 Good morning, and welcome to the second meeting of the local government housing and planning committee in 2022. I would ask all members and witnesses to ensure that their mobile phones are on silent and that all other notifications are turned off during the meeting. The first item on our agenda today is evidence taking on the draft of the fourth national planning framework, or NPF4. This morning, we will be hearing from the Scottish Government officials. This is the first of five evidence sessions that the committee will be holding on NPF4. I would like to welcome to the committee Fiona Simpson, chief planner and Andy Kinard, head of transforming planning at the Scottish Government. Thank you for joining us today. We are going to move straight to questions and I am going to begin by asking if you could and I will direct this initially to Fiona. You could briefly outline how the Scottish Government engaged with communities and planning stakeholders in the development of the draft NPF4. Thank you, convener. The national planning framework 4 has been built from early engagement and collaboration from the start of the process. That has shaped the priorities, structure and content of the document as a whole. The process has been about much more than just consulting people on a draft after it has been prepared. We have taken an approach to co-production from the early stages of the process. First, we ran an open call for ideas in early 2020. That was followed by a fuller consultation on a position statement that we published later on in that year. Now we have a current consultation running on the draft national planning framework 4. It is important to say that throughout we have targeted different audiences, whether that is the professional sector or key sectors with an interest in particular policies or areas of the document, a wide range of organisations and communities. We have worked really hard at ensuring that communities can get involved as part of that, as well as working closely with planning authorities. We have used a variety of methods to do that, whether that is easy read materials, guides, events, using different techniques to involve people, drop in events so that people can just turn up and have a discussion with us. We have worked through and with networks, and we have done online, as well as in-person engagement. I would like to invite Andy Cunair to add some further detail to that. Yes, please. Okay. Thank you, convener, and good morning. I can just run through a bit of the detail. Our initial call for ideas ran from January to April 2020. That was a period of 16 weeks, which included an extension of four weeks due to the first lockdown. We received around 350 responses to the call for ideas. Supporting that consultation that our engagement programme had included an early session with the Scottish Youth Parliament, then on to a road show where we met with over 180 workshop participants plus 100 or so who attended the drop-in discussions. The road show attended 13 locations around Scotland, and we also had sessions at two schools at Bucky High and at Bedalben academy. Unfortunately, the last seven events from our road show had to be cancelled due to the start of the lockdown, but at that point we published a blog showing how people could get involved in other ways, and it was at that point that we extended that deadline by four weeks. We produced a resource pack to help people to be able to engage with us. That pack had maps and presentations and leaflets, a guide to holding community workshops themselves, some policy background notes, information on submitting national development suggestions, a guide to impact assessments and a housing technical paper. At that point, we also provided a community grant scheme offering small grants to support local engagement in events. Later in that year, in November 2020, we published the Scottish Government's position statement setting the direction of travel in our emerging thinking and drawing on what people had told us in response to the call for ideas. We hadn't previously intended to do that, but delays from the pandemic presented us with an opportunity to test our thinking. We ran a further consultation on that position statement over a 12-week period, and we received around 250 responses to that, about 20 per cent of those from individuals and the rest from organisations, including community councils, residents associations and campaign groups. Again, supporting that consultation with some events, we commissioned Paz, Planning Aid Scotland, to host a series of five community discussion events and some youth engagement involving a survey and virtual workshops at which 200 young people participated. We also commissioned the RTPI to hold four cross-sector ring tables under headings of post-Covid recovery, 20-minute neighbourhoods, achieving net zero and delivering good-quality development. If I may just mention going forward, we're building on those experiences. We're backing up our current consultation on the draft NPF for involving some open invitation-facilitated events, nine in total, covering the four policy themes in the five action areas in the draft NPF. Again, we've produced some online resources, including presentations, policy background notes, digital narratives and all the evidence that we received through the call for ideas and a position statement. We're just putting the finishing touches now and they're about to launch these open invitation events. We've again launched a community grant scheme to support community groups to help them to engage with us through the consultation. We're exploring with potential facilitators how best to further discuss with community groups. We just had confirmation that our bid for a workshop at the next Scottish Youth Parliament gathering in March has been successful. We're meeting this afternoon with Place Scotland to discuss further opportunities for engaging with young people. I think that I'll stop at that. Thank you very much for that. From both of you, it's certainly very thorough work that you've been doing and during this challenging time of the pandemic, a fairly restricting activity. I'm aware that the consultation is still running, but we've had several stakeholders who've questioned the Scottish Government running a consultation on the draft NPF during the 120-day period for parliamentary scrutiny. You can imagine that that does cause challenges. Could you please explain to the committee the Scottish Government's interpretation of the Planning Scotland Act 2019 in that regard? I don't know which one of you wants to pick that up. Andy, thank you. I'll pick that one up for us. We had been looking at the new statutory procedure for the NPF that was set by the 2019 Scotland Act 2019. In particular, in section 3C8, subsection 3, groups together, the requirement for ministers to consult in accordance with the participation statement and to lay before the Scottish Parliament the draft that we're currently looking at just now, but then to have regard to all representations received on those within the no more than 120-day period. I do appreciate that there can be a bit of awkwardness around running the two at the same time, but we feel that's the way we needed to do it to make sure that our requirement to take into account all of the representations within that 120-day period meant that they both ran at the same time. Okay, thanks for that response. I'd now like to move on to a question from Mark Riffon. Thank you. I just wanted to ask about competing priorities for planners and local councillers who will make decisions. MPF4 will be part of a redevelopment plan, and sometimes planners and councillers will be expected to balance competing policy objectives in different documents in that plan, but also perhaps competing priorities with their local communities, who may or may not be so supportive of what's in the plan. Are you able to set out what guidance the directorate is going to give to planning authorities and councillers as to how they balance those competing priorities? I suppose the first thing to say is that planning is all about balancing competing objectives and priorities. It's in the nature of what we do. Every development proposal is unique—the proposal itself, its location, how it relates to its broader context. Under planning legislation decisions on individual planning applications must be made in accordance with the development plan, but also taking into account all relevant material considerations. The policies need to be read in the round and weighed up together in decisions. It would be for the decision makers themselves to take into account all those relevant policies, including those set out in the NPF4 and those that are in the development plan. In drafting the NPF, we sought to balance providing clarity and certainty with the need for flexibility for decision makers to be able to account for local circumstances. It's very much in the nature of what we do. There won't be competing policies that things don't always pull in entirely the same direction, but that's what planning has to do and take account of each of them and attach the appropriate weight. You feel that the NPF4 and the associated documents lean more towards flexibility for local decisions, rather than taking a stricter approach? I wouldn't say that it's about the NPF leaning to flexibility. That flexibility is involved in the planning system. We want to ensure that the plan-led system operates well. The NPF, as part of the development plan, will do that. We want to make sure that our policies are as clear and as direct as possible, but the planning system is written in a way that allows for a bit of flexibility to consider all relevant considerations. I'm going to come in with another question. Can you set out how the national developments, including the NPF4, were chosen and how they will align with other Scottish Government policy documents? For example, none of the national developments appeared to feature in the infrastructure investment plan. Thank you, convener. I'll start off, and I may add further. Just to talk you through the process of how we selected the national developments, it's important to note that we issued a call for national developments as part of the initial call for ideas, but ideas also came from the regional spatial strategies, the indicative regional spatial strategies that local authorities were looking at, as well as responses to the position statement. We received about 259 suggestions for national developments, and most of those have informed the draft NPF. Some have been adopted as proposed national developments in the draft, and others are part of the spatial strategy. The suggestions that we received looked at either individually or as groups where there were similar proposals, and we considered them in relation to four criteria—climate change, people, inclusive growth and place. Those are criteria that are shared across a whole range of wider Scottish Government policies and programmes, so that helped to achieve the alignment that you mentioned. We also did a full integrated impact assessment, and that was an iterative process, so we took into account the impacts of the developments as we progressed the assessment. Some of the proposals were really good ideas, but perhaps they were not actual development proposals. Some were broad ideas that were already advanced—for example, they already had development consent in place, so we had to look at how the proposals related to the planning system. We considered all of that in relation to the emerging spatial strategy and the collaborative work that we did with local authorities to develop that spatial strategy. As the spatial strategy began to take shape, we asked ourselves which of those national developments can best support delivery of that spatial strategy. The proposed national developments in the draft are those that we think will help to deliver the spatial strategy to a degree that makes them more than local or regional significance. We have published a full report of the assessment of national developments on the Scottish Government website, and we are obviously seeking views on that now. In terms of integration with wider policies, as I said, those priorities that shaped the call for national developments and analysis are shared across a wide range of key policies and strategies, so that alignment should take place in that way. Thank you. Andy, do you want to come in on anything else? No, it's fine, convener. I think that we were both very keen to jump in there, but Fiona Scott covered it. Great. We are going to move on to another question, which is from Willie Coffey. Thank you very much, convener. Good morning to you, Fiona. I wanted to ask a broader question, if I may. We know that the NPF forward places the current Scottish plan and policy document. In future, frameworks will become a formal part of every local development plan. First, can you give us a flavour of what the more significant changes are that we are hoping to bring in with the framework? Secondly, are the local authorities themselves okay with it? Do they see it as an imposition on local flexibility in that sort of issue? I would be obliged for a response to that. Okay. There is quite a lot of change that we are introducing in the NPF, but I will try to walk you through some of the big changes. Overall, the document is really trying to focus on the key themes that I have already outlined. In particular, we have really looked at every policy and part of the strategy to see how it could best contribute to net zero, as well as the nature crisis. That cut across everything, but also in the context of recovery from the pandemic. There is a whole load of key drivers that draw significant change. We took into account the fact that the NPF will have a different status as part of the statutory development plan, and that is quite a change from NPF 3. We took into account wider policies and priorities and thought about what has changed. We thought about what the new requirements are that stem from the Planning Scotland Act 2019. Obviously, we have done a lot of early engagement, so consultee views also shaped what the priorities were. Crucially, we are thinking about how to have a special strategy that could be delivered through sound policies. The policies bring forward what was in the Scottish planning policy, but a lot of them have been significantly changed or updated, and there are quite a few new ones. I can run through in a wee bit more detail some of the big changes. Policies 1 to 6, the universal policies that we set out, are largely new. We have covered some key principles around the importance of a plan-led system, the climate emergency, the nature crisis, human rights, equality and discrimination—one of the statutory outcomes for NPF to address, community wealth building, a key theme that we want to see cutting across decisions, and we have updated our policy on good quality design. Policies 6 to 14, some of the newer policies here are around 20-minute neighbourhoods, infrastructure first approach, play and health. That flows from much of the debate during the planning bill but also some of the statutory requirements and our emphasis on the local livability that we think is really important for net zero in the future. Policies 16 to 23, look at productive places. We took into account the changing context for work as part of that. For example, Policies 16 covers things like home working and live work units. We have new policies on sustainable tourism, culture and creativity, and we have introduced significant changes in the draft to Policies 19 on green energy and on zero waste because we think that they have a critical role to play as part of the draft to net zero. The final section is around Policies 24 to 35 on distinctive places. Again, a fair amount of change here, so there are quite significant changes to policies relating to city, town and local centres. That aims to respond to the town centre review. We have a new policy on vacant and derelict lands. We think that that is really important to support sustainable patterns of development. Policy 31 on rural development has changed quite significantly. Again, we heard during the debate on the planning bill that there is a lot of emphasis on growing the population of rural Scotland. We have updated our other policies in this section, including on peat, carbon-rich soils, woodlands and trees and coasts to reflect climate change. There is a whole range of drivers that we have taken into account. What has changed since MPF 3 was published and what the Scottish planning policies said in 2014? We have worked closely with local authorities in a number of ways throughout the process, whether that is through the work that we have done with them on collaborative work at a regional scale to form the spatial strategy. Local authorities contributed to the call for ideas, and there are a lot of consultation responses from them. I think that 29 responded to the consultation on the position statement. They have worked closely with us on the housing land requirements and contributed to many of the policies. They were part of stakeholder groups, for example, on our work on the nature policy. They have helped us with research, and they have been engaged in different areas of the document. Much of that work has flowed through from our work on planning reform, which has been close working with local authorities. That is really thorough for you. I am sure that colleagues in the committee will pick out some of those items as we go along, but I will pick out one of them for my second question. I had previously raised the issue of derelict demand and shops building in land. You mentioned it near the end of your statement there. Do you think that it gives us local authorities any more powers to deal with those issues? When I look at the breadth of MPF 4, it looks great that there are a lot of good things in there. However, what I see as a local member and I saw as a local councillor for many years is derelict and abandoned shops, buildings and pieces of land and really limited powers that the local authorities had to try to affect change and to serve immunity notices and so on to improve the environment, particularly within our towns. Do you see the framework given as any strengthens additional powers in relation to that so that it can make some kind of contribution to the overall look and feel that towns and villages might need to have to support them going forward? I would say that the framework is about policy rather than powers, but we have tried to be very clear in our policy about the importance of this and the importance of good quality placemaking and how we can channel new development that the planning system deals with to improve our places. We have touched on delivery in the final section. That is still a work in progress because we are conscious that this is a draft document and more work will be needed on delivery. However, we have touched on the importance of thinking about how MPF will be delivered and thinking about the tools and mechanisms that could be there to support that. However, that fits within a wider picture of planning reform, where we are looking at moving local development plans, for example, to a 10-year review cycle in the same way that the national planning framework has. The aim of that is to bend a bit less time on preparing plans and more time on implementing the plans. That should free up a bit of resource in the planning system to do that. I think that the policy intent around vacant and derelict land and quality of place is very clear in the draft document. Okay, thank you. I can follow up on that. Thanks very much for that view and I'll probably get back to you, convener, to allow other members to come in. Thanks, Willie. I'd like to now bring Miles Briggs in. Thank you, convener. Good morning to Fierna and Andy. Thanks for joining us this morning. I wanted to follow on from the line of questioning that Willie just took forward with regard to renewable energy. Looking at the draft MPF IV, there are a number of questions with regard to the signal that it sends around the presumption in favour or not in favour of renewable energy developments. How was that designed? Is that your expectation when we are trying to meet climate change targets that there will be a presumption in favour of renewable energy developments across Scotland? Thanks. We have taken a different approach and used different language to presumption in favour, so each of the policies set out what should and should not be supported and we tried to make that as clear as possible throughout the document. The work on renewable energy, we have the policy intent that we have been very clear about from the start, which is to enable all sorts of technologies and renewable energy development as part of that, to recognise its importance as a contribution to the net zero agenda. We looked at the existing policy and looked at what could be changed about it. Obviously, we took into account a wide range of views from the consultation about how the policy could evolve. We considered wider Government policy and strategy to make sure that planning was aligned with that. We have updated the policy on renewable energy and it sets out that there is support for renewable energy development with regard to wind farms other than in national parks and national scenic areas. From that, we are expecting each proposed development to be assessed on a case-by-case basis. We have set out what the considerations are around that and we have tried to emphasise throughout the spatial strategy as a whole the importance of renewable energy, not just in relation to net zero but in terms of shaping the future of places and the opportunities that that provides for large parts of Scotland to achieve real benefits. I would also mention the new policy on climate that we set out policy to. That is giving significant weight to the global climate emergency as part of the process. Again, that is trying to underline the importance of those technologies. Thank you for that. The section on renewable energy seems to lack clarity and sometimes looks to contradict itself as well. I think that that is where there is a concern around different priorities being opened to interpretation. Obviously, we as a committee cannot amend the draft plan, but in terms of the consultation that you are having with energy developers, where is that discussion taken forward? We know that there have been a number of complaints previously that renewable energy developments have not been taken forward or that the time is taken within councils to get those taken forward or, in fact, being called in by the Government when they are rejected. What learning has taken place and what future development to make sure that that renewable energy comes on as quickly as possible into our energy needs? That is the benefit of being at the stage where we have a draft policy set out in the national planning framework, and that is the purpose of the consultation. We have engaged with all sectors, including the renewable energy sector, throughout the process. We have taken into account views that we have had, including on the consultation, on the position statement where there is support. However, the draft is the first time where we have set out in detail the policy wording. That is the stage where we are keen to hear views from all stakeholders on how the policy looks, how it could work in practice and whether they feel that we have the wording right to reflect the policy intent. That is the purpose of the consultation now, and we will be meeting with renewable energy sector representatives during the consultation process to discuss that further, as well as taking into account a whole range of views from all stakeholders. That is helpful. I wanted to move on to the recently introduced planning legislation requiring the Scottish ministers to set out how NPF will contribute towards meeting a series of outcomes, including around the needs of people living, particularly housing needs of all the people and disabled people. There has been criticism, for example, from the law of society, who questioned whether or not the approach is compliant with the planning act. If you could explain to us your approach to that and how those outcomes will be included in NPF 4. I do not know Fiona or Andy. The planning act places the new requirement that the NPF must contain a statement about how development will contribute to those six statutory outcomes. We included our first cut of that statement at annex A of the draft NPF 4 in the interest of transparency, and I appreciate that that is the point that the law society was referring to. That first cut cross-refer to some of the policies contained within the draft that we think will demonstrate how they will contribute to those outcomes. We have also included a specific consultation question just to explore the new requirement and the draft text that we have offered further to make sure that it is sufficiently robust to meet the requirements. We will revisit that with the benefit of the responses that we receive when we formally produce the statement that is required to accompany the final version of NPF 4. However, it may have been revised by that time. Thank you very much. I am grateful for that clarity. Just finally, I wanted to ask that it relates, as opposed to my initial questions, with regard to the new requirement on developers and planning authorities to life-cycle carbon emissions of certain development and for those to be assessed by developers. I just wondered about taking that policy forward and planning officers being tasked with doing that. What impact assessment has been undertaken to look at that new requirement? Has that been conducted or is that something that, during the course of this consultation, will be looked at? Because it could be very significant and potentially burdensome process for developers and individual councils as well. I will start to answer that, but Fiona may want to come in and join in. The assessment of life-cycle is something that we have considered in relation to all of the national developments that are required to do. The proposed national developments have had that assessment carried out. We appointed consultants to do that for us. There is also the requirement within the new planning act for all major developments in the future. They would also have that assessment carried out. We are going to build on the experiences that we have had through the NPF to then produce the guidance for how that would be taken forward for assessments on all major developments in the future. I do not know whether Fiona might want to add a little bit to that. Yes, just to add to that. We recognise that this is quite a challenge. As Andy said, we have drawn on work that was commissioned and undertaken by climate exchange to look at the methodologies that can be used in that. It is something that we want to see applied. In the policy, we have tried to take a proportionate approach where there is a higher level of assessment for national developments and major developments or EIA developments, where a fuller environmental impact assessment would be undertaken in any case. We have tried to take a proportionate approach. We recognise that there is possibly a need for guidance on that. We will look at that in the round, thinking about where the priorities for guidance are. Given the climate emergency, it is really important that planners are skilled and have the knowledge to be able to understand what the emissions arising from developments will be in the future to be able to make sure that the decisions that they make will contribute to reducing emissions in the long term. Thank you for that. Just before I hand back to you, convener, I wanted to look at that. It is an important issue and it is something that we should seriously consider at this stage. For a lot of developments, we have to look at life cycle carbon emissions. We have to look at the technology and how other schemes could reduce them before after they have been built, for example, community heat schemes. I know a number of those taking place in Edinburgh. Those developments are already under way, but there is the potential in the future. I just wanted to put on record the point that there seems to be a lot of carp before the horse is potentially now taking place in developments where they could actually have a lower carbon footprint, but they might not go ahead if that is not taken into account during the life cycle carbon emissions. I do not know whether you want to come back on that, but I think that we should be aware of that as well and that that could potentially prevent development as well. I just want to bring in Paul, who wanted to come in and pick up a bit more on the renewables theme, Paul McClellan. It is probably just coming back to the point that you said about that Miles Blake has raised, and it is about the renewables and the deliverability of renewables. Obviously, we had the Scott Wind announcement yesterday, which is great news and substantial planning requirements will come out of that. I wanted to ask Fiona first of all, Fiona, part of the NPF4 is about its deliverability. Obviously, Scott Wind is present in major opportunities, as well as existing renewables applications that are going through. I am just wondering what consideration has been given to, for example, our individual resource planning in that regard, because NPF4 is all about deliverability. Do we have the resource at the moment to deliver on the renewables? Obviously, in the future, in terms of delivering to Scotland, the proposals around which Scotland ensure that we do have, as I said, enough resource to deliver what has been proposed. Thanks. Scott Wind and the wider, longer-term future around renewable energy features right across the spatial strategy, where we have emphasised the importance of the blue economy, we have highlighted opportunities to fit with growing the rural population and the future for the islands as part of the low-carbon agenda. All that plays out across the spatial strategy. In terms of the resource, that is a very good question. It is really important that the planning system is able to respond to the opportunities that we have here. We are conscious of the issues around resourcing for planning authorities, and we do work through the high-level group with COSLA, Sullis and Heads of Planning Scotland and the Royal Town Planning Institute to look at resourcing of planning authorities. I think that this will be a really exciting opportunity for planning to show how a strong planning system that actively enables development and supports the smooth transition of applications through the system can contribute to the wider economy of Scotland and the benefits that flow from that. Planning can add a lot of value by thinking about what that means for our future places and how those benefits can be secured locally. I do not have the answer in terms of resourcing, but I am conscious that it is an important part of the strategy. We will be looking at delivery in more detail. We have asked the Scottish Futures Trust to take forward some work throughout the consultation period on the draft national planning framework to explore delivery in more detail. Some of that will focus on the national developments and some of the wider priorities that are arising from the different action areas. That is a work in progress at this stage. The important thing for us was to set out what we thought the draft should be and the detailed wording for a fuller consultation, but we are following that up with fuller consideration of delivery. Thank you, Fiona. I think that that is really helpful, because I will probably pick that up later stage in future discussions. There is no doubt that we will be discussing the NPF-4 on a regular basis in the next few months, but that is good to know, and I will probably raise that further down the line once that consultation has been done. Thank you. I will pick up on a couple of things. One, Fiona, you were saying earlier that one of the focuses of the NPF is about growing the rural population. One of the things that I am aware of being Highlands and Islands MSP is the tension between renewable energy potentially being something that can support rural population because it will bring jobs. What I am picking up is the tension between sticking more about onshore wind rather than offshore wind. Places that happen to have a lot of wind seem to get a lot of planning applications, obviously for renewable energy. What I am hearing from people is that tension because they also have or are growing a tourism sector. There is a tension between inviting people to a really beautiful Scottish landscape and to enjoy their time there and their visit in Scotland with the need for energy and the planning application. Where is the help for thinking well about do we concentrate renewable onshore wind in places that are consideration around that? It is important to remember that this is a framework. What we have tried to do in the national planning framework draft is to recognise that rural places are very diverse and that there are different pressures and challenges in different parts of rural Scotland. That was all informed by research that we commissioned on rural planning and that has really helped us to develop our policies. We are trying to set a balanced approach and there will be competing pressures. One of the things that we try to do within the spatial strategy is to set out a framework for emphasising that rural areas, low-carbon development in rural areas, will look different in different parts of the country and to provide a framework within which local development plans will play a crucial role in thinking in more detail about the balance of uses and a strategy for those different areas. I would go further than that and say that a really important part of planning reform has been the introduction of local place plans. We would want to see local place plans also bringing together communities to set out what their aspirations are for their area and for that to feed into local development planning from a community level. We have sought to achieve that balance. We have been very clear that the drive to address net zero is an overarching priority, but we have thought about how that can create opportunities for sustainable development of rural communities and try to create positive synergies, rather than just ignoring the conflicts and trying to bring them together in a positive way. I hope that that answers your question. Thanks. That is very helpful. I just want to pick up on the piece about local place plans, because I think that within the committee ourselves, but also talking to stakeholders, we do have some concern about—I know that we just—a statutory instrument just came through our committee—how will local place plans really be respected and honoured if we have a local development plan that is 10 years? How do you imagine if a community three or four years into that development plan realises that they want some agency and input into how things are being shaped or how the response to climate and nature is taking place? How will that be respected and given the power for the communities to have their say? I think that Andy Cunair was going to come in here. That was one of the specific points that was debated during the planning bill, during the last Parliament, on how we can make sure that a local place plan coming on mid-term of a local development plan can still have some influence. There are two parts to the answer to that. First of all, that local place plan would already become a material consideration in the planning system. Again, it would be for the decision maker to consider just what weight to attach to that. The act also allows for us to bring forward regulations covering the arrangements for an interim amendment of the local development plan. It would be possible for the planning authority, rather than reviewing the entire LDP, to amend parts of it that would allow them to bring the elements of the local place plan that they support on board into the formal development plan. That is another one, which is the MPF4 plan-led approach. There is a lot of focus on planning departments. It is quite concerning, because we have been taking evidence from planning stakeholders about the lack of resources. I wonder if you think that that there are the resources required in planning departments to cope with things like life-cycle emissions assessments. They are already stretched, and we are going to be asking them to do more things. What do we need in place to ensure that we have the proper funding, we have enough planners—that is the other thing that we have been hearing about—and many people, especially those like ecologists, to consider aspects that really need to be considered? We are very much aware that planning departments have seen reductions in their budgets and, ultimately, reductions in staff numbers over time. Although the overall resourcing of authorities is provided through the local government budget settlement, however, planning fees have a very important role in ensuring that applicants in the taxpayer cover the cost of determining any applications. We are probably aware that we conducted a consultation seeking views on updating the planning performance and fee regimes back in December 2019 through to February 2020. Implementation of that new fee regime, we had to postpone during the pandemic. However, we can recommend that work last summer with a view to laying new fee regulations, which we will do in the next few weeks, which we intend to come into effect this coming April. Those will see fees increasing in some of the cases by between 25 per cent and 50 per cent, so we are looking to get substantial more resource into planning authorities. Once we have increased those fees, we will be looking to monitor their impact and use that to inform our future work programme in relation to planning resources and performance. That continues to be a key priority that we have in working with the high-level group on planning performance. You mentioned the point about making sure that we are getting people into the profession. We are also supporting hops in the RTPI at the moment in their current work to encourage more people into the planning profession. We recognise that getting more funding in is only part of the story. The planners need to be out there. We have been picking up the work with hops in the RTPI and working closely with the high-level group and the partners in the planning group. That is another vital element of getting more money in one part, but making sure that we get planners into the system is equally vital. I am going to bring Miles in for a supplementary question. Thank you, convener. It is just following on from your line of questioning. It is an issue that every single MSP, MP and councillor, to be quite frank, are always concerned around. That is community building, where we see large-scale housing developments. I have faced this service the past five years with a significant house building that is going on across Lothian. The lack of forward planning with regard to health services, local primary schools, for example, and community facilities is genuinely how we build communities. I just wondered how the latest fourth edition of the national planning framework would help to change that going forward. I am not sure who wants to answer that specifically. I think that a few are coming in this one. This has been a key theme throughout planning reform since the work that we did way back in 2015 around infrastructure and planning. The importance of linking up house building with wider community facilities and services has been a really important theme. We have sought to address that in the draft, and there are a number of ways that we have done that. There is a new policy, for example, on 20-minute neighbourhoods. Thinking about things in the round is really what the concept of 20-minute neighbourhoods is all about. There is a new policy on taking an infrastructure first approach to development planning and to thinking about the impacts of development proposals on infrastructure. That is a really important message in that overall policy. We have also looked at the policies on housing. The Scottish planning policy set out a long and complicated way of calculating housing numbers. We are taking a different approach here in response to the statutory requirement. We are setting out what the minimum all-tenure housing land requirement would be for local authorities to work from. By doing that, there can be a focus more on quality and placemaking when you are planning and delivering housing. The emphasis is on thinking about housing as part of a wider place-based strategy. Alongside that, we are currently consulting on draft regulations and guidance relating to local development plans. That plays out the key policy messages in the national planning framework through to draft guidance, which provides much more information on how we would expect local authorities to go about preparing local development plans, what sort of information we would want to see in an evidence report and how they can then take that information and work through a special strategy and allocations of land in local development plans. I would also draw attention to one of the new policies under housing, which relates to the community benefits arising from housing proposals. We have added that in response to a wide range of views. There is always quite a wide range of views on housing proposals. We often hear from communities that they want to see if housing is taking place in their area and how that will impact on infrastructure and what the benefits would be. However, we also hear from the housebuilding sector and we heard from them during the consultation that people perhaps do not appreciate the benefits that are provided by new housing development. That policy aims to draw that out and provide a clear explicit statement for some applications that set out what the benefits will be for the local area. That is helpful. One of the key parts of that jigsaw is often the health board. The delivery of health services and GPs are private contractors to the health service, but in terms of any expansion in housing, they often do not see additional funding coming from the health board to provide those additional services. What change do you think is needed around that? A national planning framework then also impacts on health boards in additional funding or the reprovision of services to a greater number of people who, especially with new build developments, will often need young families to be in there and need a lot of additional health services. The approach through planning is to understand where there is existing capacity for starters when planning future development and allocating housing and to understand what the additional requirements are on top of that. There is complexity around infrastructure planning because infrastructure is provided not just by the public sector but by private sector, and there is a complex relationship between developer contributions that can be sought from proposals for development. We are trying to address that by encouraging authorities to work with others in preparing local development plans. A lot of the purpose of what we are trying to achieve from the planning system is not to expect authorities to plan and take forward delivery on their own but to work in a way that is collaborative with a wide range of infrastructure providers to understand what the capacity is and what else is required and how best to plan the delivery of that. It is a complicated process, but we have sought to address that through the infrastructure first policy. We have backed that up with the draft guidance on local development planning. We will continue to work on that as we explore the delivery programme for the NPF as well. Thanks, Miles. I am now going to move on to questions from Megan Gallagher. Thank you, convener, and good morning panel. Before I ask my questions this morning, I would like to refer members to my interests as I am a serving councillor in North Lanarkshire. My question relates to a topic that we have touched on slightly already, and it is in relation to 20-minute neighbourhoods. My question is, civil respondents to the committee's call for views have raised concerns that the definitions and delivery mechanisms for 20-minute neighbourhoods and community wealth building are not sufficiently clear. A concern for decision makers, given the quasi-judicial nature of planning and the planning process. I would like to ask the panel how those concerns will be addressed, and do they believe that there could be a conflict between the intention of bringing in those 20-minute neighbourhoods and the role and responsibilities of our councillors? Thank you. I will pick up that point around the definitions. We have included a glossary in the draft NPF, but we are conscious that people are raising questions about the definitions in there themselves or are asking for more references to be defined. NPF 4 is going to be a statutory document and will be approved by the Parliament and adopted by ministers. In that, the text needs to be fixed within the NPF. It cannot constantly evolve, so we need to be careful about overdefining references, but we can consider that further when we see what people are suggesting in terms of what they think the definitions should be or where we need to be adding more definitions. We can see what comes through people's responses. One of the other options could be that we include some working definitions and guidance outside of the NPF so that that allows the definitions that are maybe a bit of a moving feast at the moment to be able to evolve. We have a few options around that, but we are just being a bit wary about having too many really tight definitions, particularly of things that are still evolving. Thank you. I will pick up on that point, which is very briefly Andy Pais in relation to overdefining. Could that be open to interpretations between councils and, therefore, you could have 32 councils doing 32 different things in relation to bringing in those 20-minute neighbourhoods? I suspect that, to some extent, you can get that anyway, even when you are tight on the definition. We can certainly do all that we can to help to guide the understanding of what it is that we want the 20 neighbourhoods to be and to achieve. That is something that is moving forward at the moment anyway. It is becoming better known. Thank you, convener. Before I ask my question, I would just like to refer members to my register of interest, I am still an existing councillor, anesthershire council. Before I ask the question that I was going to be asking, I would just like to revisit, briefly, community benefits, if I may. I am just wondering if NPF4 and guidance that is going to come out was going to help local authorities to be able to zoom out, especially when there are multiple applications for housebuilding in a specific area and how they can make sure that they have the cohesive best use of those developer contributions. Sometimes, you have multiple applications for thousands of houses in a very small space from different applicants. I am just concerned that sometimes that does not always translate into the best use of those contributions. I do not know if Andy or Fiona wants to come in on that. Fiona, thanks. I will start off, but we have been looking at developer contributions. We commissioned some research on that. That is a parallel piece of work that has been running alongside the policy development. It is really important that we get that right. We looked at that when we introduced an infrastructure levy as part of the Planning Scotland Act. As I mentioned before, it is complex and there are different ways of delivering development. However, the important message is that we want local development plans to be supported firstly and corporately across a council. They are not just a document for planners, by planners, for planners, but they have that traction and support across a council. However, they are a tool for engaging much more widely, setting out what the requirements are and the expectations are for the development sector. They are inspiring others to get involved, or they are a practical tool for bringing together all the infrastructure requirements. It is a complex picture, but the key lies in having a strong place-based local development plan that forms the basis of decisions about development and is signed up to by a wide range of parties. That can bring a strategic view of a place. It can be evidence-based, it can take into account the challenges and opportunities for that place, and it can set out a plan of action that is supported by a delivery programme. Work in progress, but what we are thinking about in the NPF is how to provide a framework in which those plans can come forward. Policy 4 states that planning should respect, protect and fulfil human rights, seek to eliminate discrimination and promote equality. Those are outcomes that councillors—I know this as a councillor myself—policies and plans seek to promote those, but could you explain what that means in practice for planning officers and councillors on planning committees? It is not something that is forefront in their mind when they are taking planning decisions. It is not something that is thought as being a material consideration. Just to pick up on the language a little bit, when it says should, is that the same as must, if you could maybe speak a little bit to that? I am not so sure who wants to pick up. I have got Andy in the chat. Andy, if you want to pick up on that, thanks. Yes, certainly. Improving equality and eliminating discrimination is one of those six high-level outcomes that set in the planning act, which the NPF must contribute to. In planning, we can play quite a significant role through our choices and the decisions that we make to tackle inequality in society and to lead the development of places that improve opportunities right across our communities. That policy 4, we recognise that planning needs to respect human rights, to seek to eliminate discrimination and promote equality, and to make sure that we involve people meaningfully in making decisions about their places. Also ties in well with wider reforms such as the introduction of local place plans that will give people a better opportunity to get involved and to make sure that decision makers know and understand what they need and how they feel. Also policy 5 further develops that people-centred approach by support for community wealth building through planning decisions. Progressing on publication of the draft NPF4, we emailed around 70 equalities organisations to alert them to the consultation and asking them to publicise it across their networks. We are also holding on equalities around table discussion at the start of March, which we will be able to explore further. We are looking forward to the feedback that we get on those points to help us to embed that focus on reducing disadvantage through the choices that are being made about places. We will pick up that point about the use of language and whether we should be saying must or should. We followed a convention across the draft that we would only use the term must where that relates to a statutory requirement and then bring in should where it is something that is much more a matter of policy or practice. That should not be seen to read as should as a weakened message, but it is still an expectation that that should be done. We just have to be a bit more careful in the wording, especially if we were to say something that a proposed development must be supported or must not be supported in a particular circumstance because the planning act requires that all decisions are made in accordance with the development plan and also considering all relevant material considerations. We just have to be careful not to bring forward a policy that would push the position that a decision can swing or should swing just on one policy point without taking proper account of everything as required by the legislation. I hope that that helps to clarify that point. Thanks very much for that, Andy. Just to pick up on a little point before I hand back to the convener, in terms of training and skills development for those who are on planning committees and indeed the planners within those departments, does that seek to put qualities on an even level playing field in terms of all the other material considerations? Should that be brought up further to the councillors on planning committees or planners themselves when they are taking a decision? It is just to understand how is that going to work in practice for those who are taking those decisions? I should probably just start by stressing that there is no hierarchy within the policies that appear in the NPF. It is very much for the decision maker to consider everything that is relevant and to attach the weight that is appropriate. In terms of skills development, that is something that is across planning and including for councillors sitting on committees. Things have changed over time and there are always a bit of new thinking that comes into the system. That is something that we will work with a high-level group on in terms of the skills for the planning services. There are also provisions that we have stolen to bring forward in comments from the 2019 planning act that we will look at elected member training, so how we can set up what the priorities should be for that elected member training within planning. It was another one of those provisions that fell foul of the pandemic and the change in our priorities that came along, but that is something that we are looking again to pick up on later this year so that any new ideas, new thinking, new priorities that are coming into the planning system, including through NPF4, will be able to make sure that there is a reasonable prospectus for member training going forward. That was good to hear, Andy, because underlying a lot of what we have to do in response to climate, nature, emergencies and equalities is really a change in thinking, a change in mindset, and that really has to happen in the training. It is not just going to happen necessarily in people by themselves, so it is good to hear that that is being considered. I would like to bring in Mark Griffin with a couple of questions. Thanks, Camilla. I just wanted to ask about the deliverability of a number of the proposals. There are a lot of very desirable proposals that communities will want to see delivered, and just to ask if there could be any thought to producing a document just setting out the Scottish Government's capital investment plan to support those proposals so that they can be scrutinised in the round and for communities to get a better idea of what will and perhaps wouldn't be delivered. Thank you. I can come in on this one. We have mentioned this a few times before, but our work is under way on our delivery programme. Obviously, we are being very careful, because we are conscious that this is a draft and it could well change, so putting down a delivery programme at this stage is probably not the best thing to do, but it is really important throughout the consultation process to have a conversation about deliverability. There is a wide range of partners involved in public and private sectors in delivery and communities as part of that. We need to think about how things align rather than having a single dedicated capital investment programme. It is how planning is a tool for implementing those programmes, but it also helps to shape those as they evolve. Obviously, it is complex and we are conscious that this is a draft, but the Scottish Futures Trust will be leading some collaborative work on delivery, and that will bring together stakeholders as part of our engagement programme to think about how we can have a shared delivery programme to take forward the national planning framework. Delivery programmes will have a really important role to play as part of the local development plan process. We will be able to take into account things like the infrastructure investment plan, the recommendations of the Infrastructure Commission for Scotland, and the place principle. As planning is about place, the place principle is about how to get people working together to support delivery of change in a positive way, and in a way that provides much more benefit because they are aligning and because they are working together to really focus on what is special about a place, what needs to change and how can we achieve more by working together. The outcomes from all the work that we are taking forward on delivery and will progress will be a delivery programme that will accompany the finalised draft of the NPF4 once it is approved and adopted. We can take it so far at the national planning framework level. We would expect authorities to pick that up in their delivery programmes for their local development plans. However, the main point of all this is to get people behind planning and to make sure that planning influences how people work together in places. Thank you for that. I take a point about delivering plans not being in place until a final document is approved. To go on to the work, the long-term nature of deliverability will be in place for much longer than its predecessors in now 10 years as opposed to five. I will continue on that theme of deliverability. How will that longer period of time impact on when any reviews might take place, how progress of implementation is tracked, how it might be amended if possible, given the longer time scales involved? We learned a lot from national planning framework 3. For that, we had an online delivery programme that acted as a way of monitoring how things were progressing following the NPF3. We tried to build shared ownership of that with different lead partners for the existing national developments, etc. However, planning is quite hard to monitor, because a lot of the change that planning brings about is long-term. That is important to bear in mind. However, we will look at how we monitor implementation as things progress and look at how that collaboration is working. The monitoring is a requirement for some of the impact assessments, too. Andy Cunair wants to come in further. I will say a bit about the review and amendment. The NPF can be amended in the same way as local development plans, as I mentioned earlier. It can be amended without a full review and replacement if it is appropriate to do that. We want to consider the case for making any amendments alongside the confidence that comes from maintaining an established policy framework. However, the new provisions that were added by the 2019 planning act require that the NPF must be reviewed at least once every 10 years. However, the act also allows for Scottish ministers to amend the NPF at any time. It enables us to make regulations that will set the procedures for future amendments. It also requires that we must set out in regulations the circumstances in which an amendment would mean such a significant change that a full review would therefore become necessary. However, we have not progressed those regulations yet, but we intend to do that once the NPF has been adopted. We are expected to bring forward our proposals for review and amendment of the NPF later this year. We have already touched a little bit on housing, and we are going to shift it a bit more and focus on that. I will bring in Elena Witton for the question. One of the stated aims in the draft national planning framework 4 is that it wants to support the delivery of high-quality, sustainable homes that meet the needs of people throughout their life. I want to touch on what Fiona Hyslop has already discussed, which is the minimum all-tenure housing land requirements. How do those figures differ from the arrangements that we have already got in place at the moment? We have gone through a different process at the moment. There are requirements set out in the Scottish planning policy, and each local development plan, often working within the context of a strategic development plan, looks at what the housing land requirements are. We took a different approach in the national planning framework, where we took forward collaboration to think about how we could come up with some clearer figures in the national planning framework. That is designed to be a bit broader and more flexible than previous approaches to calculating housing numbers. It is expressed as a minimum all-tenure housing land requirement. The focus is on how many homes we expect to see built. It is more focused on how much land does each local development plan need to allocate. The reason for that is to focus on land and its role in the overall development strategy. To do that, we took a different approach. We did some work across Government with housing colleagues and the Centre for Housing Market Analysis to set out some initial figures that were defined using the housing needs and demands assessment at a national level. We did collaborative work with each local authority. We sent them the numbers, and they had an opportunity to consider the numbers and to come back to us with their thoughts on how they wanted the figure to change. We have set all of that out in a full explanatory report, and we have also set out our assessments of each of the local authority areas in detail. The purpose of all of that is to try to provide that clear steer to make it flexible. A local authority can change that if it comes forward with its local development plan. It can work with the minimum all-tenure housing land requirement, and if evidence indicates that it needs to change, it can increase that if it chooses to do so. That is the overall process that we have undertaken. I hope that answers your question. I have a wee further question on it. I am specifically thinking of the two local authorities that my constituency covers in terms of rurality, where they have come back and said that the Honda analysis and figures are based on population at the moment. However, what we are seeing is that the pandemic has given rise to people seeking to move back into places such as Ayrshire, where we saw a depopulation happen previously. Do you think that the flexibility allows for that type of change and reflects the numbers of houses that are perhaps required that we did not perhaps think where in the past? We have already introduced a flexibility allowance to the figures, so we took the output of the HNDE and added a quite significant level of flexibility, reflecting the fact that that is a long-term plan for a 10-year period that we are planning for. We added 25 per cent flexibility for urban areas and 30 per cent for rural areas. That was in the initial figures. Authorities could look at those figures and provide adjusted estimates on top of that. That is also one of the benefits of having a minimum requirement. You can go much further than that, but it is the amount of land that is set out as being a minimum that you would be planning for. Having said that, in the consultation that we are running on development planning and the guidance associated with the new regulations on local development planning, we are also changing the way that we want to see authorities allocate land for development. We are keen to establish a pipeline of allocated land for housing that will identify short, medium and much longer-term development. The policy in the NPF is designed to allow for some flex between that. If you have an area where land is allocated for housing development and that land is being used up and you are starting to see that there is more demand or you want to stimulate the demand in areas where the market perhaps has less interest but you have place making objectives to attract development, then you can bring forward land from the longer-term part of the plan that is thinking much longer term. The aim of all that is to try to have strong but flexible local development plans that can work with the level of take-up of land that is sufficiently flexible. Thanks for that. Finally, in sticking with that flexibility issue, planning democracy and its submission to the committee are asserting that there doesn't seem to be any rationale behind the flexibility. The figures are sometimes about 77 per cent over and above housing needs demand assessment figures. They have concerns that that will give rise to speculative housing building across the whole of Scotland. How would you respond to that? It comes down to flexibility. If you have a long-term plan and it is flexible, you are on the front foot where you are thinking about what land will be required, not just immediately but in the longer term, then you can take a planned approach to that and you can be proactive in your local development plan to look at how you want development to be distributed across your area and how it can fit with the infrastructure first approach. Although the figures are set out as a minimum, you can work with all that to think about how that development can be distributed to best improve that area over the longer term. The figures are not. They are evidence-based. We have been clear about what the evidence is when we set out to use the HNDA tool. We have added the flexibility allowance given the 10-year period that this is relating to. We have taken into account what local authorities have come back to us when we have shared the figures with them and asked for responses. Overall, there is a positive approach to enabling good quality development. To do that, you need to plan up-front where that development should take place. Thank you very much. I want to continue on that theme a little bit. Some of the concerns that I have heard are the situation in which housing happens in communities that developers own land. I understand what the local planning department does is put out a call for the land supply and the generosity piece that we have spoken about. What people have been raising to me is that, up until recently, we had not realised how important it is to protect our peat land and to potentially shorten our supply chains and grow more food locally. Our farmland is going to be in limited supply. What we do about situations where developers may have land that is in the long run with a shift and our just transition and bringing things more locally, if they bring forward land that is better for farming or better to be protected than building on, I wonder how we handle that situation. That comes back to looking at how the policies work in the round within the national planning framework. We have set out a whole range of different policies. Some of those policies relate to specific types of development proposals that we would expect to see, some of them relate to areas where we would want to encourage certain types of development. Others are about locations or features that are sensitive and that we want to see protected and where possible in hands. Looking at those in the round, it is about balancing all of that up and coming back to the balance that Andy Kinaird raised earlier. I would still come back to a plan-led approach that has a clear vision for an area and is very place-based. Recognising the particular features of an area is what we want to see as being the effective way of guiding development in the future. When it is introduced, it does not apply retrospectively. It is about evolving and transitioning into sustainable patterns of development in the future. I will move to a few questions from Paul MacLennan and then Willie Coffey will come in on a supplementary. We might go over a little bit of our time, but I think that we are okay. I should have mentioned that I am referring everyone to my research system and I am serving cancer and easel in cancer at the moment. It is really just to yourself, and it is really just expanding on the minimum all-10-year housing and land requirement. A couple of questions. One is about the cover of a 10-year timeframe. You are touching us already on how the changes in housing will be accounted for during those 10 years. You have already touched on the hondas and the housing needs in local authorities. How has the approach that has been taken linking with local housing strategies? Ten years is a long time, as we know, in planning requirements. It comes back to the issue that you talked about flexibility. Do you know if there is anything else that you want to add on? I am probably coming back to my time as a councillor as well. In the past 10 years, things have changed dramatically in my own local authority. It is really just to touch on that point, if you do not mind. I think that the overall approach that we have taken to the policies on housing are designed to remember that it is not just about planning. It must be about planning joining up effectively with housing. The local housing strategy has a really important role to play. The role of shared tools, such as the HNDE, is really important. We have designed all of that to be flexible. We are conscious, for example, that a local housing strategy runs to a shorter timeframe—it is four years. If a local housing strategy came forward and was resulting in significant changes or suggested that you might need to look again at your local development plan, the beauty of some of the new provisions of the planning act is that rather than having to go back to the beginning and review your whole plan, you will be able to update it in part and will bring forward regulations on that. There is flexibility in there to allow for that read across with housing policy. Ultimately, housing and planning need to work together to deliver that. That is quite clear messaging that comes from Housing 2040. It is going back to having a minimum but also a plan-led approach with a flexible pipeline of housing allocations. It would mean that plans can flex but have that strong core spatial strategy and vision. I will give you a supplementary question if you do not mind. It comes back to the deliverability side of things. Do we look at how we monitor deliverability over a period of time? I know that that is difficult because every local authority is in a different position. In terms of deliverability, is there a mechanism in place to measure that if a local authority has only delivered 20 per cent of its allocation within that 10 years and more to seven or eight years in? That is going to create a problem. Is there a mechanism in place that you have in terms of that to look at that over all local authorities and overall within Scotland? Yes, there is a lot of debate on all of that within the planning system at the moment. What we have sought to do in the guidance on local development planning is to look at that. I think that housing land audits could play a really important part of that process. Local authorities prepare them at the moment but they are done differently in different areas. That is an area that we would like to look at so that housing is informed by information that everyone is signed up to and everyone is clear rather than having lots of different interpretations of the numbers and how things are progressing. That is an important area to look at for local development plans. We have covered some of that and what we are expecting in the guidance on local development planning. I would like to bring in Willie Coffey on the theme of urban transformation. I thank the convener for allowing me to come back in. Just as colleagues were talking here, I was having a look at the central urban transformation section of the document in relation to what I was asking about earlier. It seems to me that the policy intention here is to talk about major disused sites and areas that have been blighted by dereliction in the past, to open cast and stuff like that. However, what I am talking about is our high streets and the blight of abandoned empty filthy shops that trees and bushes have grown out of and bits of abandoned land within the urban envelope. I am backing up the wrong tree here for you and are these powers best left to other areas of existing planning enforcement or do you think that we can reach out and tackle those kinds of issues within the framework's proposals? That is very much what we are trying to achieve. We are recognising in the policies and the town centre reviews that inform us about how places are changing and how, although planning has to focus on new development proposals, it is responding to applications that come for development. We are doing that in the context of thinking ahead within the local development plan of what the future vision is for our place. In the central urban transformation zone, we are talking quite a lot about reinventing and the future-proofing city centres. We are talking about different uses that could be supported and that will require some imagination. There is a different thinking to think about how those areas can be developed in the future. There is a new policy on town centre living, backing that up as well and getting the balance right between the range of uses that will be really important for those areas. I hope that that goes some way towards answering your question. I am sure that the other members are seeing this in any town centre or high street in Scotland. There are loads and loads of empty shops that, in my opinion, are being left to rot. I have tried this in a number of occasions to get the owners or the agents to do something about it, even to clean them. Even a simple request to clean up a building and make it look a bit more appealing often falls on deaf ears because it all comes down to cost eventually. The noble aims within the document that we have to do future proof and reinvent our city centres—how do we bridge that gap? Do you think that when some owners or agents will simply refuse to clean up a building in a shop and get rid of the graffiti that is stuck to a window, how do we achieve that? Is that the right place for us to try to attempt to do that? I think that some of that may go beyond planning. I do not know if Andy Cunair wants to come in to mention anything about enforcement powers. Hi. I am happy to do that. You mentioned yourself earlier that the access to amenity notices is one of the range of enforcement powers that are available to authorities just to require that clean-up to happen to some extent. That is certainly one of the areas. Also, running parallel to the policy that is still going through a wide transformation of the planning system— Excuse me, Andy. Sorry. Your mic is a bit close to your mouth, so there is a lot of kind of light. Let's see if that works. Try that again. Alongside the policy review, this is one part of a much wider transformation in the whole of the planning system and how it operates. As part of that, we have a commitment to look again at land assembly. Supporting the push to have more investment coming into town centres, we have proposed also to look at how we review and update compulsory purchase powers and also to take a look at compulsory sale order powers in the future. We have a commitment to look at that with a view to legislation coming forward later in this session of Parliament. The policy driver and the NPF are certainly looking to get more activity happening within town centres, but so much of what is happening across the whole planning reform agenda is interlinked and some will require new legislation or just such that change of mindset. Just very lastly, Ariane, on that immunity notice issue, Andy, if a local authority serves an immunity notice on an owner or an agent of a shop or a building and it is not carried through, not action or challenge or whatever, does the burden then fall on the local authority to complete the action? I have heard that that might be the case and perhaps that is why so few immunity notices are ever served. Is that again? Authorities have direct action powers that they can take and then fill the owner for the work. I know that there has been difficulty in recouping the costs in the past that the new planning act had looked at new powers that would allow authorities to place charging orders on to a property to make sure that they at least get that back at some point. The authorities have the powers to take it on. Thank you very much for that. I just wanted to ask the question that Mark Griffin had earlier about the process of monitoring and reviewing the NPF. What trigger would be in place? What could trigger a review before the 10 years? Maybe we will go with Fiona. I think that it is impossible to set out that. I think that it is a case of you will know when you see it. I think that it would be where the NPF needs to change because something significant has happened or there is a very significant shift in policy. We have designed it to be flexible in that way and struck a balance between providing certainty and predictability with that flexibility, so I would hope that it can stand the test of time. However, we will be looking at how the circumstances have changed and whether that means that the planning response needs to change significantly. I think that it is important that we are creating a document that is somewhat, yes, evidence-based but somewhat abstractly with a lot of changing context with climate and nature emergencies. It is good to hear that there is this potential for flexibility and that, yes, reviewing is considered an important part of it. That is the end of our questions. Thank you very much for joining us. It has been very helpful to hear how the thinking behind how this complex document came into being and to hear from the beginning and what you laid out about how so many different stakeholders were engaged in the process. It has been very useful for our evidence sessions with us this morning. As part of our approach to the NPF 4, we will now consider the evidence that we have just heard in private and I will now close the public part of the meeting and we will move into private.