 Richard McMillan, rwy'n dden nhw'n i siarad ar i ddechrau'r cyfliniedscolau Sex slaughter. Thank you so much and welcome to meh to the fifth meeting of the Net Zero Energy Transport committee for 2022. This week we are conducting a meeting in hybrid format with some members in the Room and others attending remotely. At agenda item one we have consideration of whether to take agenda item 4 in private. Item 4 is consideration of today's evidence. of evidence on the draft of the Scottish Government's fourth national planning framework referred to as NPF4 in short. A number of committees are joining in scrutiny of different elements of NPF4. Last week, this committee heard evidence on how effectively NPF4 addresses energy policy. Today, we are going to hear from two panels. The first panel, the focus will be on transport and I am pleased to welcome the following witnesses who are joining us remotely. Dr Caroline Brown, policy adviser, Transform Scotland, Chiquita Elvin, head of infrastructure and delivery, SuchTrans Scotland, David Hunter, member, mobility and access committee for Scotland and Paul White, director, confederation of passenger transport. Good morning everyone, thank you very much for joining the committee today and thank you to those who have submitted submission in advance to the committee which we are very grateful for. We have just over an hour for this session, we have a lot to cover, we do appreciate complete answers but also concise answers where possible. Given that, we will move straight on to questions and I would like to start with a question for each of you. One of the main themes running through NPF4 is to prioritise localisation across a number of policy areas. In the context of reaching national net zero targets across all transport sectors, I would like your views on how important will local authorities be in meeting these net zero targets and what do you see as being the main challenges faced by local authorities in meeting those net zero targets. If I could put that question to the panel in the order that I introduced you, first of all that would be Caroline, then Chiquita, then David and then Paul. Caroline, over to you please. Thank you convener. A really interesting starter question. Clearly local authorities are crucial in the delivery of these policy targets because the planning system is effectively delivered at the local level and NPF4 guides development plans and decisions that are made at the local level. Local authorities are critical and that localisation agenda through 20-minute neighbourhoods is also going to be delivered through local authorities and the way in which they plan and bring new development forward. The challenges for local authorities are going to be around resources and skills. If we consider that the planning system in Scotland is a discretionary system in which developers are able to negotiate policy areas. They are able to negotiate around the things that they deliver in new development. In an under-resourced planning system, planners have less time to negotiate those goods, that localisation and the delivery at the local level. If you are a stretched authority, you have developers hammering on the door wanting to bring development forward and it is hard to push back and deliver things that are different to the way they have been done in the past. That is a big challenge. We can have a skills challenge as well but I think that resourcing is a big area of challenge. The other thing to keep in mind is about the unevenness in space and how we work together at the local and national level to bring consistency between local authorities. We know that there are developers and local authorities that push further and faster with those agendas and others, but we have to bring the tale along in order to achieve those pressing challenging targets. Thank you very much, Caroline. You touched on a number of issues that I am sure my colleagues will want to explore. Chiquita, the same question to you, please. I echo a lot of the points that Caroline Brown made. I think that resourcing and skills are going to be the biggest challenges. Of course, local authorities are not just about working with developers about the sort of projects that they deliver on their own that come out of the local development plans and other local plans. We have seen similar problems with resourcing and the skills and the impacts on the speed of delivery. How quickly can we tackle that? There would need to be further investment and training on delivery, but it is also at the moment that it is just the number of people who are able to carry that out. That is across the private sector as well who support local authorities in terms of consultancy support as well. Thank you very much. I am sorry to interrupt you there. Third one is to mention resources. In the context of the national planning framework priorities, one example that I will give to that is that there is quite a lot of emphasis at the moment on active travel freeways, which are part of the strategic transport planning projects review, and major active travel routes. At a local level, the most important thing for many disabled people to get around is just the everyday pavements, the quality of the pavements, the size of the pavements being able to cross the road, the bread and butter things. One of the things that I think is really important to make the planning system and mobility work properly is that councils are able to improve the everyday local pedestrian environments, which in many parts of Scotland—all parts of Scotland—is very poor and a big inhibition for many disabled people to get about. Resources and the balance between the centrally funded major projects and the local bread and butter walking and wheeling environments is one thing that I have mentioned. The other thing that I would just say is about we want to see better implementation of public sector equality duties, understanding the impacts of planning projects, transport projects and all kinds of initiatives on disabled people. I know that there is currently a review of PSED, the public sector equality duty, under way. I think that we feel that the planning system and the transport system have not been as effective as it should be in carrying those out. Good morning. I am going to complete the set and also reference resources and skills. Localisation, in terms of the sector that I represent—public transport, particularly bus and coach—we have positives in terms of the bus partnership fund and means to hopefully improve infrastructure as it relates to public transport. I think that one of the challenges would be learning how to deliver that effectively and expediently and sharing good practice. Thank you very much, Paul. Let me just follow up with Caroline. Caroline, you mentioned planning will be crucial to meeting the targets. The common theme, obviously, across what we have heard, is that resources are limited and challenged. Last week, the committee heard evidence that there has been a 20 per cent reduction in planning officers since 2011 at local authority level, so, obviously, the resources are going in the direction of being decreased. To address what we perceive as being the increasing demand from local authority and the planning teams to meeting the zero targets, do you have an idea or a ballpark figure about how much more additional resource is going to be required in local government planning departments? Are we looking at a 10 per cent increase in officers or are we looking at a transformational change? Are we looking at almost having to double the number of planning personnel available at the local authority level? You really need to touch the royal time planning Institute Scotland. I think that it has figures that it has put in its submissions to other committees about that. I think that it is in the order of hundreds more planning officers working in local authorities, so it is a significant increase. Although some of that may be covered by the increases in planning, not all of it will. I think that it is a significant change, as you say, quite a significant loss looking back over the last 10 years, and we need to undo that and put new resource in to cover the skills that we need to deliver those changes. It is very helpful. Thank you very much, Caroline. Let me bring in Fiona Hyslop. Good morning, everyone. I want to ask about multi-modal hubs, and I want to come first to Chiquita Elvin and then to Paul White. Draft MPF4 talks about multi-modal hubs, where people can easily switch between bus, rail, walking, wheeling and cycling. I want to know from you what you think needs to happen to make those a reality. My constituency goes half-way from Edinburgh to Glasgow, and it is in between the MA and the M9. It has lots of towns. It is over 100,000, the biggest in Scotland, and lots of commuters. In reality, how do we tackle that and what needs to happen? That's quite all right. I think that integration, network planning from the highest level, and I think that this is something that the planning system is very well equipped. A plan-led approach to integrating all those modes. I think that accessibility as well, as David Hunter touched on considering how different people use our spaces and making them accessible to everybody, is key. Broadening our understanding of that and I suppose improving the quality of active travel infrastructure, in particular, and things like bike parking, and access to the different, whether it's a station, whether it's a bus stop, even as simple as that, is allowing people to connect all those dots. So, a plan-led approach and integration of all the different modes working together. Can I just ask who makes this happen? Sorry, I couldn't quite... I wanted to ask who makes this happen. Who makes this happen? Well, it's going to take partnership between central government and local government, all the different delivery partners at a regional level, as well working together, as well as the private and public sectors, and, of course, the third sector as well. But it needs to be everybody from planners down to construction. Thank you. Can I ask the same question of Paul White? Obviously, the bus companies in particular are very keen interested in those multimodal hubs. How do we make them happen? What has to happen and who is responsible? As you can imagine, I'm a fan of multimodal hubs. I think there's a lot of benefits that can be realised through this. What needs to happen? Again, I'll be looking through my sort of bus lens here primarily. I think we have the formats where we can generate the discussions that are required to deliver these, such as the bus service improvement partnerships that were within the last Transport Scotland Act, where you can bring together the stakeholders that Chiquitib has mentioned. You can involve bus operators, local authority, Scottish Government, other key stakeholders in that and look to agree a partnership approach, whereas the infrastructure for the multimodal hub is funded by the local authority or through the bus partnership fund. The operator in turn commits to serving that hub with a degree of frequency or with a standard of vehicle or whatever is required to then hopefully make it a success. Other aspects of that have to be considered is integration with active travel, integration with rail, depending on what kind of multimodal hub you're referring to. I look at ticketing. That's something that a lot of operators are already introducing, that integrated ticketing across a bus. Can we integrate it with rail? Can we integrate it with the cost of bike hire, for example, and information provision? We've got a good resource in Scotland, Travelline Scotland, but we're just informing people how to access these things and how to use them appropriately. Will the NPF for help facilitate and enable this, or is it just a statement? In terms of NPF for, there are aspects of that where you're looking at the mass transit network and where you can identify examples of maybe looking to build in those kind of hubs. I also think that in terms of serving new developments and developer contributions, this is something that we should be looking at in terms of looking to make developers part fund those types of hubs where you do not require the service, the bus service that serves any new development, to go and essentially rent the houses, if you excuse the phrase, and serve a hub. People can access that hub by quality cycling and walking routes, and the bus can be there and away. You're not massively increasing the journey times or the boarding times that are required, and everyone has a quick and reliable service. In terms of NPF for, that's an aspect that I think we should be looking at. I was wondering to ask the other two witnesses about 20-minute neighbourhoods. First of all, to David Hunter. 20-minute neighbourhoods are mentioned 34 times in draft NPF for, but from your perspective, how might they be delivered in practice, particularly in urban and suburban areas, and particularly from your perspective, what needs to be there to make this a reality and positive for different communities in Scotland? It's a good question to the how, because I think that Max has spent quite a lot of time over the past year or so looking at the concept and sharing it with other disability groups and doing a number of webinars and so on. We're quite enthusiastic about the concept. I think that the how, though, is more complicated, and particularly whether it's a planning-led approach in which local authorities are actually directing those neighbourhoods and facilities in some way, or whether it's a more market-led approach. I think that there's a fair bit of work to do about that, but we do think that the more local facilities and services are close to where people live are on their doorstep, that's going to make for more inclusive and accessible environments. We'd certainly like to encourage them, whether quite what the levers are to achieve them. I'm still a little bit unclear. If I could, just when I have the microphone, I just wanted to complement your previous question about mobility hubs, just to say that interchanges are particularly important for disabled people, that they need to work well if they're going to be accessible, even if it's something just like having taxis close to railway stations. That kind of integration of transport modes is really important. Just draw attention to our submission that suggested that transport interchanges should be added to the list of national developments in the NPF4, by which we basically mean bus stations and train stations, so I just wanted to add that point. Thank you very much. Finally, to Dr Caroline Brown, before I hand back to the convener, to ask for your views about 20-minute neighbourhoods and how, in reality, they can be flexible enough for rural and island communities in particular, and how that might be achieved. Yes, Scotland has really taken on the challenge here in attempting to apply the 20-minute neighbourhood concept to rural settings. Examples of other countries around the world that have used this concept have really been mostly urban in their focus. This is a good question about how it applies. I think that there has been quite a lot of dialogue and there are some hints in NPF4 about the way in which that can be adapted for rural settings, so accepting that 20 minutes, not going to be a 20-minute walk or an 800-meter walk in a rural area, but this idea that there are a network of hubs that provide key services, and that's a much more local offer than perhaps is the case currently. I think we need to have a nuanced understanding of what 20-minute neighbourhoods deliver and the sorts of infrastructure that is present there. We don't just mean having a coffee shop nearby where you can get a nice latte. I think that we need to have a more rounded understanding about bike travel infrastructure and public transport services, but also social infrastructure, community infrastructure, ace for local businesses. I think that this is a really good question about implementation. The planning system already has policies around mixed-use development in urban areas, has done for a long time, and all of you know Edinburgh, and you can probably think of some places in Edinburgh where we have mixed-use developments with flats and residences alongside retail units or commercial units, and those retail commercial units are empty and have been empty in some cases for several years. There's a question about building it and then there's a question about making it work, and I think MPF4 and the planning system doesn't have the levers to make it work, so we need to think about how these things work together at local level, central government level, to animate those spaces, to provide incentives for businesses to come in and actually bring a nursery, a dentist, whatever, a repair centre or a repair cafe into that community and make it work. That applies for rural settings as much for urban settings. How do we make it work, even if we deliver the site? Thank you, convener. Thank you very much. Fiona, let me bring in Mark Roskell and Mark Overture, please. Yeah, thanks, convener. I wanted to ask you just about the bigger picture here. We've got a national planning framework for, we've got the strategic transport projects review that's just been announced as well, we've got a national transport strategy and we've got the budget. In your view, do you think that these are all properly aligned and do they actually respect the transport hierarchy as well, or are you seeing some differences or some misalignment there? I mean, I'll maybe start with Paul on this one. Yes, I think that my perspective of the STPR document and its planning framework going back to national transport strategy is that for the sector I represent, this is a fantastic opportunity. I think that you're seeing the spotlights firmly placed on sustainable and active travel properly, probably for the first time in a good long while. We see references to the sustainable travel hierarchy throughout the bus circle of growth. I think that there is an alignment there in the messaging around where we need to be focusing on improving our travel network and it's up to us to now really deliver on that. I don't see any misalignment, I do see challenges though. Particularly given, for example, the transport strategy is really referencing a pre-COVID world and as we emerge from that, there will be discussions about how you interpret elements of that to a network, for example a public transport network rail and bus and underground that is still looking at, in the medium term, at least patronage recovery. Really, we need to be building up that patronage and strengthening the public transport network if we're going to make it unaffordable and a comprehensive alternative to the car, which everyone is in this panel on. Within the committees, probably in agreement, that's where we need to be reducing those car journeys. I don't see a misalignment, but I do see a challenge. In the past, transformers may have been somewhat critical when it comes to Scottish Government budgets in terms of the transport hierarchy and whether what's in NTS materialises when it comes to spending the cash. What's your thinking at the moment in terms of these critical strategies and capital programmes and how they align or don't? Clearly, for any of this to work, these big ambitions have to be delivered and I think that's a key weakness about in the MPF4 and STPR2 is about how those are delivered and the timeline. MPF4 says really clearly that the climate emergency is the priority that we have to make a rapid and just transition, but we don't have any sense in here about the timescales, the delivery or which interventions and projects will deliver the greatest reduction in emissions over time. We need to start with those first. I think that's a big missing part of the agenda here, not just in MPF4 but also in STPR2. We can't wait three years, I think it is, in STPR2, for a strategy about demand management. We need it now and we need to start implementing it and I think that's a big question about how the national projects, the national network, the rapid transit, how those are delivered and over what timescales. Okay, thanks. David, any thoughts? Sure. I think, broadly speaking, the language is fairly similar and there's a fair amount of consistency between the various initiatives. It's probably quite helpful that there are a number of concurrent consultations going on at the moment, such as STPR2 and the 20% reduction in car travel target. What I would say is that we have been quite critical in our comments about the MPF4 document in not giving as much attention to the reducing inequalities goal that is quite prominent in the national transport strategy. We think that the bits on equality in human rights are very weak, very limp, to be honest. It basically says that statutory equalities should be followed. It says something very timid. We think that planning policy and transport policy as a whole can be much more assertive in trying to reduce inequalities. As I mentioned, there's lots of bread and butter things just like the state of local pavements, but although this is maybe not a planning issue, taxis—in many, many parts of Scotland—you cannot get a wheelchair-accessible taxi for love and money. Bus stops and shelters are just not good enough in lots of places. Our focus is on the tangible delivery side. There's a bit of a gap between the high-level rhetoric—it sounds a little bit unkind—but the high-level policy goals and what actually happens in the ground and what people see in their local neighbourhood. That's the real big challenge for all of those strategies. From an active travel perspective, Scotland is very well aligned just now. We've got the investment coming as well in 2024. However, the main concerns would be around the deliverability and the resources and the skills to be able to do that. Even if we can do that, how are we going to maintain things? Are we going to ensure that they are reliable for people to make genuine choices and changes in their lives? I think that there's obviously the inclusion of walking, wheeling and cycling infrastructure for the first time as a national development in NPF4. Is that detailed enough and the same with STPR as well? Is it really clear what it is that the Government wants to develop here? I think that most people look at that and think that that's the national cycling network, but we've got the concept of active freeways and there's obviously different levels of aspiration that could be put towards that. Is it really clear what the extent of that development is and what's required? I think that it is clear in the framework. The NWCWN looks to be both local groups but also joining up different communities as well. Then we have the whole notion of leisure and I guess that element of health as well. Once you combine that with creating places and talking about place rather than talking about just active travel or just housing, you start to join all those dots. Active travel is just one element that we need, but it's good to see that it's threaded throughout the national planning framework. From my point, I think that it's clear, but again it comes down to how do we deliver this. Caroline, do you have a perspective on that in terms of what's currently spelled out as a national development for walking, wheeling and cycling? NPF3 had the national cycle network as a national project and that was delivered through Sustrans and NatureScot's work and the canal's focus as well. In NPF4, the network is framed slightly differently towards everyday cycling and it includes that. While I take on board Chacuta's point about transport and the network if you like appearing in many places in this document, I think that it does seem a little bit confusing particularly with this new idea of the active freeways which isn't mentioned in NPF4. Presumably that's just a timing issue, but I think some clarification is needed about that and clarification about the idea that we're building an extensive active travel network which is about everyday journeys. From the 20-minute neighbourhood up to the city scale and between settlements and places in order to provide that longer distance leisure and tourism possibility. I think that there is room for this to be clarified and tightened up and to make more explicit some of the expectations at the local level about walking and wheeling networks. Gringing through David's eloquent point about equalities and the impact of that very local infrastructure on people, particularly people with disabilities, the quality of the pavements and the cycleways in their neighbourhood shapes that and we should be clear about the benefits that disabled people get from good active travel infrastructure not just for pavements but also for bikes because disabled people cycle too. I think that there's room to tighten this up. My final question is just about delivery and the mechanisms that we've got for delivery. I know my local authority in Stirling that they have a plan for what they want to deliver. It's taken a long time to roll that out and some of that is down to the traffic regulation orders and system that we have around this. Are there particular barriers that you would point to that could bust up against the ambition of NPF4? Can I go back to Chiquita on that? You're obviously directly involved in rolling out the tarmac on the ground. I'm afraid I'm going to go back to resources as one of the key barriers to delivery, particularly if we want to accelerate delivery and looking at tripling the investment into active travel. At the moment, that would be a challenge with the resources that are available to local authorities in particular. You touched on the TRO process. That has slowed things down. I think that what we've got in the framework is the Government reiterating and reaffirming their commitment to active travel as a priority for delivery. That will give local authorities a clear mandate when it comes to delivering big schemes such as the ones that you refer to. Other local authorities are at a different place and are still looking at those smaller schemes and making them fully accessible is one of the challenges that we now have to really tackle. Any final thoughts from Caroline or David on that? David, do you have any final thoughts on that? Sorry, I think that deliverability is a big issue, but I think that that's the best I can contribute to be honest. Thanks. Caroline, are you there? Okay, I think that we've maybe lost Caroline, but we can come back in a future answer maybe. Okay, thanks very much, Mark. It looks like Caroline has dropped off for the time being. We'll try and make sure that Caroline reconnects. I believe that Liam Kerr has a supplemental in this area to be followed by Jackie Dunbar, so Liam, over to you please. Yes, thanks, convener. I do have a supplemental, but it is for Dr Brown, so perhaps you could bring me in at the end if she reconnects. Okay, that's good to know. Thank you, Liam. In that case, I'll bring in Jackie Dunbar. Jackie, over to you please. Thank you, convener, and good morning, panel. I think that my questions would be for David and Paul in the first instance, but I'm happy to have any thoughts from Chiquita and Caroline if she joins us again. I'd like to ask, do the policies that are set out in the draft NPF4 give sufficient considerations to the travel and accessibility needs for all disabled people and people with mobility issues? If not, what would you like to see in the NPF4 and what would you change? Can I maybe go to David first, please? Sure, thank you very much. As I've said before, I think that we would like to see the equality and accessibility dimensions strengthened much more explicitly in the NPF4. When, whether it's major transport projects or planning initiatives, I think there are always opportunities to improve access and mobility, and those opportunities often aren't taken. Just to give a really specific example, which I think we mentioned in our submission, sometimes there's a development with a, which there's still a narrow pavement outside, and surely developers should be expected to contribute to decent-sized pavements and pedestrian environments to make sure that drop curbs are installed or continuous footways outside places. Whether this is through the kind of technical processes, the section 75, I think, processes or through voluntary agreements, we think that there's a much, we'd like to really raise the bar in the expectations of how planning developments could improve local environments that shouldn't always be down to the councils, which, as we've heard several times, often have very limited resources. We'd like to see that culturally as well. It's not just a question of skills. I think that there's also professional cultures. We would like to see just a more imaginative use of, more imaginative thinking about, you know, how could we make a local environment more accessible, whether that's about pavements or cycleways or bus infrastructure or that kind of thing. I think the NPF4, when it's in its final version, would like to see a much, much tougher and more explicit mention of things like understanding the impacts, the equality impacts of measures and the opportunities, not just mitigating negative impacts but opportunities because the built environment is so massive that we've got to change it bit by bit as we go along and we can't expect councils just to do this from their routine kind of roads and such like budgets. Okay, if I can just maybe ask a little supplementary there, I think. I think we've spoken about earlier about the developer contributions are negotiated. Is that something that you would like to see baby strengthened rather than, you know, so that it's written down that it must happen rather than that they've negotiated that it will happen because I'm aware that sometimes these things are put in place, but it's difficult to then go and find out later on if they've actually been done. Yeah, I'm probably outside of my comfort zone to be honest in the how exactly that should be done. That's fine. I mean, I think that there are, as I understand it, you know, the section 75 could be used to require investment and is used, but I think it's too limited. I think that the horizons are too low on that. But if the same results can be achieved voluntarily through negotiation, then as long as results good, then I wouldn't really have a problem with that. Maybe more people who are more expert in the processes could see whether the drafting could encourage those kind of opportunities. Can I pass over to Paul now and ask him the same questions, please? Thanks. I will instantly have to just bow to the superior knowledge of David and a lot of those accessibility points. I will say that we are keen to work with others to improve accessibility. The bus fleet should be at a stage where it is 100 per cent accessible. I think that, listening to David and the question that you posed, there is that aspect of OMPF4 talks about reusing and conserving buildings and infrastructure. Some of those older infrastructure might not be fully accessible. We need to think about how we ensure that public transport—for example, my sector—has the ability to have access to developments, to be able to pull vehicles close to kerbs, to be able to drop kerbs and to be able to use the bus, how we interact with active travel and bike lanes. You will be aware of floating bus stops and the issues that they sometimes cause for people who are wheelchair users or who are concerned about crossing a bike lane to reach a bus stop. Again, when it comes to developers, we need to be involved in this—if not receiving developer contributions to ensure that the infrastructure is safe—at least involved in the very early stages of those planning discussions to ensure that the infrastructure, the road infrastructure, is accessible not only for people but for vehicles. The correct vehicles or a bus, whatever shape that might be, might be to get where it needs to get to allow people to board. The only other aspect that I can think of is that we might be able to access a public transport facility within 400 metres, whether that is too much or sufficient. I would have to think that it would probably be better to answer that. I am not sure, because I cannot see you because I am online, if Caroline Brown or Chiquita would like to come back in with any final thoughts. If not, I am happy to pass back to you, convener. Caroline Brown is now back online. Caroline, did you hear the initial question from Jackie Dunbar? I did. Thanks, yes. I just wanted to say that I think David's point about NPF4 being much stronger on equalities and human rights is a good one. We would definitely agree with that, particularly the understanding of the underpinning inequalities that the built environment currently creates and perpetuates. Although the document says things about equalities, it does not give any specifics about the types of inequalities or the types of groups that are specifically disadvantaged. That would be really helpful, because if we do not know what the inequalities are, then we cannot do something about them. We have to start talking about those inequalities. Inequality for children, inequalities for women, inequalities for people with disabilities because of the built environment, the way that it is configured and the way that it undermines some other things that those groups do or could do. I think that that is an important point. We completely support all of the work around accessibility and, again, paying attention to the everyday settings of the 20-minute neighbourhood and how that supports accessibility specifically for those disadvantaged groups is really important. Thank you. Okay, thanks very much, Jackie. Now that we have Caroline Brown back with us, let me bring in Liam Kerr, who I believe has a question for Dr Brown. Thank you, convener. Yes, Dr Brown, I want to pick up something on the line of questioning that Mark Ruskell was exploring with you. You talked about a lack of strategy in NPF4 and STPR2. We have heard this morning quite a lot about the urban possibilities, but it is difficult to relate a lot of that to the rural setting or perhaps where bus services cannot be run for perhaps financial reasons, as correctly set out in my view in the CPT submission that we have received. The Climate Change Committee says that we need 30,000 public EV chargers by 2030, but we currently have about 2,500. Going back to your comments earlier about the lack of strategy, do you feel that NPF4 sufficiently accounts for a roll-out of EV chargers? Can it facilitate the sort of roll-out that we need? I do not think that it does. I think that that is an excellent point. There is mention of digital infrastructure here, and the focus tends to be on the urban rather than the rural. Scotland is not a largely urban nation, but it is a mostly rural nation. That is a really important point, but I think that that is where we go back to some of our previous discussions about multimodal hubs and the possibility of using some of that existing infrastructure to provide those settings. Chargers do not have to simply be near or at the point of someone's residence. They can be in many other places. Those 20-minute neighbourhoods that we are talking about, adapting those for the rural context, of course, means providing the sorts of infrastructure in those hubs. Having centres where you can charge your car, having centres where you can pick up your parcels, go to the library, get healthcare or whatever, those things need to join together. I think that that is where NPF4 could extend the envelope by, as David says, thinking more creatively and imaginatively about some of those concepts and linking them together. I think that there are possibilities there about that. There are some really interesting transport and energy projects about hydrogen and things that might be imagined in the future, but we should be aware of them now, because this plan is supposed to be in place for 10 years and to guide us through that 2030 deadline. Yes, more strategy required and a lot more thought and nuance in this document about the rural context. I think that is important. I am very grateful. Thank you, convener. Thanks very much. Liam, next up we have Monica Lennon. Monica, over to you, please. Thank you, convener. Good morning to our panel. I have a first question here, which I think was aimed at Caroline. I am glad that you are back, Caroline. We have talked about some of the national developments and the Anglo-Scotish high-speed rail project. I read an article in the ferret yesterday and some concern has been expressed by some campaigners, including Friends of the Air Scotland, about gas-guzzling high-speed trains, because the current refurbish stock is diesel-powered. I had a look to see what Transport Scotland is saying. It says that we plan to replace the high-speed trains by 2030 with zero-emission fleets, and that is dependent on progress with the developing programme of electrification and rolling stock capabilities of battery and hydrogen-powered fleets. With all that in mind, Dr Brown, I wonder what you think about the project in terms of delivering on the aims of reducing car travel and encouraging modal shift, which we have talked about a lot today. Are there other projects that you believe should take priority instead? That is tricky, isn't it? You are absolutely right that there is this issue about timelines. We have already talked about that. That is a central concern to Transport Scotland about how we deliver the significant changes in carbon and emissions in the timelines that we need to do. 2030 is our first timeline than 2045. If we are not getting electrification of those high-speed links until the early 2030s, we are in significant danger of missing our targets. We have to provide those strategic links, because that is important in relation to replacing and providing a viable alternative to short-haul flying, which, of course, is much worse in a carbon sense than high-speed rail. We are in a bit of a bind here. We need to step back, as I said earlier, and look at the things that need to be delivered and the timelines in which they can be delivered in order to meet the reduction of emissions targets that have been set. Which projects do we need to do first? If Transport Scotland did that with the Scottish Government, perhaps some of the investment could be directed towards those types of long-term strategic projects that will help us to shift away from short-haul flying, for example. That is really significant and really important. Thank you, Dr Brown. That should be helpful. My next question is from Emma Chiquita and Pauline David. Mark Ruskell has already covered the need to align different strategies. On that same theme, the Scottish Government's trunk roads investment programme has a planned expenditure of £7 billion, but it is not mentioned in the draft NPF4. Do you think that it supports the special principles and the priority set out in the draft NPF4? If not, how could the two be brought into alignment? I do not know whether I will be able to add too much to that. From an active travel perspective, obviously investing in roads would not be our priority from a such-trans perspective. We need to think about modal shift and road-based reallocation. We also need to think about the impact of the roads that we need once we start looking at rural areas, for example, the speeds of the traffic on those roads and the impact that that has. We need to really think about people making those everyday journeys and to think about streets being for people rather than for the vehicles that are on them and to bring the place focus back to the centre of all the different strategies. That would be my view, sorry. That is okay. We will come to Pauline David to get a bus and coach perspective on that. Thanks, Mark Ruskell. Clearly, there are issues of inter-urban services and bus services that use the motorway network. From the Government's strategy point of view, I know that, within the budget for the bus partnership fund, there is money for a managed motorways project. I would say that work on that, the discussion around priority for public transport on motorways has been slow. The Scottish Government has to set an example if it wants local authorities to make brave decisions about road space reallocation in city centres, if transport Scotland is shying away from those brave decisions that it needs to make and the elements of its motorway network. Other than that, there is not much that I can really talk to about the Toronto budget that the Government has. That is okay. I wonder if David has a view that I know that Mary Caroline would want to commence with her time, convener. I would like to come back to Caroline. From Max's point of view, we are probably not focused so much on the trunk road network and the decisions balancing the spending decisions. There is a massive legacy of inaccessible infrastructure. We just look at railway stations, for example, in Scotland, the number that you cannot cross from one platform to another that makes them inaccessible to disabled people or many disabled people. We have to try to balance those objectives, the accessibility and inclusion objectives with the investment in roads infrastructure. Obviously, there is just a massive legacy of inaccessible transport infrastructure in Scotland, and I suppose that our priority would like to see that at the top. This issue about budget and spending is really important, and we have talked before about delivery. Just to put this into context, you are talking about £7 billion being spent on trunk roads, but if we can trust this looking back to NPF 3, the investment in the national cycle network set out in NPF 3 has been around £50 million. We can see the scale of investment in active travel is but a button compared to massive mountains of money going into trunk roads. We need to be really clear to deliver emissions reduction, to deliver health benefits, improvements in air and environmental quality. Significant investment in active travel would repay us in space. When we see figures like this, we know just how much money there is for transport infrastructure, and if we have directed even a relatively modest proportion of that £7 billion into that national cycle network, into those active freeways, then we could do very quickly something very dramatic. As a final thought, I would encourage the committee to have a look at the sister organisation in Wales. Transport for Wales is doing some very interesting work, and they have essentially stopped investment in roads in Wales because they are concerned about the climate impact, and they are re-evaluating many of their roads projects. I think that there is a really great model to look at. Thank you, Caroline. We are always keen to get recommendations and extra homework. I have a very brief final question, which I will aim at David, because no time is brief, and I will declare an interest as the patient of disability equality Scotland. There has been a lot of discussion in Parliament previously when we looked at the planning bill about the role of access panels and whether they should have statutory status in the planning system in terms of how decisions are made. Is that something, David, that you have a view on? Given what we have heard today about embedding equality and inclusion in planning, do you think that there is a stronger case now, perhaps? There was a few years ago to properly recognise the role of access panels? Yes, that would be the answer. They are incredibly valuable. Obviously, it is not very consistent across the country. Some are more active, but my experience with access panels is that they perform an absolutely fantastic grass-roots perspective on all kinds of things about planning, transport and any way to support them or to give them a kind of stronger status. I would really encourage that. That is helpful. Thank you for that, David. I will hand back to the convener. Thank you very much. Monica, I believe that Liam Kerr has a supplemental to follow on. Liam? Yes, thank you, convener. I will direct just a question to Paul White, but based on the line of questioning that we have just heard from Monica Lennon, your submission talks about the need for bus services to receive on-going funding, absent which operators will need to make some very difficult decisions on fares and routes and frequency, for example. The committee is doing an inquiry at the moment into local authority ability to support net zero. One of the things that we know is that there are significant cuts to local authority budgets coming. Is there sufficient recognition, whether in the NPF-4 or more widely, of what central government needs to do to prevent those negative impacts that you mentioned in your submission? I think that the point from the submission was, within the NPF-4, it talks about facilitating bus services that would then do without the need for further public sector support. Our point is that all local registered bus services received from the Scottish Government bus service operators grant, which is shortly to be returned to the network support grant. There is a form of support that is continuous. The wording of the NPF-4 would probably need to be tightened up to talk about a lack of further support, whether that be from developer contributions or local authority funding to support a service in its infancy required support, but it could then, hopefully, quickly transition to a commercial service. I think that other operators are keen to run non-supported services where possible, and in cities that maybe 90 to 95 per cent of the bus network is run commercially. I'm sorry, Ms Keag. Can you repeat your question? I feel like I've gone off my tangent. No, I think that that was an interesting answer. Really, what my question is around is, given that local authorities are facing some severe funding challenges, do you think that, given your submission that central government recognises, when you say that there must be an understanding that any bus route that is new or existing will receive on-going public sector funding, do you think that central government has sufficiently recognised that, whether in NPF-4 or more widely, to satisfy the aims that, as you pointed out earlier on, we're all trying to get to? I think that the Scottish Government has supported the sector through the pandemic, which has been incredibly vital to ensure that we have a comprehensive bus network for those essential journeys that had to happen. At the moment, we are looking at patching age levels at about 70 per cent of pre-COVID levels, so there's still a need for a government to provide transitional support as we build up to, hopefully, pre-pandemic levels of patching age and beyond. Government support for bus services is tangential to the aims of NPF-4. What is more important is that we focus on the relationship between bus operators and local authorities and other key stakeholders to address where we can release real benefits for bus operators, which is in tackling congestion. Congestion has been a huge cost to the sector over the last 10 years. We've seen journey times increase by 10 per cent. That leads to increased operating costs. At a time when patching age and commercial revenue are down, tackling those operating costs by bringing buses from congestion, by looking at the aspects of the NPF-4 that we've talked about in mass transport networks and the focus on public transport, that's where I'd like to see NPF-4 focus on. The issue of support for bus services, some will have to remain supported services, whether they're not commercially available. Essentially, Scottish Government does provide that support currently, and it's tangential to the aims of this document. I'm interested in the discussion around the importance of equality issues. Some of that has been touched on in response to my colleague Jackie's question, but I would like to expand. Obviously, 20-minute neighbourhoods can mean very, very different things for different people, and I understand the sentiment that we need to reaffirm what a 20-minute neighbourhood is. Dr Brown, it was stated that it's not just about being able to nip out for a coffee, but it's about enabling people to meet the majority of their daily needs. For example, needs can be a very different thing for a young person in comparison to, for example, a pregnant woman or an elderly person or a parent with young children. Out with that, not necessarily a physical or mobility issue, but there's also the element of families on low incomes, which needs to be recognised. People obviously have a whole range of different needs, and that relates both to infrastructure and services, but transport really is key in that. To ensure that those neighbourhoods are accessible for all, how do you think that those needs could be highlighted more, and how might that be incorporated into the planning, especially in a rural setting, like we touched on earlier, the difficulties with that? Can I direct that to Dr Brown, please? There's a lot of things in there. Sorry, I realised that that was quite a long question. I think that, as I said earlier, being more explicit and understanding the current inequalities and how they serve different groups would be a really good starting point. We don't have any mention of that in this document, and I think that possibly that's something that's missing from the general piece about the concept of 20-minute neighbourhoods and how it might affect those groups that you talked about. Children and pregnant women and older people focus on low incomes. I think that those are really important. If planners, designers, practitioners are going to deliver 20-minute neighbourhoods, they need that understanding, so having that set out is important. Transport, local accessibility, is about providing that high-quality network of walking and wheeling opportunities. It's well designed, well maintained streets with paying attention to the dropped curbs, the crossings, the way in which the vehicle becomes a guest. That should be what we're aiming for, so we're thinking always about pedestrians and people on wheels, not people in cars and we're not providing all vehicles. There's a lot of retrofit and reconfiguring to go on in order to do that. That probably falls outside of much of the remit of NPF4, which is about setting that high-level policy. It's down to those nitty gritty everyday details. I'm sure there are other people that want to come in, but I think there's a lot to explore in these equalities and through into design, and not only in the urban but in the rural setting. Caroline Brown's answer was very comprehensive, so I would reiterate all those points. The ability for different groups to feel safe in their environment, particularly when it comes to walking and wheeling, needs to be explored much more because of the lack of understanding about how different groups access infrastructure. Access to good-quality green space for young people in particular can be a challenge in urban settings. Again, it comes back to the skills when we start to look at who will be designing and delivering many of the improvements and infrastructure that will be required. There's a lot of work to be done. Of course, when it comes to the national developments, they should all be fully accessible. I think that a bit more focus on that and what that actually means would be very helpful. I'll bring David in next, and then Paul, if you've got anything to add. I think that this point about having examples or illustrations about the impacts and opportunities for having inclusive local neighbourhoods is really quite important. The impact on children, on older people, as well as disabled people. The document could include some case studies or something like that that could bring that to life, because that's one of the things that maybe doesn't come out of the document as it is. We've talked quite a lot about the local pedestrian environment, which is something that I'm really passionate about and keen to see improve. I noticed that Disability Quality Scotland did a poll about 20-minute neighbourhoods a year or so ago. The key scepticism that many disabled people expressed was that it's all very well having things on your doorstep that can get across the road, that pavement is not accessible for me, et cetera. The final point about sustainability is one thing that came up in a previous point, that it's one thing having the infrastructure there. Is a business of some sort, whether it's a local corner shop, it's probably the most important 20-minute neighbourhood facility, it's fine designing a space for that shop, but is it going to be economic? How are these 20-minute neighbourhoods going to survive economically? There's clearly big issues around out-of-town shopping centres and competition from other areas, which is very much a planning issue. We need to look at how those 20-minute neighbourhoods and the services and facilities that are in them are sustainable economically, so that we don't just design neighbourhoods that then become waste lines, which we see quite a lot in urban Scotland. You have little shopping centres, and half the units are empty because people aren't making money out of them. Why aren't they making money out of them? Partly that could be the quality of the public realm, but it's probably also that there are other more attractive economically out-of-town shopping centres and so on. There's an awful lot of thinking to be done about how the whole package works sustainably, and I mean principally economically sustainably. The final point is that the other point that maybe hasn't come out so much in the discussion is that it's about community sustainability, as well as physical accessibility. If people live together and they don't have to move out at different stages of life because they can't sustain their life as they get older, for example, that's the most sustainable type of community where you have different age groups, different groups of people who are all part of a community that functions well, and that's an economic and a social aspect, as well as one about physical access. Thank you, David. Paul, if you have anything to add? I probably have little to add after the great contributions there from the other panellists. I would say that in terms of 20-minute neighbourhoods, I think that there is an important role for bus in sustainably linking those neighbourhoods, providing access to wherever your education or your employment might be based. I think that it's important that we build that in. It's not really a planning issue as much as I would say maybe for equality and accessibility information provision. It brings to mind that we've seen examples of information provision improving through the pandemic, where people can look online and see how busy their buses are, whether those are wheelchair-based free, that type of aspect, and I think that that might provide surety for people who maybe have accessibility issues, that there are sustainable transport options available for those longer journeys, where walking and cycling wheeling isn't possible, and that they are able to access those both in terms of physically access it and feel safe and know there's a space for them on that vehicle. Thanks all. It's really important that we get this right, so I appreciate all your comments on that matter. Just to round off, I'll ask the full panel, are there any other specific transport-related improvements that you think could be made to draft MPF4 that have not already been highlighted in our evidence session today? Paul, you've been last quite a few times, so I'll bring you in first. I'll just go the opposite way this time. Paul, thanks. I quite like going last. You get the other good comments. The one thing that stood out to me from the discussions that I brought up earlier today was something that Dr Brown was pointing out about the charging infrastructure. We've touched on the difficulty of introducing some of those concepts in rural areas. Looking ahead at the desire to decarbonise and providing sustainable transport links, particularly in rural areas, there are specific challenges for public transport provision, and decarbonising that in a rural setting, where loadings are generally lower and less people use them. The end-to-end journey time is longer than long services, so if you're looking for an electric solution to that, you need to have access to charging infrastructure not only at the depot but at the end of the route, wherever that may be. That also goes for sustainable tourism, which comes up in MPF4 and sustainable tourism travel. I think that coach plays an important part in that. Access to charging infrastructure for those vehicles and taking groups of 70-75 people in one vehicle to see some of the great things that we have in the Highlands. I'd like to see more focus on how we deliver that charging infrastructure across Scotland and how it's made accessible not only for people who have a private vehicle but also for those kind of mass transit vehicles. Thanks, Paul. Can I go to David now, please? I did mention before, but just to say that our submission suggests that transport interchanges may be slightly different from the mobility hub issue, but it's related to something that we should see so that every town should have a decent, accessible and high-quality bus station or train station. All right. Thanks, David. I think that we welcome much of what is in there, particularly for the national walking cycling and wheeling network, but going back to Paul's point about charging and maintenance, you need that for bikes as well. You need good-quality bike parking, and that shouldn't just be focused on people in flatted developments as well. Different types of homes need different types of bike parking. I think that the maintenance question, again, we need to ensure that whatever is delivered can be used reliably by people throughout the year. Oh, thanks. Dr Brun, thanks. Thanks. Like others, I think that there are lots of good things in here. We'd like to see, as I said earlier, clarification of the active freeways idea and the national cycling and wheeling network idea, which has shifted since NPF3, but there's something that we haven't talked about, which is about infrastructure first, which is a new principle set out in NPF4. That is a welcome one, but we would like to see that go further so that new development is infrastructure-led. If we have new housing planned, we need to have the walking and wheeling network in early. We need to have the public transport links in early so that the people that go and move into those houses have options from day one. It's no good having a bus link or a rail link that opens after five years or some cases 10 years. You can't shift people's behaviours at that point, so I think that that's something worth thinking about here, about strengthening that infrastructure first idea into infrastructure led. That is critically important for active travel and public transport. All right. Thanks all. I have no further questions, so I'll pass back to the convener. Thank you very much, Natalie. For a brief final question, I'll pass over to Mark Ruskell, please. Yeah, thanks, convener. It's actually on the back of Liam Kerr's comments earlier around local government funding. We've seen dramatically increasing capital budgets for walking, cycling, wheeling infrastructure over a number of years now, but that has been delivered via Sustrans to local authorities. Local authorities are bidding effectively for it's ring fence. It's maybe an unfair question in a way, but is that the right balance? Or do you think more money needs to go from those pots directly to local authorities to build the capacity to actually do the work to build out the plans? Or is the current model of delivery via Sustrans the best way to do it because effects will be relying on national charity to deliver a national network? Chiquita, that's perhaps a hard one for yourself, but could I ask Caroline and then Chiquita if you've got any thoughts that you may be able to share with us on that? Yes, it's funny. We had a conversation about this very question the other day when I was preparing for this session. Why isn't Transport Scotland? Why doesn't Transport Scotland have a role here? We can see that it delivers strategically on other types of transport infrastructures. Why not on cycle and active travel infrastructure? I also mentioned the point earlier about unevenness and where things are left to local authorities and where we have this bidding into a pot. The danger is that some authorities become very good at that. They have skills and resources to do it and they successfully develop networks, but the neighbouring authority, which is perhaps less resourced, doesn't. The people living there, the citizens of those places, don't benefit from that funding and those infrastructure developments. We have to think seriously about that, about the delivery of this. NPF4 doesn't say anything about delivery of the national cycling and wheeling network and who is going to be responsible. It did in NPF3, and I think that there should be a strategic role for Transport Scotland on active travel. We would like to see that. That is one of our suggestions. Sustrans has done a cracking job in many ways, but as you say, it is a third sector organisation. As more public funding is going towards active travel, you should be looking after that and co-ordinating it strategically with those local authorities to deliver what we need for the emissions reduction, the car vehicle, or the kilometres reduction targets that have been set by the Government. Jackie-Zif, do you have any thoughts that you are able to share with us on that? Clearly, that is a bit of a difficult one for me because I do feel that the money coming through places for everyone funds in particular. The reason that it comes to us is that we are uniquely placed at value to all of those projects. We provide support for the local authorities who are the main delivery partners, although we do work with other organisations as well. Our focus is on the quality of active travel infrastructure. We work with them. However, being a charity, we are still working towards the aims of the active travel framework. I think that there should be increased investment going direct to local authorities, but, equally, I think that investment coming through places for everyone is very effective as well. Let me thank the panel members for joining us this morning for a very interesting discussion. The committee will share its findings with the LEAP committee on NPF4 towards the end of this month. Let me suspend the meeting to allow the second panel to join us. Thank you again to the panel and enjoy the rest of your day. I think that we are all set. Are we good to go, everyone? Okay, good. Welcome back. We will now hear from our second panel of the day on NPF4. This panel will focus on the natural environment, waste management and the circular economy. I welcome to our panel Anna Bezzic, programme manager, Adaptation Scotland, Ian Gilland, executive director and chief executive officer, Zero Waste Scotland, Rosie Simpson, senior policy officer, John Muir Trust and Bruce Wilson, public affairs manager, Scottish Wildlife Trust and representative of the Scottish Environment Link. Thank you all for joining us this morning. It's a pleasure to have you in the committee meeting. As with the previous panel, we have just over an hour for this session, so while we do very much appreciate complete answers, concise answers are also very welcome. Let me start by moving straight on to questions. I have a question for each panel member. One of the main themes running through NPF4 is to prioritise localisation across a number of policy areas in the context of reaching national net zero targets. In that context of reaching net zero targets across the natural environment, waste management and the circular economy, how important will local authorities be in meeting those targets and what do you see as being the main challenges faced by local authorities in that context? Let me put that question to the panel in the order that I introduced to you, so that would be Anna First, followed by Ian, Rosie and then Bruce. So, Anna, over to you please. Great, thank you very much for that question. My work focuses on boarding wide ranges of organisations to adapt to the unavoidable impacts of climate change. We are clear that local authorities have an absolutely crucial role to play, the impacts of climate change. Changes in temperature, changes in rainfall, severe weather events are not going to be felt evenly across Scotland. It's not like an average change. The impacts are played out and very widely across the country, so it's really important that local authorities and regional partners play an active role in understanding the kind of risks that they face and are equipped and able to respond to those risks to address. In a way that is aligned with local culture and values as well. Thank you very much, Anna. We'll come back to some of those issues later on, I'm sure. Ian, same question to you please. Thank you, convener, and thanks for the opportunity. I think that, as I said many times, local authorities are hugely important in delivery of national targets but also delivery of infrastructure on the ground to support the shift to a more circular economy. So, specifically, we're serious about moving our approach to waste further up the hierarchy in terms of reuse and repair and remanufacturing. I think that there's a huge opportunity for local authorities to develop accessible infrastructure for both citizens and businesses, and to support economic development at a local level for businesses in that space, as well as engaging with citizens and providing a kind of enabling role for the specific citizens that they have in their communities, whether that's an urban environment in cities or the rural environment will be very different. So, absolutely, I think that one of the challenges is we see is still the idea of a circular economy is still very much embedded in the kind of waste management part of local authorities. We need to raise that so we are obviously in this instance engaging with planners, engaging with economic development personnel, procurement officials across the wider scope of local authority delivery to ensure that we're not just talking about how to manage waste at the end of life, how are we building infrastructure to ensure that it's not about the end of life, it's about how do we create that circular use of resources both at national level and at a local level to reduce not just the carbon impacts here in Scotland, but the global carbon footprint as we know goes beyond our measurement of our territorial emissions. Thanks very much. Ian and Rosie, if I could put the same question to you, thank you. Thank you. Just to say thank you for having us, I know we're accommodated later in the day, so thank you for that. Local authorities, we'd say that they're absolutely vital for the localisation and the translation of the national targets, but they can't do everything on their own, obviously, so the need for that first facilitation of partnerships, particularly with others with statutory bodies and maybe a good example there being a framework that's been created of partnership and facilitation of the HAGSAW energy cluster, and it's maybe a good example of how local authorities are part of perceived planning and seeing that energy development take place, but they're absolutely doing it in partnership with public bodies and the private sector and with communities, that communities are just as vital as well, and powering them and enabling the local place planning to come through to delivery is important, too. Thank you, Rosie. Finally, Bruce, same question to you, please. Thank you. As you might expect, when last ordered, there's a lot of agreement with what everyone else has said, but particularly on the biodiversity side of things, there's a strong feeling not only among Scottish Environment Link members that local authorities are under resourced to be able to carry out what's asked of them within the NPF4, but also just drawing on a little bit of discussion at a recent CIE event, bringing in local authorities themselves to look specifically at the biodiversity measures within NPF4, and a lot of local authority representatives shared those concerns that there was a lot asked to be able to tackle the nature crisis and we need to be able to make sure that they're resourced appropriately to do it. Rosie's point as well around helping them, maybe not reinventing the wheel everywhere, there's lots of processes around the NPF4 that could be common amongst local authorities, and having 32 different localised approaches to solving the nature and climate crisis through planning is maybe not the best use of time or the resources, so I think that that is something that we do need to look at in the draft. Thanks very much, Bruce. There seems agreement, obviously, that local authorities will have a crucial role in delivering net zero targets. I wonder if I could dig a bit deeper into the main challenges faced by local authorities in your experience. In the previous panel, some of the challenges identified were a lack of resource, for example across planning departments, a lack of the necessary skills and expertise required in delivering some of these really challenging net zero targets, and financial constraints as a result of budget cuts. I wonder if each of you could give briefly some practical examples of how you see those challenges manifest when you deal with local authorities. Just to mix things up, I'll go in reverse order, so Bruce, I'll come to you first and then Rosie. Some examples that we can foresee with the burden placed on local authorities would be around, for example, application of positive effects for biodiversity. Some people were referred to as biodiversity net gain. There is a lot of interpretation required there. The language around that is not very tight. There could be scope for large developers to really reduce what is expected of them just simply because local authorities do not have the resource to be able to appropriately assess developments. There is also the follow-up from that. Local authorities are under resource to be able to take a view post-development implementation, whether it has been successful with meeting positive effects for biodiversity. That concerns us. We also see the lack of specific guidance being quite an issue for local authorities. Not only are they having to interpret it, but they are having to look at guidance that has not been drawn up with the climate and nature crisis in mind. We have some of the documents that are referred to in the document that are a decade old or some that have not been written yet. There is definitely a lot that we are concerned about from the perspective of authorities or other planning authorities. Thank you very much, Bruce. Quite a lot there that we will follow up on. I say that keeping up with the pace that is required on the decision making, we would foresee that demand may only rise. That is the resourcing question for local authorities. I cannot say that I feel qualified to answer on the expertise of local authorities. When it comes to reviewing applications for planning on their potential harm to nature to biodiversity and the carbon emission impacts, that gets to the detail of quality of information that has been provided to local authorities to enable them to make decisions. We would foresee not necessarily a problem, but are they receiving the accurate information that they need on carbon emissions of a future development to weigh up that planning decision? I will stop there. Iain, I will bring you in at this stage. I guess that I was just building on what I have said. Clearly, another experience is probably just the experience. A lot of what we are involved in in the circle economy is very new. It is about building new types of infrastructure and new ways of working in partnerships. I will come back to a previous point about how to evaluate the proposals that are coming through carbon. It is about how we engage with other parts of local government in terms of awareness-raising and providing them with the support so that they can gain that expertise and experience in relatively quick times so that they can make those types of decisions to progress their projects. Ultimately, the support from agencies such as ourselves and from colleagues is to do things differently. Ultimately, we could talk about resources, but there are different ways of delivery in terms of different types of partnerships, both in the private sector and in the third sector, to deliver things like reuse and repair infrastructure at a local level. It just needs a different type of thinking, so that, to some extent, they just need the space and the confidence to go and pursue some of those obvious opportunities in a different way than they have probably been doing before, as well as all the other pressures that they probably have, so possibly a bit more about capacity within local government. Thank you very much, Ian. Finally, Anna, the same question to you, please. Thank you. I guess just to try and have some different elements to points that have been covered, I fully agree about the issues around resourcing skills, expertise and financial constraints. I think that there are also additional areas around the decision making cycles, many of the benefits of investing in a more resilient climate, resilient future, and long-term benefits were immediate. It is hard for investments in those benefits to always compete with short-term leads, and that is a constant tension within local authorities. I think that the case for change needs to be stronger in terms of the evidence and the economics behind why action on climate resilience is needed. There are just really key challenges around mainstreaming, so taking responsibility for climate action outside of the sustainability box and embedding that across decision making. How are we seeing sustainability and climate change objectives being delivered through city deal programmes, for example? How is that landing with directors of economic development in terms of regional prosperity frameworks? How can we begin to build the economic case for that to translate into some of the major revenue streams that do exist? I think that there are some challenges that we need to address within local authorities and their partners. Great. Thank you very much for those opening remarks. I am sure that my colleagues will want to explore some of them further, so let me bring in Fiona Hyslop. Thank you and good morning. There has been some criticism that planning policies on biodiversity are too aspirational and in the preparation of NPF for one of the working groups looking at securing positive effects for biodiversity, and I want to focus on biodiversity in particular, stated that support of planning policy on biodiversity and green infrastructure more generally is not translating into delivery on the ground. Green infrastructure can be seen as optional or as an element that can be negotiated out. Now that we have the draft NPF 4, I want to come to Bruce Wilson first on that and then to Rosie Simpson. Do you think that the draft NPF 4 really delivers on the radical change on biodiversity that the national spatial strategy set out in its introduction? Without being too negative, no. Overwhelmingly, the environmental organisations that are represented within the Scottish environmental link think that the high-level rhetoric is really nice about solving the climate and biodiversity crisis holistically, but the actual changes that we see from NPF 3 to NPF 4 do not amount to much. There are new sections in there on creating local nature networks and implementing the positive effects for biodiversity. When you translate those two things through, it comes down to that there is a lot of shoots and there is not a lot of musts. There is very woolly detail there. We are also very concerned that the approach for net gain from developments in terms of biodiversity is not data driven. There is no requirement that we can see to establish a baseline. Using the old adage that you cannot manage what you do not measure, if we were to somehow assess that a development has had a positive effect for biodiversity, we need to know what has been there in the past. We are very concerned that there is not going to be a data driven approach to that. We know that at the international process around COP 15 there are requirements being written in for looking at net gain around nature. That is something that we will presumably be aspiring to when we are creating our new Scottish biodiversity strategy. The nature targets that have been discussed in the programme for government, we are worried that the national planning framework, which will set the agenda for years to come, will not be coherent with that. We will lose a huge opportunity. We know from past experience that languages will lay around those things that developers will not put in the required implementation for biodiversity. In summary, answering your question, will this provide the transformational change? We do not think that it does at all, and we need to see significant strengthening of the language. There is still time to do that. This is a draft document, but we do think that that needs to be done. In terms of aspiration and the principles within the draft MPF form, there is an awful lot that we would welcome and, of particular policies, two and three and on natural places, really great and certainly welcome. As Bruce said, when getting to the detail, when thinking about the evidence to help that way to decision making and the information that planning bodies are going to need, for example, to know whether the biodiversity will improve overall for development or whether the carbon savings will be greater than the emissions. Whether it can fall into guidance, but that is where more detail on the decision points and the thresholds would be really helpful in the draft MPF form. Just to add that land is a huge natural carbon store, and it is there as our key for achieving biodiversity targets. There is nothing in the draft MPF form that contradicts that, but it is the recognition of that huge potential there that the policies need to follow. An example of that would be the peatlands that has drafted, but that does not go far enough on the protections required if we are going to treat that as a natural carbon store in the future. Sticking on the theme and reflecting on what you have said about data in particular, I am very struck that if you have the same piece of land that is open for development for very positive reasons for renewables, for example, there will be a very strong data-driven aspect to carbon reductions using renewable energy. We have heard about what a piece of land may end up being double-counted for different companies or organisations. At the same time, we are concerned about the same piece of land. For example, peatland, the data is not sufficient perhaps to look at some of the issues around the carbon-rich soils and the other aspects, and that biodiversity therefore can be the poor relation in relation to that quantification of what impact any development might have. Is there a possibility that MPF poor should enable that interchange? If we have a twin crisis of biodiversity and climate change, surely if we have the one piece of land that needs to be calibrated equally between those two crises and the measurement of that, does MPF poor do that, the draft? If it does not, what is needed to make sure that it can deliver on both those crises? I will come first to Rosie and then back to Bruce, and I will back to the computer. A twin crisis here is that MPF poor can help us to address both at once or go in the opposite direction on biodiversity and climate emergency. Reading the policies, taking them more in the round and not in the isolation and thinking about how they can work together, to refer to the draft that we have and that they can. Reading policy 3 on nature crisis with natural places and then with, say, take the green energy policy that is there for 19, but the burden would definitely fall on the local authority to continue that very intentional balance with what is there. I do not know if Bruce would like to add to that, but I think that there is a lot in the draft that is workable. We would not say that that twin, which is addressing simultaneously biodiversity and climate, cannot be reached through it. How do you think that policy 3 and policy 19 could work together in such a way that biodiversity is not seen as a pro-relation because it does not, for example, have data? We are lacking the overarching targets on biodiversity that we have in the same way for climate, but that definitely drives policy. We have commitment to bring in those targets on biodiversity, so we will hopefully get to a position where policymakers are driven by the desire to meet those targets. In the meantime, it is important that we take a data-driven approach, so that should be enshrined. A loose overall net gain will not bring the balance that we want. That is a crucial part of the planning policy, to find the balance between these developments. I believe that it is possible. I think that there is scope in the documents to have better coherence with things such as regional land use partnerships, which have been brought through the climate act and are looking to get communities taking a natural capital-based approach to what happens with the land. Historically, even when there have been burdens on developers to put in place biodiversity measures and post-development, so that you use the wind farm example, there are lots of places where local authorities do not have the resource to follow up on that and check that those things have been done properly. Restoration is going as planned, so there may be a stipulation, but there is not really any way of keeping a check and balance in there. That is very important that we make sure that that is being done properly and effectively. Thank you, and I will pass back to the convener. Fiona, let me bring in Mark Ruskell to be followed by Liam Kerr. Thanks, convener. If I can just stick briefly with biodiversity and national infrastructure, there is a commitment to NPF for local nature networks. I think that the understanding is that every local authority will develop its own local nature network. Perhaps if I could start with Bruce and just ask you what is the difference between that and a national nature network in terms of its status, in terms of planning, and what you are looking for in terms of that status in NPF? For a start, I am really glad that they have defined them within the glossary of terms in the NPF that is a very positive start. Basically, each local authority has been passed with having a range of activities and projects that would constitute a local nature network. That is great, but I think that it really gets to the heart of the problem that we are then going to probably have 32 different local approaches to local nature networks with varying degrees of delivery and success between each place. There is no real mechanism for joining those up at scale. When we know with biodiversity if it is bigger, better or connected, we get more of those benefits that we need as a society. Never mind all the intrinsic value that that creates because it is enhancing our biodiversity. There was a call from Scottish Wildlife Trust and all the other linked members. It is the most signed up to policy document that we have ever produced with the Scottish Environmental Link to get this nationally ecological network, or Scottish Nature Network, as it is referred to, to get that at scale as a national development. We have already heard evidence this morning about things such as the national cycle network, or we know that the central Scotland green network is in there. We know that we can do these large at scale networks. Taking that approach would help to give a little bit more context to our green and blue infrastructure aspirations. It would maybe help us to plan a little bit better for some of those projects' goals. There is more ecological coherence and we get a little bit more bang for our buck for investment. We are going to have a problem relatively soon because we know that public investment in nature is not going to be enough to meet our nature and climate goals. We are going to have to work out how to get private sector funding in there. We are going to have to work out if we have a system of net positive for nature where that goes in a landscape. A kind of at-scale national ecological network, or the Scottish Nature Network, is helping different local authorities to map, using opportunity mapping. The best places for investment and projects on the landscape will help us to get much better handle on that. We would never plan a road network by just having different local authorities put in place different bits of grey infrastructure. Obviously, it is not the same with Biodiversity, but we similarly cannot expect the same results if we have different bits of green and blue infrastructure in the landscape. We will not make that coherent network. It does not always have to be a physical network but just to allow nature to permeate our landscape a little bit better. That is vital for providing all sorts of services from flood prevention, pollination for crops and, obviously, sequestering carbon. During lockdown, we are fully aware of the massive benefits of having locally accessible nature as well. The point is that you are talking about co-ordination. I am imagining a catchment like the fourth, multiple local authorities, maybe different landscape initiatives, different ecological networks. I am trying to get my head around what the actual qualitative difference is, of defining that as a national development within MPF4. Go on and turn around and say, well, we will make sure that there is co-ordination, but we do not really need that as a national development. What does a national development actually bring in the way that CSGN, for example, has been a national development? I think that that almost answered the question. We have seen the action and the movement within CSGN. There are definable projects that have been taken forward. We have got great initiatives like the Glasgow Clyde Valley green network. We are looking at how that blueprint can be applied wider throughout the CSGN. There is a lot more energy and action in that area of Scotland than there are in some other places, providing that national development angle to it. It becomes a priority. At the moment, there is just a lot of ambition around nature networks that we will strive to create, but there is not actually any defined mechanism for creating the nature network. Specifically, what the national ecological network could do would be to help to provide that opportunity mapping, which is so important for us working out where does that green and blue infrastructure go and to deliver the most benefit for the most Scottish priorities. I do not think that Rosie wants to come in on that before I move on to a different topic. Just to take up where Bruce left off on opportunity mapping, that is a strategic view and foresight on what areas are we safeguarding or protecting to enable either that connectivity or that ecological restoration. For that to take place at the same time, we have the planning for, say, built development for infrastructure so that we do not use what we have before we know it, in a sense. Critically, maybe from the general trust perspective, we could give the example of the mapped carbon soils that we have as a baseline for a national nature network. The mapped designated landscapes and wildland areas that we have as a guide to where we can direct the ecological restoration across Scotland. If Anna has any comments on a specific question at all. I do not have anything specific. One of the points that Bruce raised around financing all of this and trying to find a way of recognising what we need to do in terms of nature conservation exceeds our ability to pay for it at the moment. How we leverage in private sector investment is crucial in terms of a skills development area. We need more people who can come up with innovative financing around nature-based solutions. That is valuable. Can I move on to a different topic? I can bring in Ian on this one. Waste incineration. Effectively, we have now a moratorium on decisions on new waste incinerators in Scotland, at least for the length of time that the Government is conducting its review into waste incineration at the very least. What do you think is going to come out of the review? How might that shape the way that Government approaches waste incineration circular economy in NPF? Will it have any bearing on what is in NPF? There is a related issue here about whether the planning system has actually been effective in the past. Ensuring that where waste incinerators have been built, they actually connect in with heat networks and deliver on that side of things. There is a concern there around loopholes. Do you have thoughts on any of those two points about the effectiveness of the planning system at the moment and what might emerge and how it will relate to NPF going forward? Mark, I am probably not in a good position to pre-empt the reviewers when they come up with. Obviously, we acknowledge that NPF is recognised that there is a review, and it says that it will take on board any of the outcome of some of the reviews. Obviously, that is to be welcomed, so we are not just talking too much detail about that. In the past, there has been some challenges around the engine from waste in terms of planning, in terms of the development of proposals, and you are right. Obviously, we have provided some information about that in terms of the efficiency of some of the existing plans, because they have not been attached to heat networks, etc. If we are given the opportunity that we are missing, whatever comes out of the review, we need to strengthen some of that, not just the decision making, but obviously the documentation of any proposals that come forward. Ultimately, I think that we welcome the review and can do a waste document to understand what the future role is for energy from waste. Ultimately, as I said to the committee, we want to get out of waste. We need to be planning infrastructure in such a way that we can get ourselves out of waste, whether that is for incineration or landfill. Ultimately, we want to move things up the hierarchy and use waste and create that circular economy. It feels odd that we are for us. There is some good stuff to be commended in the national planning framework for around waste, but it really misses the point about circular economy. It does not put a lot of the language in it and it still feels very linear about how we manage disposal going forward. If it is always going to be there, it is always going to be something that we are going to have to deal with other than trying to create a different economy in terms of the materials and the use of that. There are, again, some of the specifics. Some of the language is still very linear for us. We need to be looking much broadly at how we embed circular economy, not just in the waste chapter or the waste policy 20, but in lots of the policy areas as well. We have talked about green energy, about where we want to local living in 20-minute neighbourhoods. There are huge opportunities to shift the thinking around infrastructure, but it is not just about the linear economy and what can we do with the waste that has been produced. How do we drive infrastructure, or how do we create infrastructure—the right infrastructure—accessible infrastructure for all citizens, communities and businesses to participate further on the high ground? I think that other colleagues might want to come in on certain aspects of that, but can I just put that question around waste incineration, where it sits with NNPF, what may change to Bruce from Environment Link? Sorry, I had a little drop out there. Can everyone hear me? Yeah. Did you get the original question that I posed? Yeah, sorry, I heard it there. Actually, there was just a lip on the screen. I mean, I think what Ian says around needing a bit more clarity is probably where we come from that as well. We recognise as well what Ian is saying about the embedding of the issue there with regards to waste, but yeah, I think that there's broadly an agreement with Ian. Okay, back to you. Great. Thank you very much, Mark. Next up, Liam Kerr. Liam, over to you, please. Thank you, convener. I will direct a question to Anna Besick, please, on coastal protection and resilience. If any other panel members wish to come in on either of those questions, just indicate. Anna, good morning. The policy 35 requires that the local development plan spatial strategy should consider how to adapt coastlines to the impact of climate change and says that there is a need for a proactive and innovative approach. How well does NPF4 support the need for climate adaptation and coastal resilience, and how proactive does it really require stakeholders to be? Great. Thanks for that question. I think I guess to answer your last question first around how proactive does coastal resilience require stakeholders to be, it requires them to be extremely proactive. There are very serious risks facing areas of Scotland's soft low-lying coasts. We are facing very significant changes in terms of sea level rise in coastal erosion risk and it's definitely not a challenge that can be left for another day. I think there are some really good signals within NPF4 around the need for coastal adaptation. I would like to see more around what we would call flexible adaptation pathways. That means that we understand the near-term current risks that we face. We build resilience to those, but we are also much more aware of the long-term risks. We use a flexible approach to planning that will allow us to respond as risks emerge in the future. I don't think that there is currently enough about the need for that kind of adaptation pathways, that flexible approach that is built into NPF4 at the moment. It connects in with nature-based solutions as well. We have excellent assessment of coastal climate change risk through the dynamic coast project in Scotland, which tells us about the extent to which nature and natural coastal systems are protecting key assets and land in Scotland, so understanding how we sustain and value those assets is crucial as well. We are working across Scotland through the Adaptation Scotland programme in urban rural and island communities and the approaches to addressing coastal risks need to be different in those places, depending on whether they have existing built defences such as an Edinburgh, which gives you a false sense of security, you have those defences, you just assume that those will always exist, you will make them a bit higher, but the kind of changes that we are seeing are game changing around the risk exposure that we face in the future and the way in which we need to be considering coastal climate risk. That is even more evident in low-lying island communities that face very present and real risks that are not currently being addressed in the way they need to be. I am very grateful for the answer. I think that that last point might be the key one. What I have in my mind is the issue that is going on at Montrose, in my region, that has been very active with colleagues from across the parties in trying to address. That leads on to a similar point that various members of the panel throughout the morning have talked about the current burdens on local authorities. That is happening in a context of, as Bruce Wilson pointed out earlier on, major budget cuts and funding pressures. In your view, given what you have just said about the need to proactively address that, is NPF4 sufficiently cognisant of the ability of local governments, financially and resource-wise, to mitigate what we are seeing happening at Montrose and the likes? Or does it need to be stronger in mandating central government to provide the resources and the financing? That is a great question about the resource implications. I think that areas such as Montrose are the forerunners almost, where we are seeing these climate risks very imminently. You are seeing those impacts and they are a shadow of things to come. What is playing out in Montrose is that we have not had the benefit of time. I think that there needs to be much more recognition of the scale of this challenge and much more resourcing coming into it both nationally and locally. There are some excellent expertise in Scotland and some excellent partnership work happening, some really good evidence coming to the fore that is telling us more about coastal climate change risks, and some positive work has really started. Unfortunately, the scale of the challenge that we face means that additional resourcing is an essential part of what needs to happen. To see that strengthened in NPF4 would be excellent. That is very helpful and grateful for the answer. I believe that other panel members wish to come in, but I am not sure who. Make yourself known, perhaps not Liam. In that case, I hand back to you, convener. Great, Liam. Thank you very much. Next up is Natalie Dawn, to be followed by Monica Lennon. Natalie, over to you, please. Thank you, convener, and good morning, panel. I would like to focus on woodlands and ask the panel, is the wording on policy 34 on trees, forests and woodlands sufficiently clear and directive to guide development in a way that is sensitive to existing woodlands? Do you have any examples of additional public benefits in policy 34C that would justify the removal of woodlands? If I could come first to Anne, please. Thanks for that question. Sorry, Anna. Sorry, Anna. No problem, no worries. It's one small letter. Just around the role of woodlands, I think that one thing that I would like to see acknowledged through that kind of policy, but just more broadly across the natural environment content of NPF4 is just the state of the climate emergency that we're facing around existing risks to the natural environment, including woodland species. The latest UK climate change risk assessment was published last summer, which highlights that risks to the natural environment, including to pests and diseases into woodlands, have increased over the last five years and are an area that requires further action. We need to be considering that when we're considering the role of woodlands as part of the progress towards net zero in terms of their ability to provide those vital ecosystem services unless we protect woodlands, unless we enhance the health of woodlands, unless we focus on reducing risks from pests and diseases, so they won't be able to retain their current services, let alone deliver the enhancements that we need if we're to meet net zero. I'd like to see that kind of messaging strengthened a little bit more personally. Thanks for those comments, Anna. Can I come next to Bruce, please? Actually, the policy around ancient woodlands and veteran trees and stuff, we're actually really welcome. It's nice to be positive about aspects of the document since I was kind of a bit more negative about some of the early stuff. We're really welcome that, and we really want to see that carried through into the final document. If we could, in policy 34, strengthen that slightly to say that the dealt proposals must not be supported where they would result in any loss of ancient woodland, ancient trees or veteran trees or adverse impacts to the ecological condition, I think that that would actually be great by Scottish environment links view of the document. There's so many benefits that these trees bring in both urban environments but also in rural environments as well. There's all sorts of information available on the kind of financial benefits that they bring in terms of flood prevention, slowing the flow of water, sequestering carbon, reducing urban heat island effects and everything. Let's also just think about the huge cultural aspect of these trees within communities. How much seeing those trees out and about in green space can really help to make you feel better and really kind of tie a sense of identity to development as well. It's a huge welcome step. I think that that improvement in the policy around woodlands in policy 34, isn't it? Obviously. Sorry, can I just follow up on that? In terms of the additional public benefits that we're saying in policy 34C, are you saying that you would rather just see it strengthened so that woodland is protected not over the public benefits but you find that the most important thing? Yes. With a number of public benefits that these woodlands provide, there will be occasional exceptions to that, but overwhelmingly they provide massive benefit in terms of everything that is listed as well. There are also the mental health aspects of trees that are very important. Sorry, I'm not sure if I've sort of came across right there. Obviously it's seen the additional public benefits that would justify the removal of woodland, so I'm just saying that you would like to see it strengthened so that the removal of woodland would not be possible or would be an absolute last option. Yes, thanks for the clarification. Sorry. Thank you. No problem at all. I'll come to Ian last if you get anything to add. No, really. Not specifically about ancient woodlands. It still comes back to even the biodiversity point for me. We need to find ourselves that the extraction of virgin raw materials globally contributed 90 per cent of all biodiversity and water stress globally comes from our continuing extraction of materials. All of the stuff that is on the plan for reducing the impact of materials on our built environment going forward, making more of the buildings and infrastructure that we already have, making it more flexible, so we're not building things new. Clearly it's going to have a huge, if we stick to that and make that paramount to our plans going forward, then the stress, the pressure on our own environment by diversity loss and woodlands, etc., is going to be greatly enhanced, as well as globally. All of that is interlinked. We need to look at how important some of those other policies that are listed take the pressure off what we've just been talking about. It's critical both at a national level and at a local level. Thanks all. I have no further questions on that. I'll pass back to the convener. Thanks very much, Natalie. Next up is Monica Lennon to be followed by Jackie Dunbar. Monica, over to you please. Thank you, convener. Just before I go into my question, I think I heard Mark Ruskell refer to a moratorium on new integrators. My understanding is that ministers haven't confirmed a moratorium, but I have asked planning authorities to notify them of any new applications and decisions for energy for waste development. Perhaps we can get clarification on that later for the official report. It's good that we are discussing the role of incineration and energy for waste in the waste hierarchy. From 2011 until 2020, the total quantity of waste that was incinerated in Scotland has increased by over 200 per cent. It clearly is an issue worth exploring today. If we don't see a permanent ban or moratorium on new energy from waste developments, what should we see in national planning framework for in relation to the future role bearing in mind possible climate and nature impacts? I think that we have already heard from Ian Gullan today that NPF4 is missing the point on circular economy. There is a bigger picture here, but I would be interested to hear views from the panel, perhaps coming to Ian Fartons. I have mentioned you, Ian. I guess that my answer is probably too early for me to make a comment on the review, which will hopefully bring a bit of clarity to the future role of incineration in Scotland. Therefore, if we take recognition of that, we might just briefly mention things around maximising opportunities for heat from any energy and waste facilities that are built. It doesn't have a position statement on proposed incinerators without energy recovery. Whether they are going to be allowed or not, you could say that it could be more explicit on that. If we were going to have such infrastructure going forward, there is even just linking up with local heat strategies, heat and energy efficiency strategies in terms of the energy efficiency programme, so just recognising that there are other things that could be taken into account if future proposals for energy from waste were coming forward. We had to see what the review comes out with. There is lots to commend in the NPF-4 on circular economy. It says lots of really good things around body carbon and buildings and infrastructure, thinking about different materials, recycled materials and all our infrastructure, and making the best use of what we have already got, refurbishment, design for de-construction and the flexible use, which is hugely important. I just saw the end of the last panel when we were talking about 20-minute neighbourhoods, adaptability going forward, going back to Anna's point about the challenges that we have in terms of adaptation because climate change is already happening and how flexible can we make our buildings going forward. There are lots of good phrases and proposals there, but then it just goes into the waste point. I think that it just misses that point. The waste section is very much about the linear economy and what do we do with the waste, because how can we design infrastructure, how can we develop infrastructure that is around reuse, repair, refurbishment and it is not about big facilities. The circular economy is a much more distributive economy across the whole of Scotland. It is not about sucking materials out of all of the Scotland into some big factories in the central belt of Scotland, whether that is incinerators or not. It is about distributive materials and products in local communities, particularly in the highlands and islands, where we can really see economic regeneration, social regeneration, preventing loss of jobs and so on. There is a real opportunity here. I just think that that has missed in terms of how we could embed circular economy thinking and planning for some of that other infrastructure that is talked about throughout and obviously linking it into the protection of our natural spaces. Thank you, Ian. I think that Rosie wants to respond next. Thank you. Sorry, my request to come in was that it was on the Woodlands policy, so I am happy to stay quiet on that if the moment has gone. I can give a contribution. If you want to add in to Rosie, please go ahead. I apologise for taking us back to the Woodlands policy. At the time of that conversation, I could reiterate what others said, but in addition, I thought that that policy could ask more from developers. It is on the enhancement of biodiversity, whereas the policies that I have drafted are clear on the need to protect ancient woodlands and native woodlands and veteran trees. There is that step on, which is about the enhancement and what can we or planning authorities be asking of developers in terms of bringing forward plans for how they will be enhancing woodland creation, which has huge biodiversity benefits. That was all. Thank you for allowing me to come in. No, thank you, Rosie. I am glad that you have got your point on the record. I wonder if I can perhaps ask Bruce for a Scottish Environment Link perspective on the climate and nature impacts of incinerators or large-scale energy from waste developments. Just these points about clarity and how NPF4 aligns with other reviews. Does that link have a view on that, Bruce? Again, sorry to echo quite a lot of what Ian said, to be honest. If there is energy from waste facilities, there definitely should be a requirement to make use of that heat that is being produced. However, I think that we can question the place for energy from waste beyond the medium term, because we would really hope that we would have got to grips with a circular economy by its very definition of creating energy from your waste. You are not continuing that cycle circularity. That is where we are there. There are obviously a lot of issues around particulates and other things that are created from the incineration process. That would be of concern to us as well. We would probably question a net zero and a circular economy in place, whether there is a real place for energy from waste in Scotland. Does that happen? Thank you. That is really helpful, Bruce. Finally, Anna, do you have a take on this? I would just endorse Ian's point on the need to consider the circular economy as the main focus for MPF4 and thinking about the system-wide changes that are required to deal with waste in a more sustainable way. I would defer to Ian's judgment if he feels that that is not fully communicated through MPF4, but it would be good to see that strengthened. Okay. Just while we are chatting here, I am just thinking that we do not yet have the circular economy bill or that legislation in place. Does anyone have a view on the importance of that legislation coming forward so that everyone involved in making planning decisions knows that that is something that is really important? Ian's popped up in my screen. I wanted to give an example of something that I was talking about, maybe just slightly missing the point if I could use that phrase, because there is a bizarre statement in policy 20 towards the end. It talks about development proposals that will not be allowed if they directly or indirectly limit the operation of existing or proposed waste management facilities. Surely the circular economy is all about limiting the disposal of waste, but how does that work if we are all serious about proposals for reuse, repair, remanufacturing, repurposing of materials? Are they going to be stopped because they start to compete with existing infrastructure? It is a little bit about the language. It feels that that section is very much looking backwards, and we could be a bit more creative in what we are trying to do here. I think that the circular economy bill is hugely important in thinking about how that could help to frame the direction of travel going forward. Also, there are references to Government strategies. Clearly we have targets at the moment for 2025, but we are obviously working with Government on developing a route map beyond 2025 to hit the targets 2025 and beyond. The reference is there that things are moving as a very dynamic space, so it is not as hopeful for our 10-year window, so I am trying to make sure that we are playing in all those other things that are happening as well. I am glad that you mentioned policy 20 in MPF4, because I am looking at part of it that the development proposals for energy from waste should only be supported where it is consistent with climate change mitigation targets and in line with circular economy principles and should supply a decarbonisation strategy aligned with Scottish Government decarbonisation goals and be refused where the strategy is insufficient. I am a former town planner and I find all that a little bit difficult to navigate. We have heard about the shortage of planners and issues around skills. Again, you have mentioned part of policy 20, but I have read out another part. Do we think that we are creating some mixed messages here? I think that it is a bit of clarity about how the circular economy fits in or to the broader planning rather than just on waste. That is important. I agree and I think that it goes back to my earlier point about local authority planning officers and developers. How do you navigate through that in terms of what you are evaluating specific projects against? There is quite a lot in that list that he has just read out. There will be other things when you add in communities, social justice and all sorts of other economic development, job and all the other things that are taken into consideration and obviously mitigations. It is always about the delivery. These are high-level documents, strategies and principles, but what guidance is going to be made available to local authority planners to navigate through proposals? It is not about—I still think that it is reactive—what comes forward. It comes back to my earlier point, which is that we are going to be much more strategic in thinking about what infrastructure we need. There needs to be some sort of investment strategy that sits alongside that, whether that is public-funded or private-funded, that people can start to understand. How do we make those things happen, rather than just wait for people to come up with proposals and then try to understand whether it fits or not? We know the kind of things that we need to do, certainly we do, in terms of the circle economy and the infrastructure of the people who are beginning to think about how we can shape that. We need to do that nationally. We need to go back to your thing about national, what you call it, national natural parks. You have a national one or you have local ones. We need to make it all joined up, but we need to make the provisions for reuse, repair, refurbishment and redevelopment of opportunities across the whole of Scotland. It is not just—you cannot just do it—you know, here is an authority doing something, but nobody else is doing it here. We need to have a much more common approach. The strategic image comes back to a point that I made last week to another committee around local authorities absolutely have a vital role, but they also have a vital role to work together to bring that coherence, that co-ordination across Scotland to a national picture, particularly around resources. It is not yet absolutely vital to what they do in their own communities, but it is vital to how they can work together and really make the impact by working together. That is really helpful. Thank you for that, Ian. Do we have any more questions? Does anyone else in the panel want to add anything before I hand back to the convener? I cannot see anyone, so that is why I am asking. I do not think that there is, Monica. Thank you very much, Monica. Last up, the final question is from Jackie Dunbar. Jackie, over to you. Thank you, convener. To ask the panel a couple of probably different questions, if you do not mind. It is fair to say that everybody believes that a green field site should not be used if at all possible, and we should be using brown field sites whenever we can. How could MPF4 policies on the vacant and derelict land be strengthened to reduce the pressure on our green field sites? Thank you for that question. It is a really fun challenge. I wonder how much this connects to the place principle and about the involvement of communities in decisions about land that is a part of their community, often with post-industrial legacy and coming up with creative solutions and multiple use for brown field sites in ways that perhaps have not been done previously. I wonder if there is more that could be introduced there as we consider about how to make the most of those assets. That is something that springs to mind for me, but what is that? Thank you. Bruce, do you have anything that you would like to add? Yes, thanks very much. Quite often, because access to high-quality biodiversity green space is so limited in our urban areas, we find that brown field sites can sometimes become real biodiversity hotspots. Locally, I can provide further information to the committee on that if that is of interest, but you can find some really rare plants and species. We also know just from being around those spaces ourselves that they become popular walking places and informal path networks. We absolutely see the sense in that preference away from green field sites, but we have to keep in mind slightly the local importance of those sites to both wildlife and people. It would be nice to put a line in policy 31 around that. The return to a naturalised state is not likely to make sure that we are getting that balance that was mentioned previously by the committee member between the carbon importance and biodiversity importance. I am not sure whether Rosie or Ian would like to come in. I cannot see, convener. If not, I am more than happy to go on to my next question. That is fine, Jackie. Sorry, I am not getting used to being online when we are having a meeting like this. The climate change adaptation policies in the MPF4 places emphasis on the flood risk in the application of nature-based solutions. I know from where I live that we have a couple of SAD systems around about me, and they are totally different from one another. How well is Scotland currently doing in terms of the uptake of SADs, or sustainable urban drainage systems? Do you think that there should be standards and best practices that must be applied to ensure that they deliver maximum benefits? I think that I would probably go to Bruce again, needy, first. At the moment, the qualifier that is used around SADs ponds should be put in place wherever practicable. We would like to see that strengthened to an absolute really. They are very important. You also mentioned sustainable urban drainage as a nature-based solution. I would suggest that the MPF4 picked up nature-based solutions and used that in the glossary of terms. It is used a lot in the document, but it is really important that we define that properly. The IUCN, the international union for conservation of nature, defined nature-based solutions very well, and it would be very easy for the Scottish Government to pick up that and use it. The use of SADs, especially by-diverse SADs, provides not only the flood mitigation benefit, but also the biodiversity benefit that is essential from the Scottish Environment Lakes point of view. That strengthening around language would be welcome. I totally agree with you. As I said, I have two totally different ones. Just a two-minute walk from where I live and the nature biodiversity one is just absolutely brilliant with all the wildflowers and everything that comes out of it. Sorry, I am digressing a little bit. Rose, do you have anything to add on that one, or will I just go to Anna? Thank you. No, I do not have anything to add to what Brace has said. Thank you for that. You are just hearing me talk about your experience of walking past the beautiful SADs pond that gave so many more benefits and could really see just the power of that when they are well-designed and well-planned, that kind of blue-green infrastructure can deliver so many additional benefits and so much added value for people. I think that the ambition for that is strong within the current draft of NPF4. Perhaps examples such as the one that you provided really bring that to life and what that actually means in practice. There is a lot of talk about nature-based solutions, about blue-green infrastructure, but what you have described there and your personal experience is what that actually can mean for people in practice. Anything that we can do to really strengthen the multiple benefits and see that the challenges that we face because of the impacts of climate changing in terms of increased flood risk. Our responses to those can deliver many benefits for society. Yes, we need to reduce flood risk but we can do that in such a way that it improves quality of the natural environment, it improves quality of life, access to open spaces for people. I think that that is really important. If I may just pick up on one point, I think that you were quite right in emphasising that the current NPF4 just naturally flood risk is a key risk for Scotland and we've talked about coastal risk and flood risk this morning, which has been really important. I think that I would just like to highlight in terms of the national developments that are put forward within NPF4. I feel that there's a lack of connection at the moment between the low-carbon net zero ambition within the national developments and what's required in terms of climate resilience. I think that that needs to be strengthened because otherwise there's a risk of stranded assets in future if our net zero investments are not fit for a future climate. I think that the policy statements of NPF4 make that intention but it's not translated into the national priorities at the moment in quite the way that I would like to see, so just to dig way a little bit and make that point in case it's helpful. Thank you very much. Back over to you, convener, because I have no further questions. That's great, Jackie. Thank you very much and that brings us to the end of our allocated time and the end of our questions. Let me thank the panel once again for joining us this morning. Your contributions have been very much welcomed and we appreciate you taking time to join the committee session. The committee will share its findings with the lead committee on NPF4 at the end of this month and this concludes our evidence sessions on NPF4. I will suspend this meeting briefly to allow a change of witness and to get ready to hear from the minister for transport. Thank you very much. One and a half, okay, that's good. We're doing decimals, are we? We're doing fractions. Liam, I've got your WhatsApp message. Yes, I'll make mention of that. Welcome back everyone to our last public agenda item of the day, which is evidence session on Scottish statutory instrument 2022 for the workplace parking licensing Scotland regulations 2022. Those regulations are subject to the negative procedure. That means that they will become law unless, within 40 days, a motion to a null has been laid before Parliament. If a motion to a null is laid, the instrument must be debated by the lead committee, which is this committee. This instrument helps to pave the way for workplace parking licensing and sets out a number of practical considerations and issues. It's important that we have an evidence session with the minister and officials before we formally dispose of the instrument at our next meeting. I therefore welcome Jenny Gilruth, MSP, minister for transport. I also welcome officials who are joining us remotely. Heather Cowan, Elizabeth Hawley and Sandy McNeill. Thank you minister and officials for making yourself available for this session. I also welcome minister, I also welcome you to your new ministerial role and the committee also passes on its best wishes to your predecessor, Graham Day MSP. The committee is joined for this session by Graham Simpson, MSP, who is joining us for consideration of this instrument. Minister, I believe that you would want to make a short opening statement, so I will pass over to you. Thank you. Thank you for inviting me today to provide evidence on the workplace parking licensing Scotland regulations 2022. As you are aware, the power for local authorities to set up workplace parking licensing schemes was included in the Transport Scotland Act 2019 and further regulations and guidance are necessary in order for local authorities to implement those schemes. In line with the commitment made in our climate change plan update, the national transport strategy delivery plan and the Scottish budget for 2022-23, those regulations were laid in Parliament last month. The regulations will be followed by guidance for local authorities in the first half of 2022. The purpose of those regulations is to make detailed and technical provision on certain elements of the framework that is already provided by the Transport Act 2020, so that local authorities can use that tool that Parliament has provided them to implement workplace parking licensing schemes that suit their local circumstances. Those provisions will help to ensure that schemes operate effectively and fairly. As the previous Rural Economy and Connectivity Committee heard, having held an evidence session on workplace parking licensing at stage 2 consideration of the bill for the Transport Act 2019, workplace parking licensing schemes have the potential to encourage the use of more sustainable travel while raising revenue that will be used to improve public and sustainable transport. It also supports our commitment to reduce car kilometres travelled by 20 per cent by 2030 as part of our climate change goals. Those new discretionary local powers, which are already held by councils in England and Wales, are welcomed by our local authority partners in COSLA and by local leaders of all parties. It supports this Government's aim to put more say over local resources in local hands and a vision that has been supported by leaders across political parties too. I am pleased that those regulations have been laid so that local authorities can use their new powers if they choose to do so. My officials and I will be happy to answer any questions from the committee on the content of the regulations and the framework that they provide for local authorities. We will now move to questions. I would appreciate that there are quite a few members who have questions and I would appreciate brief responses if at all possible. My question relates to concerns raised that the regulations could be highly regressive in their impact. What assessment has been made to ensure that the parking levy will not disproportionately impact those on lower pay who might not be able to afford it, making parking at work the preserve of those on higher salaries who can afford the additional expense? It is important to reflect that there are assessments considered rather than the impact arising from the regulations and decisions that were considered and made by Parliament in the Transport Act of course were out with the scope of the impact assessments themselves as those were decisions, which would be for local authorities. You mentioned a point regarding potentially an inequality that this might create. I know from my own constituents and my own experience locally that poor areas, for example, have low levels of car ownership. We know that there is already a challenge there in terms of facilitating behavioural change, but we also know that car ownership is more likely to occur in richer areas of society. It is hugely important that local authorities think carefully about the introduction of the scheme itself. Of course, it is up to local authorities to make prescription for the scheme locally and to take into consideration some of the key issues that you raised with regard to inequality and how that might impact on staff members locally. Can you confirm the discretionary nature of that and that two or more local authorities can choose to jointly implement a licences scheme for workplace parking? Bring in mind, for example, a number of political parties previously have advocated that for the city of Edinburgh, but a lot of the commuters do not come from Edinburgh, they come from, for example, my constituency in West Lothian. What options are there for the spend from the levy to be co-ordinated between two local authorities? Fiona Hyslop for her question, specifically with regard to her first question, which links to the discretionary nature of the legislation. That is, of course, the discretionary power for local authorities, so it will be for the local authority to decide whether they wish to use that power and to shape proposals that will suit local circumstances. Local authorities will be required to undertake a public consultation and impact assessment before implementing a WPL scheme, which I think is really important and links back to the convener's point about inequity and how that might be tackled locally. They may also use revenues from the WPL to support the policies in their local transport strategy, which, additionally, is hugely important in terms of the revenue that the scheme will generate. To the specific point, no, with regard to whether or not the scheme can be accessed across more than one local authority, the member is correct that that is the case and that is built into the legislation currently. Thank you, Fiona. Liam Kerr, to be followed by Mark Ruskell, please. Thank you, convener. Minister, the instrument makes provision for schemes to be examined by a reporter, but only if the council chooses and it will be for the council to choose the scope of that examination. The reporter then goes on and decides the process and the timetable. Some might feel that that is the council marking its own homework. Under what circumstances would a council be expected to do that? How often, i.e., is the default position that there would be a reporter? What issues would the reporter consider when deciding the procedure to be followed at a public examination? I thank Liam Kerr for his question. On the specifics with regard to the scope or nature, in our guidance for local authorities, we will outline the themes that have emerged in the public consultation, which was undertaken to inform the regulations and guidance. That will include issues that were outwith the scope of the regulations, but local authorities might want to look at, given their own consultations and the needs of their own local communities. That guidance will also include referencing to the support that is already available to local authorities in existing guidance for best practice on consultation. Just to the timescales around that, which I appreciate, Mr Kerr might have an interest in that. I checked with officials this morning, and we plan to publish guidance in the first half of 2022. I would be happy to share more details with the committee on that specific point, because I appreciate that it has been raised in previous evidence sessions with the historic committee. Thank you, minister, and yes, I think that that would be useful. You correctly anticipated my question. Following on from that, can you tell me what consideration has the Scottish Government given to if a workplace is nowhere near public transport, or, for example, if shift workers cannot get home by public transport after a certain time? On a related note, what impact does the Scottish Government project such schemes would have on surrounding streets? Thank you, Mr Kerr, for his question. Apologies, convener. He asked an additional point in his last question regarding the role of the reporter. If I may come back on that specifically, it would be for the reporter to determine the process for examination based on the requirements that are set out in the act, and to look at the options available to the reporter for the examination on the basis of whether or not the reporter needed further information. It would be for me, for example, to direct the reporter in that respect. That is in line with the regulations on examination elsewhere, for example, around low emissions zones. Mr Kerr's additional question links to access in terms of public transport links locally and potential challenges that might exist in areas where that is not apparent. That would have to be a decision for the local authority to consider. It would not be for ministers to instruct, but he raises a fair concern. Of course, there is a requirement built into the regulations, which require local authorities to consult locally before bringing in any new scheme. I think that that would address Mr Kerr's point. I do not know if officials want to come in on further specifics with regard to the regulations on the historic consultation that was undertaken. Heather Cowan, I was just going to come in additionally to say that the act is also the requirement that the revenues arising from workplace parking levies cover, of course, the net cost, but are also available to support delivery of a local authority's national transport strategy. That might provide scope to support public transport within a local authority's area. I have one final question about measurement. The stated aims of the policy that you alluded to earlier include reducing car use and increasing the use of public transport. How does the Scottish Government intend to formally measure to establish whether the implementation of a workplace parking levy has caused the achievement of the aims? In other words, there is causation rather than simply correlation. On the same measurement point, how does the Scottish Government intend to measure the convener's point on whether, if employers pass the cost on to employees that we are not simply forcing the lower paid members of a company, say, on to public transport, while the higher paid members avail themselves of the parking space? To Mr Kerr's specific point on the measurement, this is a scheme that will be administered at local level. Given that local discretion is built into the scheme, we will expect local authorities to take it forward on the condition of the local circumstances in front of them. There will be a statutory application of the scheme—I do not think that that is nationwide, for example. That is what, for example, gave the idea of local authorities working together, which I think makes sense, particularly when there are blurred boundaries and people can meet across local authority boundaries, as it were. On the specifics of the measurement, it is a matter for local authorities to measure the impact in their local area. As to the aims that he sets out in relation to reduction in car kilometres, we absolutely expect that the legislation will drive behavioural change. He knows the importance of facilitating that model change and moving away from cars and on to public transport. He links, again, back to the convener's point about potential challenge in terms of inequity. That was considered, I think, previously with regard to how poorer employees might fail in terms of how they might not be able to afford the expense that this would incur upon them. It is important that local authorities take local decisions and then employers decide whether they want to pass that charge on. That links back to how a local authority, for example, might carry out its own consultation locally to look at the needs of employees. I very much hope and would expect that local employers and local authorities would consider the financial incumbents on the earnings, for example, of their employees, which I think is hugely important. We do not want to make that a prohibitive measure at all. In the second part of Mr Kerr's question, how do you make public transport more affordable? I think that there are a number of mechanisms that we have already undertaken in this space. Last week, for example, we had the launch of the under-22 bus travel scheme, and we also have the fair fairs review, which allows us to look at how public transport joins up, but equally how that funding is applied and charges are applied equitably, or not as maybe the case across the country. I think that that is a hugely important challenge as we move forward, but it is not a reason not to move to this scheme. I hope that Mr Kerr will understand my reasoning behind that. No further questions, convener. Mark Ruskell, to be followed by Monica Lennon. Obviously, where workplace parking levies have been introduced, they have raised millions and millions of pounds for public transport active travel investment. Is there a requirement on councils to invest in those types of priorities? The measure points to local transport strategies, which could of course be broader in terms of investment priorities than just investment in active travel and public transport. Is there a reassurance that we can get that the money's raise will be invested in the solutions that people need to get out of cars in the first place? I thank Mr Ruskell for his question. He is right to say that any revenue raised by the workplace parking levy must be used to support local transport strategies that can support greener transport choices and affordable public transport. In Nottingham, which Mr Ruskell has mentioned, it has its own WPL scheme since 2012, and the city has, among the highest public transport use in the UK, an associated decrease of 14 million car miles over the past 15 years alone. The revenue from WPL has also supported the expansion of Nottingham's successful tram system and the redevelopment and capacity enhancement of Nottingham train station, along with investment in bus services and electric buses. Nottingham council officials have also said that those schemes would not have happened without the workplace levy. They have also made grants available to support employers to put in place sustainable transport measures such as bike parking, showers, electric vehicle charge points and car park management systems, for example. To his question, there is a requirement that that would be reinvested locally. It speaks to the importance of local discretion for local authorities deciding on what their transport strategies and priorities are and using the funding to support it accordingly. Do you expect that, in any public consultation on introduction of workplace park and levy, there will be a consultation with public as well about what their priorities are so that they are able to see that there are alternatives coming down the tracks and not going to be long with paying for charges forever because there is going to be investment in those alternatives? Absolutely. There is a requirement for local authorities to consult locally with the people that they represent ultimately. It is imperative that the people who live locally have an opportunity to feed into what this looks like and how they experience the strategy to the specific point. Monica Lennon, to be followed by Jackie Dunbar. Monica, please. Thank you, convener, and good afternoon minister. Congratulations on your new role. Think about the licence. What type of conditions are likely to be applied to licences? Could the minister possibly give some examples of those and how, with compliance with conditions, are they monitored and resourced? I thank Monica Lennon for her question. It is, as I have mentioned in previous answers to other members for the local authority proposing the scheme but also for Scottish ministers or to determine whether they consider it appropriate for that examination to be initiated. However, the provisions and the regulations and act do not constrain why an examination might be initiated. Ministers and the local authority make the decision on whether to initiate that examination but only after the local authority has completed its own consultation and its own impact assessments and proposes the scheme to be made. It would be inappropriate to speculate on potential reason or scope of examination for schemes, since, obviously, no such schemes have yet been consulted on or proposed. I do not know if Heather wants to say more on the specifics of the regulation about your question. I can just clarify, minister, because I think that that was a different question to your answer, so sorry if I was not clear. I think that, once a licence has been approved, a bit like when you get a planning consent, you get conditions, do we know from learning elsewhere what conditions typically look like and how they monitor for compliance? Sorry, my dog's barking. I think that, in response to your question, it would be for the reporter to determine the process for examination based on the requirements that are set out in the act, but I might bring Heather in on the specifics. I think that the question is on the licensing conditions. I think that my colleague Elizabeth Hawley is happy to come in and, if the member has got specific points, we are probably happy to take it away. I am right on it, but if I can invite Elizabeth to come in first, if that is okay, minister. If it helps, I am just looking for examples of what conditions might look like. I know that it is a matter for the local authority, but from lessons elsewhere, for example, do we know what conditions tend to look like? Elizabeth will come in on that just now. I am not aware of any conditions that Nuttingham has placed on their licences that they have issued. Local authorities can make local exemptions. For example, Nuttingham has exempted small employers under a certain number of car packing spaces. Under the act, local authorities could also create a WPL that is only enforced in certain areas of their local authority boundary, or only at certain days of the week or certain times of the day. There are local exemptions, and I think that Nuttingham has made use of that under the English regulations. In terms of conditions, as I said, I am not aware of any that Nuttingham has imposed, but I am happy to look into that and double-check it right into you if that is helpful. That would be helpful. Thank you very much for that. Last question, then. Just thinking about driver behaviour change, I just wondered what modelling has been carried out first of all to look at the scenario where the labour is passed on by the employer to workers and the scenario when it is not passed on to employer is a modelling that shows perhaps different outcomes on that? I suppose that the only example of modelling that we would have would be the Nuttingham example to compare it to. I do not know whether officials are cited on that. I do not have that in front of me. Apologies to Monica Lennon, but I can certainly ask officials to share it with her, but I guess that the Nuttingham example is the best one that we know of, and therefore the modelling would exist because it is already in place and has been for some time now. If officials can confirm if we have that data, I would be happy to share that with the member. I do not have it in front of me. Apologies. I am happy to come in. Am I muted? I can look at the evidence for the Nuttingham. I know that there has been some evaluation and assessment of the Nuttingham scheme. In terms of the modelling that local authorities would do in Scotland, we would expect the local authority to look at that as part of their business case ahead of proposing the scheme, and that would help inform the decisions that are within their local scheme in terms of the design and so on. I think that it would be helpful for the committee to see any modelling or forecast. I am happy to hand back to you, convener. Jackie Dunbar to be followed by Graham Simpson. Jackie, over to you. Thank you, convener. It is more for clarification, if you do not mind, because we have heard some questions today. I am just a little bit worried that there might be some confusion with people in regard to who would be responsible for paying the licence. If I can get some clarification from the minister, my understanding is that it is the occupier of the premises who would be liable for it. I am aware that some companies are currently charging for spaces. Would that have the role on effect? Would that be any different to what is being proposed? Do not know if I have made that any easier or simpler. No, I thank Jackie Dunbar for her question. She is right. Employers would pay an annual levy to the council for every parking space that they have, and that would be for the employer to decide whether or not they pass on that charge or not to their employees. It is important to make that differentiation about the role of local authorities here and the role, additionally, of local employers and how employees will experience the charge or they may not, because their employer may decide not to pass on that charge. Officials may want to come in on the specifics of the regulations here in terms of some of the confusion that Jackie Dunbar spoke to, potentially. The regulations cover the circumstances in which persons other than the occupier of premises would be liable to attain a licence and pay the licence charge. That covers, for example, the situation where the member asked about, where an employer perhaps leases parking spaces from another provider. Where there is sufficient evidence of the parking arrangements between the provider and the employer, the requirement was passed from the occupier to the employer in that circumstance, and the regulations cover that. I think that I got most of that. Heather was very soft, so I think that I got most of it. Thank you, convener. Thanks very much, Jackie. Grim Simpson, please. Thanks, convener. Just going back on the Nottingham scheme and just out of information, just over half of companies involved in that scheme, it is just over 50 per cent, pass on the charge to their employees, so that is just a fact. That goes back to your very first question, convener. My question, though, is something different. Minister, I cannot see anything in the regulations or the parent act that sets a limit on what councils can charge for a licence. Can you help me there? I thank Mr Simpson for his question. First of all, he raises the scheme in Nottingham, which, as we have discussed today, has been running since 2012. It has helped to generate a fall of 40 million car miles over 15 years, but it is also worth saying that in its first six years of operation, it raised £53 million, which, of course, was ringfence for the following transport improvements. For example, there were two further lines on the Nottingham Express transit tram system, the upgrading of passenger facilities at Nottingham station, and on-going support for link bus network additionally. I know when the scheme was introduced that Mr Simpson was really keen that we needed to empower councils and give them a renewed sense of meaning and purpose. I hope that we support the legislation and the ability for local authorities to make that decision. That brings me to his question on the limit and the role of ministers or Scottish Government setting that limit. It is, of course, for local authorities to take a view on the limit that will be reached in terms of whatever they want to set the fee or the charge act. I think that it is important that the responsibility for local authorities to look at their own local circumstances and decide what that might be. Officials may want to say more on this. I think that just to add the consultation requirements that are on local authorities, they have to set out what their scheme entails, which would include the charge that a local authority proposes and that all needs to form part of the consultation of the impact assessments, which the regulation sets out the requirements for how local authorities must make that information available. I am quite astonished by that. The minister and the official have just confirmed that there is no limit whatsoever on what councils can charge for a licence, no limit whatsoever. That will frighten the life of businesses across Scotland. In fact, the Scottish Chambers of Commerce and Glasgow Chamber of Commerce, Glasgow being one of the cities where this could be introduced, saying that this levy should be scrapped or at least put on hold while we recover from the pandemic, is that not something that the minister has considered? I am listening to Mr Simpson's question. I think that some of what he is suggesting is on the margins of scaremongering in terms of the costs that will be incurred locally. This is a matter for local authorities to decide upon. If I were to come and set a top limit for this, I would be accused of interfering with local democratic principles. We have to get the balance right here. It is really important that local authorities are trusted to look at their local circumstances. They will consider any application through their own consultation processes, they will look at the needs of the communities that they represent and therefore I would expect them to set an appropriate cost accordingly. The regulations on penalty chargers are also in line with any other penalty chargers, so the manner of issuing increased charges for late payment information on penalty chargers most is, for example. I would be concerned that Mr Simpson is potentially earmongering on this issue. I absolutely trust local authorities to set these at an appropriate level, but at a level that is right for the needs of the communities that they represent. One very final point, Mr Simpson. If you are not scaremongering, there is a difference between penalty chargers, you are right minister to mention them. I think that the maximum penalty charge for non-compliance is £5,000. There is a difference between that and what I was asking about, which was the charge for the licence, and there isn't, as you have confirmed, an upper limit for that. I will leave it there. Minister, I want to follow up on the point that was made about the Scottish Government not imposing limits on local authorities. Of course, if you look at council tax by comparison, there was a limit imposed on what local authorities could do with council tax in terms of the upper increase amount. Why not follow that similar approach and have a limit on what local authorities can impose through the working living? The committee will appreciate that I was not imposed when this legislation was brought forward, but I can certainly bring forward or share with the committee the rationale behind the reasoning as to why we did not introduce a limit in this regard. Right. That would be appreciated, but you can see the concerns about this not on paper, but by regulation this being unlimited. You can see how potentially this could cause some concern for businesses large and small throughout the country who might have to pay this. I hear what the convener is saying, and I've been more than happy to share the detail of why that...