the target set out and there's been a lot of work done over the years looking at that so you know it's really that what's the capacity of the country and what's what's the target and actually what we don't know planning authorities just now is do the two equate there has been a lot of work done over previous years looking at landscape capacity and some areas of Scotland were saying you know they felt as if they were at capacity from a councils perspective and a planning authorities perspective so I think there's a real dialogue here in terms of in terms of the way in which we want these developments to come forward but you know touching on Jane's point is so much more than wind turbines are certainly new wind farms and should be put more into the kind of repowering of existing existing wind farms that are already consented and just need to be looked at in a different way but energy storage and looking at a whole range the local heat energy systems that's really coming through the NPF and also the related consultation in order that's been drafted on that so all of these things are coming together and what we need to understand is how does that relate to place at different scales where it's at the national level, a city region level, a local and a community level so it's quite a complex area but I do think that the NPF could have more evidence behind it when you specifically talk about wind turbines and the capacity of the country to accommodate the ambitions that has been set out out with the NPF. Thank you for that response Pam and I see that Craig and also David would like to come in on this. Thank you chair. I think that the drive of this policy and the NPF-4 is about providing more renewable energies and such like that is a very positive thing. I think that it is just proportionally the weight of that is just proportionally felt by certain councils in the more rural areas such as ourselves in the Aershires and the Freeson Galloway and the South Lanarkshire from there. I think that the key thing for us and this ties back into a point that was discussed on earlier on about the plans and things that are missing from the plans. We have the UNESCO biosphere, the Galloway and South Aershires, UNESCO biosphere and it's not mentioned at all on NPF-4 and that's a really important thing for us for tourism and from an ecological point of view as well to support that. How that ties into the provision of windfarms and renewable energy in those areas because there's a lot of overlap is a real challenge and that's something that we'd like to see the most significance on in the document. In terms of how it impacts on the resources for ourselves, when we get a windfarm application in and if the larger size are dealt with by the energy consent unit, so we are a consultee on that process, there's a huge amount of resource for ourselves and if we object to that it then goes to public inquiry which can take one of our officers out of the process for a considerable number of weeks in terms of dealing with that public inquiry and it usually comes down to the landscape impact, the impact on local properties in the areas of the windfarm. The overarching element, yes, we're keen to see renewable energy where the net zero drive in saving the planet is a huge factor probably and everybody believes in it as an important thing but I'm not sure that it's necessarily shared across the burden on that, it's shared across the entire country from there. I think that's what I'd like to see in that. Thanks, chair. Thank you Craig and thank you for bringing in the UNESCO biospheres and that's really important to make a note of that. David and then Ian. Actually before you go David I just want to note that we are going to run over time a little bit and I'm going to let it go to 11.15 and try to stop us at that point. Clearly we've got a lot to discuss here so David. Thank you convener and absolutely I respect the timings. I suppose just to pick up on Craig's last point which I think ties in very nicely with what Jane mentioned earlier and that's the sort of the heavy lifting that many of the rural authorities have to do in order to supply renewable energy to the country and I think there's equally a role in urban areas like my own to try and decarbonise the heat that we use, decarbonise the energy that we use so I suppose going back to Stephen's earlier point about the low carbon heat guidance which has been worked on for some time and the lack of perhaps reference to that in national planning framework 4 I think that can have a huge impact on trying to take some of the carbon out of the energy that we use particularly within our urban areas. We are fortunate to have three heat networks across the city, one run by the council but one run by the NHS and another by the university but we need the sort of support and MPF4 could form part of that to really scale those up and I think there's a real opportunity there. I think the other point that I just wanted to highlight was around hydrogen and hydrogen is mentioned several times throughout the document and it's very welcome to see that and I think it's going to be an important factor in our decarbonisation journey not just green hydrogen but also other forms of less clean hydrogen as we move to net zero but I think it's interesting that while there's I think 22 references to hydrogen throughout the document when you get to the green energy policy there's only one reference to it and that's in the preamble. There's nothing actually referenced in terms of the policies themselves where there is lots of reference to wind, solar, carbon capture and storage and so forth but that in and of itself puts the pressure on rural authorities to carry that burden you know and where hydrogen can be and is being developed in more urban areas. There's certainly opportunities to expand that further as we are doing with BP and the hopeful connection to offshore renewables. So yeah I would just encourage a wider use of or a wider reference to hydrogen and to heat networks throughout the document. Thank you. Thanks very much David it's helpful to get your specific scenarios in Aberdeen. I'm going to bring in Ian and then I'm going to move on with a couple of closing questions. I'm going to just to highlight the role of NPF and that only really covers development that comes under the planning acts and that's me why there's such a focus on onshore wind. So it does actually miss out on things like offshore wind, tidal and wave power. Getting the highlights at the point that we were making earlier and we need to tie up with other plans and strategies for example a national marine plan and make sure that these things are actually knitted together. Thanks. Thank you for that and thanks for being so succinct with that response. I'm going to just come in with another question that's around land assembly. Witnesses including Planning Democracy and the Scottish Land Commission have argued that NPF four goals can only be delivered if the public sector takes a far more proactive role in land assembly and development. Do you agree with this and if so what needs to change for this to happen and I'm not quite sure who to direct that to maybe just somebody put an hour in the chat if you've got a response on that and I'll take a couple of responses. Thanks. Okay Pam, thank you. Sorry if you start again you weren't on yet. I think we've touched on this throughout our discussion this morning particularly when we've talked about brownfield sites or sites within town centres as some focus of our discussion and that's where any areas of low land value basically where it's not commercially viable to bring forward a site or where the risks are too high to a commercial you know to a business then later scale come in to drive forward those sites and whether that is assembling land, whether that's giving confidence to a developer to pick up a site that has the infrastructure already there that's decontaminated or whatever the issues are with that site. Sometimes that could be about the public sector doing the physical works. Sometimes that might be about just financially assisting the private sector to go in and do those works so I think there are different ways of achieving it but what I think has come out this morning and in other sessions that you've had is that there needs to be to get that scale of ambition to bring forward at large brownfield redevelopment and the repurposing of sites we will need public funding. Thank you very much for that and I'll just also note that Craig said earlier with that kind of power you need a plan and then you need time and resources. I'm going to also move on just with a kind of closing question to see if there's any other specific improvements you think that could be made to the draft that have not already been highlighted in this session or in your written submissions. I know we've covered a lot but just in case there's something that you really want to tell us today and you can put an R in the chat for that and I'm going to bring in Jane. Thanks, convener. It was just to kind of go back to the renewables but also just as a concept that's missing throughout a lot of the policy. Arguably this is with my day job pattern and that would be cross boundary issues so when you're talking about large scale wind farms there's going to be some cross boundary issues there. Anything that's got a network in it will have probably most likely cross boundary issues there. This is a position for RSSs and I just think there needs to be a little bit more of that in there because things don't necessarily always happen within a local authority-bounded area. Thank you very much for that, that's a pretty crucial point. Pam, would you like to come in, Ian and then Craig? Two very brief points. The first one that we haven't touched on today is Hopps considers that there's a missing part of the NPF draft which should set out the economic and population characteristics to 2045 so that the strategy can be seen in its wider and fuller context. The second point relates to perhaps a more technical aspect about how it's actually going to work and that's the transitional arrangements. One of the other consultations on-going just now is about the local development plan regulations but certainly we want to be very clear about how those transitional arrangements will work to take us forward to the new style of local development plans sort of development plans with NPF and local development plans so I think that there is a bit of concern in local authorities about what is proposed as those transitional arrangements and we need to have certainty about how that's going to move forward. Thank you Pam and Ian. Hi, thank you, yes. I'm supposed to highlight policy 31 in rural places but I haven't really spent a lot of time discussing rural places in, for example, brownfield sites and urban development. One of the things that we're learning in the Western Isles and ourselves are particularly concerned about is the proposal to resettle previously uninhabited areas and I think the concerns of that is these uninhabited islands or remote areas that we have are very limited or no access to transport or schools or healthcare facilities, waste collection and digital connectivity, probably being conflict or potential to being conflict with policy 32 on natural places and also potential conflict in terms of protecting good quality land and how we conflict with 20 minute neighbourhoods and sustainable development when a lot of our good quality land is close to existing settlements. Also just to pick up on the fact that when we were talking about housing, things like developer contributions and 25% of development given over to affordable houses in places like Shetland, the only volume house builder is an association and therefore they are delivering on affordable houses by default. We just have to remember that there's not a one-size-fits-all approach to housing and housing types in 10 years and things like that when we're looking at the future of development in rural places. Thank you for the opportunity. Thank you very much Ian, that's very helpful and Craig. Good point for me. We haven't touched at all on national developments this morning and there's no, in the MPF3 we had the Presswick airport and the spaceport around it as a national development and it's disappeared from MPF4 and we don't know why. And it's an important time, we've got the spaceport coming through and it's not there. The other element is that I was once just to mention we have, in terms of the document, it makes reference to the Glasgow city deal and how important it is and then talks with the Ayrshire growth deal as if it's a secondary element serving the Glasgow area. Obviously we stand on two feet and we're important in that regard. Thank you, chair. Thank you very much for making those two important points absolutely take that on board. Is there anybody else for a close? Okay, so I just want to say thank you so much. I've had a lot of questions in my mind, we've been taking a lot of evidence and I feel at this session with all of you this morning has really helped actually fill in some gaps and I'm sure that my colleagues have found it a very useful session too. So with that I'm going to say thank you and we are going to move into private.