Our Evidence to National Planning Framework Consultation
In December 2021, the Scottish Parliament’s Local Government, Housing and Planning Committee has opened a call for views on the National Planning Framework (NPF4). The Scottish Government made this NPF4 explainer video if the framework is new to you.
Culture Counts has submitted written evidence to the call for views. You can read our evidence in full below. To reduce energy consumption, please only download the PDF if you have to.
Consultation and development of the draft NPF4
Please provide your views on the consultation and development of NPF4 and how this has contributed to the draft.
Given the constraints due to Covid-19, the consultation that has taken place is accepted.
The consultation has been well organised and it has been very clear how to be involved.
However, the early stages of the consultation (2020 events) were tightly controlled, questions and topics for discussion were decided in advance. This causes discussions to be partly pre-determined. The events were very well designed and facilitated, though I wonder in future if we could open it up a little so that less is predetermined.
I would appreciate it if the Scottish Government would consider signing up to the principles of the Design Justice Network.
https://designjustice.org/principles-overview
Please provide your views on the structure of the National Planning Framework 4 document.
The structure is clear, and the visual design is good.
The 'purpose of planning' statement is good (page 3, para 1), though it’s a little bland and lacks a feeling of ambition and action.
For example, a re-write where I change the language to be more positive would look this:
“The purpose of planning is to ensure that we develop and use land to build a wellbeing economy.
We want to create great places which centre our ambitions on future generations, improve health and wellbeing, restore biodiversity and adapt to climate change.”
What is your view on the 'Action areas for Scotland 2045' section?
Action 2: Support the Blue and Wellbeing Economies
It may be useful to include a definition of Blue Economy and Wellbeing Economy within this action.
For example:
Blue Economy
The ‘Blue Economy’ is an emerging concept which encourages better stewardship of our ocean or ‘blue’ resources. It underpins the thinking behind the
Commonwealth Blue Charter, highlighting in particular the close linkages between the ocean, climate change, and the wellbeing of the people of the Commonwealth. (Source: https://thecommonwealth.org/blue-economy)
Wellbeing Economy
A Wellbeing Economy is certain about going ‘beyond GDP’, and to complement – or even replace – the metric with a broader set of social and environmental indicators fed by the ever-growing amount of publicly available data on wellbeing. This is what enables the Wellbeing Economy to tackle some of society’s most looming issues such as loneliness and mental health problems, as well as complex climate and environmental challenges. (Source: Wellbeing Economy Alliance)
This section misses out the arts, museums and creative industries. It's important to remember that residents and tourists are also interested in attending art galleries, cinemas, museums, theatres and music venues. There is good inclusion of heritage via the tourism sections and world heritage sites.
There is a need to include arts, museums and creative industries in this action, otherwise we're making assumptions about what people want to do with their time and missing the opportunity to offer people a sense of belonging and connection.
When we're thinking of improving outdoor infrastructure for camping for example, we need to also consider what will people be doing, what's the view from the tent? Is there a bandstand or potential for a natural amphitheatre?
If this action included arts, museums and creative industries it may look like this:
'Arts, museums and creative industries are a key sector, improvements in infrastructure and internet connectivity will ensure this sector can continue to make our places vibrant, interesting and beautiful. The sense of wellbeing of residents and visitors depend on the offering of opportunities to connect with each other, this is why the arts, museums and creative industries are important, they offer a chance to make a connection, a chance to belong, and this should not be overlooked.'
We need to remember that it's not always possible to be outside in Scotland. We need to design outside spaces to keep the wind away, maximise light etc. We have to prioritise user-centred-design.
Action 19: Grow a wellbeing economy
This action reads a little like we should focus on economic growth with the understanding that we should remember to think about how there might be hidden wellbeing impacts coming from the traditional view of economic growth. The focus seems to still be on traditional forms of economic growth, with a nod to other additional potential benefits. This will not lead us to realisation of a wellbeing economy.
This action misses out valuable jobs and industries, such as software and games development, a key growth sector. If we want to attract people to Scotland, we have to have a cultural offer. A job in a space-port will be available to very few people; whereas tech jobs could be available to thousands, if we create places were people want to live. e.g. Places with libraries, gardens, hot-desk hubs, cafes, cinemas, parks. This is why it's important to look more closely at the word wellbeing. We don't have to start with economic growth and end up with wellbeing. We could if we were radical start with wellbeing and end up with economic growth.
The last paragraph of this action leans towards this, as follows:
"Significant investment in our health and social care, justice and learning estates will continue to provide important sources of employment and income for smaller scale local businesses.
Town centres throughout this area will also play a critical role in driving a new economic future. The recent town centre review highlights opportunities to expand the range of services and facilities they offer, reuse redundant buildings and provide new homes for a wide range of people. This in turn will ensure their crucial role in defining our sense of place is protected and enhanced, future-proofing a key asset for Scotland as a whole."
I think this should be the first paragraph and not the last paragraph as this is where we need to get to. It's important to centre this thinking and to include a definition of wellbeing economy.
In relation to all of the above, please see the link below to a recent piece in the Scotsman by Councillor John Alexander (Scottish Cities Alliance)
https://www.scotsman.com/news/opinion/columnists/how-cultural-activity-can-fuel-scotlands-covid-recovery-john-alexander-3502365
Do you have any other comments on the Action areas for Scotland 2045 outlined in NPF4?
Dundee Waterfront :
Would it be possible to include the significance of the cultural offer in Dundee to the success of securing transformational projects?
From Page 16:
"Continued delivery of the waterfront transformation is crucial to securing the role of the city as a location for investment in the net zero economy."
For example please see a recent piece in the Scotsman from Councillor Alexander.
https://www.scotsman.com/news/opinion/columnists/how-cultural-activity-can-fuel-scotlands-covid-recovery-john-alexander-3502365
Please provide any other comments on the National Developments section of the NPF4?
Policy 4: Human rights and equality / Policy 6: Design, quality and place :
The consultation that we currently use to consult communities is not currently user-led.
When we create tools such as the Place Standard, although well-meaning, we are deciding what the parameters of the conversation with communities is, in advance.
Whoever controls the questions, controls the outcome. Community consultation technology is currently produced outwith Planning Legislation and therefor has the power to quietly control outcomes for communities.
It is important for planning that will impact on communities to be user-led and Culture Counts support the principles as laid out in Design Justice Network.
https://designjustice.org/principles-overview
In order to ensure that design of technology is user-led, Culture Counts would support the exploration of the idea of appointing V&A Dundee as a statutory consultee for the development of any future government led consultation tools. V&A Dundee would be consulted on the development of software for the purpose of community consultation to ensure that user-centred-design principles are followed.
Policy 9: Quality homes: Quality Homes: G
What is Antigypsyism/anti-Tsiganism/ Romaphobia?
Antigypsyism/anti-Tsiganism/Romaphobia essentially means the same thing and is a specific and long-established form of racism. Throughout history, the words "Gypsy", "Tsigane/Zigeuner", and similar terms, have been used. These words have taken a derogatory connotation in very many languages.
This section is not using enabling language, it's providing a list of ways to stop people living in a particular way.
Policy 18: Culture and creativity :
It's great to see that the impact of culture and creative industries has been recognised and included in NPF4.
The Scottish Governments commitment and realisation of the Agent of Change principle is noted and appreciated.
Policy 18b
I'm not sure that 'public art' is the phrase that the drafter intends?
Instead we could consider for example:
b) Development proposals should consider how to provide opportunities for community belonging and connection by consulting the arts and creative community where they involve a significant change to, or the creation of new public spaces.
It's not about including a piece of public art, to make the place look nice. It's about creating beautiful spaces where people can connect with other people and feel a sense of belonging. Working with the local arts and creative community to think things through will produce ideas which wouldn't have otherwise been realised.
Policy 28: Historic assets and places :F)
Should community consultation take place before a building is demolished?
It could be that the local authority do not deem the building to be valuable, whereas the local community disagree.
There is also often scope for arts, heritage and creative industries to use buildings and re-purpose them. For example The Wiskey Bond in Glasgow.
Do you have anything else to add in relation to the draft of the National Planning Framework (NPF4)?
This section has two parts.
Part 1
The six qualities of successful places
1 Designed for life-long health and wellbeing
This section only offers 'active' solutions to physical health and wellbeing.
Whereas people access health and wellbeing in various ways including by attending a local choir, or dance group.
Other solutions could be covered in the following way.
Proposed re-draft
By encouraging healthy lifestyles, through walkable neighbourhoods, as well as opportunities for connection and belonging, we can ensure equitable access for everyone (regardless of gender, age, ability and culture) to well-designed buildings and a nature-rich local environment, including quality blue/green spaces that are cared for and well maintained.
2 Safe and pleasant
Why is the word joy in quote marks?
It seems like what this paragraph is getting at is more along the lines of:
"designing, or retrofitting spaces of all sizes and purpose to enable connection and belonging, to encourage happiness and a sense of joy"
This section could be called 'Connection and Belonging' instead of 'Safe and pleasant'.
The word playful seems to infantilise the feeling of happiness, like I have to pretend to be a kid, in order to feel happy.
6 Adaptable
A re-draft (to include user centred design)
"By building in flexibility in line with circular economy principles, so that they can quickly be changed to accommodate different uses as well as maintained over time.
By recognising the need for consultation and user-centred-design to change and cope with social, economic and environmental pressures as well as accepting the critical role of ongoing maintenance to ensure resilience and community wellbeing over time."
Part 2
Throughout the document the NPF4 uses the word 'Recreation'.
Recreation is not really used in day to day language and means different things to different people.
We propose that 'Recreation' is replaced throughout with 'Culture and Leisure'.
ENDS