Homes for Scotland, ALACHO, SFHA, and CIH are among the signatories to a letter calling for a draft document on the Scotland-wide National Planning Framework (NPF4) to be withdrawn and re-visited.

They claim that the document has not been sufficiently scoped out, with the result that there are significant gaps. They further claim that the document lacks detail on how (albeit welcome) aspirations might be delivered, on the ground.

Steven Tolson, FRICS, who chairs the Housing and Place Delivery Forum (the cross-sector collaboration behind the letter), said: “As chair of the Forum, I was extremely pleased that contributions and observations came from a wide cross-section of public, private and community interests. All acknowledged that the NPF4 is an important policy regulation. We all recognised the importance of getting such a radical plan in good order, as delivery is what counts.

“The collaboration between different groups demonstrated that it is possible to get people together, have healthy, passionate debates, and find common ground. Too often in property development, confrontational gaming is apparent. Disputes hold up progress, are unproductive and prejudicial to economic performance. Nothing can be planned well while there are conflicting positions.

 “We need to get away from top-down hierarchical decision-making to a more devolved collaborative process that is well informed, early engaging and well understood. Planning policy is rightly being used to shape Scotland into a green, well-being economy, but delivering this is full of complexities. Policy alone will not work without the deliverers. The message from the Forum is that with a little more cooperation we could make this work”.

The draft document has been out for consultation since November 2021, with a deadline for responses of 31 March 2022.

The Scottish Parliament is expected to debate the contents of a final set of proposals during the summer. This would be Scotland’s fourth NPF and would cover the years to 2045. Were it to reach the statute book, there would be a legal obligation on all of Scotland’s 32 local authorities to mould their own planning guidelines around it.

However, some critics fear there might be too much wiggle room in the final document (the language being peppered with words such as ‘could’, as opposed to ‘must’), resulting in at least widespread confusion, if not, with the benefit of hindsight, ‘planning blunders’.

The letter, which can be read here, calls for a pause in the progress of the NPF to give the Scottish Government more time to address what the signatories claim are “clear shortcomings” in the current draft document.

In addition, they call on the Scottish Government to radically rethink the spatial framework for delivering NPF4.

The letter reads: “Currently, at the national level, the framework is discussed in terms of broad, ad hoc regions that do not align with any of the existing structures of government or governance in Scotland. One solution to this problem would be to re-organise and democratise regional economic partnerships, so that they can become agents for delivering strategic change; and, converging quango boundaries, so that health, housing and economic development can be planned together and more effectively”.

The letter calls on the Scottish Government to consider establishing “a dedicated and specialised national agency with real expertise in the social, environmental and economic aspects of spatial development of housing and infrastructure at different scales”.

This call echoes similar recommendations from the Land Reform Review Group and the RICS Scottish Housing Commission in 2014 (both of which were endorsed by Shelter Scotland’s Commission on Housing and Wellbeing in 2015).

There are also clear parallels with the Scottish Land Commission’s proposal to create a new public land agency, which would have the powers and resources required to bring forward a steady supply of development-ready sites at the right time and in the right places to meet Scotland’s housing needs.

The letter stops short of detailing how such an agency should work in practice, although it does make some suggestions on purpose and scope, and the authors are careful to note that any national agency should exist to support rather than displace local authorities.

Finally, the authors of the letter extend an invitation to the Scottish Government to continue to consult further to discuss the sector’s legitimate concerns, clarify the ambition, and develop a clear delivery plan.

The letter has been formally submitted in response to the Government’s consultation which closed last week, but it remains open to anyone who would like to add their name in support of the call to press the pause button.

Those who wish to do so should contact Dr Gareth James, directly, via gareth.james@glasgow.ac.uk.