Rural Affairs, Islands and Natural Environment Committee
Meeting date: Wednesday, February 9, 2022
Agenda: Decision on Taking Business in Private, Draft National Planning Framework 4, Subordinate Legislation, Good Food Nation (Scotland) Bill: Stage 1
- Decision on Taking Business in Private
- Draft National Planning Framework 4
- Subordinate Legislation
- Good Food Nation (Scotland) Bill: Stage 1
Draft National Planning Framework 4
Our second item of business is an evidence session on the draft national planning framework 4. I welcome to the meeting Mairi Gougeon, the Cabinet Secretary for Rural Affairs and Islands, and Tom Arthur, the Minister for Public Finance, Planning and Community Wealth. They are accompanied by Scottish Government officials: Jill Barber, the head of aquaculture development; Cara Davidson, the branch head of environment and natural resources; Andy Kinnaird, the head of planning transformation; Philip Raines, the head of the rural economy and communities division; and Fiona Simpson, the chief planner.
I invite the cabinet secretary to make a brief opening statement.
Thank you very much for inviting me here today to join what I am sure will be a very interesting discussion on the draft national planning framework 4.
Ensuring that the voices of rural and island communities are heard during the development stages of NPF4 continues to be a vital part of inclusive rural development. My officials have engaged with rural and island community stakeholders to ensure that their views are included as we work together to inform the draft NPF4 and rural proof future planning goals.
Our communities face endemic challenges and opportunities that we want the NPF4 to support. Addressing the population of rural areas is a statutory outcome that NPF4 must contribute to. The draft NPF4 sets out important proposals for the resettlement of previously inhabited areas. It will also enable new homes in rural areas, with planning policies that are more proactive and directive in shaping existing places and creating new places, while being supportive of homes and places that benefit from them, including remote, rural and island communities. We are committed to bringing forward an action plan on how that will be achieved.
The draft NPF4 is also clear that we want young people to have more influence in decisions that affect their future places. We also want to help more people to access land and crofts and be part of the solution to support carbon-neutral coastal and island communities.
Future planning policy offers significant opportunities for investment to support the blue and wellbeing economies and to capitalise on natural assets and strengthen the ties between people, land and sea. The draft NPF4 also recognises the contribution that our forestry sector can make to our net zero ambitions, reversing the decline in biodiversity and supporting a growing green economy.
The draft NPF4 includes a new policy addressing the nature crisis, which aims to ensure that appropriate measures to enhance biodiversity are designed into development proposals from the outset. Scotland’s land, and the natural capital that it supports, is one of our most valuable assets. It is vital to our national prosperity, and to our wellbeing as individuals and communities. Everyone has a stake in Scotland’s land and a responsibility to ensure that land is used productively and to the benefit of all, and rural and island areas can benefit from the changes enormously. That is why the vision, objectives and principles of our pilot regional land use partnerships for sustainable land use have featured and continue to feature in the development of Scotland’s national planning frameworks, including NPF4.
I welcome the ambitions of the draft NPF4 to support vibrant and sustainable rural places. The framework sets out how the planning system should encourage development that helps to support, sustain and grow rural areas while safeguarding and growing natural assets that underpin businesses and jobs.
I look forward to today’s discussion and the committee’s questions.
Thank you very much for your opening statement. We will now go to questions from members, and I will kick off. A few respondents were concerned about the process for consulting on and finalising NPF4. Indeed, National Trust Scotland said:
“We feel that this limits informed Parliamentary scrutiny of the draft framework by not affording the relevant Committees the opportunity to thoroughly examine a document”.
How has NPF4 been rural proofed? That is not clear. Will NPF4 rise to the challenge of responding to the unique challenges of rural Scotland?
I believe that the framework will. As I said in my opening statement, the voices of our rural and island communities have been absolutely vital throughout the process. That engagement has been key in developing the draft NPF4. I also highlight that the draft is out to consultation so, of course, any suggestions that we get through that will feed into the finalised framework.
The engagement that took place in the lead-up to publishing the draft NPF4 was extensive. We commissioned research from our policy teams and from external sources to look at the shape of planning policy and how that can help us to develop thriving rural communities. In addition, we had the call for ideas on NPF4—I am sure that the minister will want to give details on that. Furthermore, the Scottish Rural Network undertook activities through the Scottish Rural Parliament, and the chief planner met the heads of rural planning authorities.
All that has been vital and has helped to shape the draft that we have before us, which is out to consultation. I will hand over to the minister so that he can cover any further aspects of engagement.
The detail that the cabinet secretary has conveyed about engagement specific to rural issues reflects the broader approach that has been taken to developing the draft NPF4.
The draft framework is the culmination of quite a long journey, going all the way back to the independent review of the planning system that was commissioned at the tail end of 2015, which reported throughout, and the work that led up to the Planning (Scotland) Act 2019, which has clearly informed the design, structure and layout of NPF4 in its new, enhanced status.
We have of course had an engagement process. There was a call for ideas, followed by two rounds of extensive consultation and engagement. We published a position statement in November 2020 and we consulted on that. There has been extensive stakeholder engagement through that process.
I will provide some numbers. We have had nearly 350 written responses, 180 people participated in our roadshow workshops and we spoke to around 100 people at our drop-in sessions across the country. There was strong support throughout for a bold and radical NPF4.
I think that the process has gone beyond engagement to almost genuine co-production. I think that that is reflected in the response that we have seen to NPF4 so far. Notwithstanding particular points around some of the detail, I think that there is a growing and strengthening consensus about the direction of travel on NPF4. I believe that that emanates directly from how the draft NPF4 was brought into existence, which was through extensive consultation and engagement.
The draft NPF4 was introduced on 10 November 2021 and Parliament has 120 days to consider it. There was the Christmas break, and we also have the Good Food Nation (Scotland) Bill to consider. Is it reasonable that the committee has such a little time to look at a hugely important document that could have a massive impact in rural areas? That 120-day period is not very much, particularly given the Christmas recess. Is it reasonable to expect the Parliament to scrutinise the framework in that time?
My understanding is that that is double the period of scrutiny that there has been for previous national planning frameworks. As I said, and as the minister has outlined, there has been an extensive engagement process leading up to this point and our consultation is open. I would like to think that that would be adequate time for that scrutiny to take place and for any further ideas or comments to be provided.
Convener, I can give you some more details about the on-going parliamentary consultation. The cabinet secretary rightly highlighted that 120 days is double the time that was previously in place. That timeframe is set out in statute, in the Planning (Scotland) Act 2019, which was agreed by the Parliament.
Of course, a public consultation is running in parallel until 31 March, and we are supporting communities to engage with that. I can provide some details. There is a community grant scheme, which makes available grants of up to £250 to community groups to help them to engage. There are open invitation events over February and into March to give stakeholders the opportunity to discuss NPF4 and encourage participation in the formal consultation.
There are nine events in total, with one on each of the four policy themes and one for each of the five action areas. There is an equalities round-table discussion in March. The Royal Town Planning Institute is hosting round-table discussions on business energy development and house building during February and March. The Scottish Youth Parliament is holding a workshop at its next gathering in March. We are working with Police Scotland to support children and young people’s perspectives. Furthermore, there are discussions with community groups and online resources.
A huge amount of activity is taking place in parallel with the parliamentary scrutiny, to ensure that everyone who wants to contribute has an opportunity to do so. I reiterate that I very much want to encourage as much engagement as possible in the NPF4 process.
I will ask a more specific question. One of the key policies is a commitment to 20-minute neighbourhoods, but there does not seem to be much for rural and island communities in that context. Are there any plans to look at the critical mass of core services and facilities that a community needs to have, given the unique nature of every island and rural community? Will there be any consideration of the same sort of idea as producing a sustainable community within 20 minutes, but on a rural and island basis?
That is a really important question. The draft NPF4 is a high-level document and subsidiarity applies, so there will be local development plans that can give effect to that in particular localities. There are also the local place plans that we have introduced, which allow individual neighbourhoods and communities within planning authorities’ areas to shape their local development plans.
With regard to what is stated about 20-minute neighbourhoods, I note that flexibility is built in, which is reflected in how the policy is defined, but also in the spatial strategy. The action areas, which include north and west coastal innovation and northern revitalisation, recognise that the concept of 20-minute neighbourhoods has a different application in areas with dispersed populations compared with places with dense populations.
For example, we will look to encourage 20-minute neighbourhoods in built-up urban areas by seeking to repopulate our town centres, and some measures are included on that. However, in local areas, that will require more nuance. That could involve establishing hubs and promoting active travel networks, but also recognising the need for cars. That can be supported through, for example, electric vehicle charging infrastructure. There is recognition that 20-minute neighbourhoods will have to be applied in a different manner in, say, South Uist, compared with how they will be applied in Shawlands in Glasgow.
Fiona Simpson might want to expand on the points that I have made and provide some more clarity.08:45
The concept of 20-minute neighbourhoods is being debated extensively in the engagement that is happening at the moment. The work that was done by ClimateXChange looked at 20-minute neighbourhoods in different settings in Scotland and found that they could be a valid concept in both rural and urban settings. The Savills research on rural planning found that lots could be done by connecting up housing with services and thinking in the round about how rural communities work. That debate will continue during the consultation period and we will look at ideas around that.
I have a supplementary question on 20-minute neighbourhoods. Is the plan agnostic on the way that the housing market operates in some rural areas where, essentially, people have to have acquired capital from property transactions in a city before they can buy or build a house? That has implications for the age profile and the sustainability of many of our rural communities. What can the plan do to address that fundamental problem that many rural communities now face?
Fiona Simpson might want to give a bit of context on how NPF4 relates to some of the other work that is going on in Government around housing, for example.
Our approach to housing in the national planning framework aims to set out a broad framework. The policy framework has been designed to allow for flexibility in rural areas. There are several exceptions in policy 9 that relate to rural housing, recognising that there is more housing need. Demand-based assessment is a starting point for the process, but local development plans for different authorities in different parts of Scotland will take that forward in different ways.
In policy 31, on rural development, a framework is provided that aims to enable more rural housing development. For example, it recognises that small sites outwith settlements may be suitable for development depending on the spatial strategy that is set out in the local development plan.
We have aimed to achieve a broad approach overall. We set out figures in Annex B to NPF4 that are a starting point for local development plans, but that policy approach needs to be taken forward through local development plans as well. The local development planning guidance provides much more detail on how that can be achieved.
Dr Allan’s question is important and it speaks to why there is flexibility in NPF4. I am conscious that some of the feedback in other committee sessions has perhaps been that certain stakeholders are looking for a more prescriptive approach, but a balance is required. We need to avoid being overly prescriptive while having flexibility so that planning authorities can take local circumstances fully into account in designing their local development plans.
The committee held an engagement event with 100 rural stakeholders on Monday. Some of the comments that were made were very interesting and I urge you to look at them. On 20-minute neighbourhoods, as well as raising the housing issue, people said that lack of transport between rural communities has made areas inaccessible, that local amenities have moved away, and that the draft NPF4 does not translate to rural settings and there is no appreciation of rural areas in it. Will you expand on how the concept of 20-minute neighbourhoods can translate to rural areas?
If the cabinet secretary is happy, I will kick off on that. I anticipate that the southern sustainability action plan in the spatial strategy will be of particular interest to you, Ms Hamilton. It speaks about a network of towns, recognising the unique character of the south of Scotland, and there is recognition that transport is a key issue.
I suppose that there are two aspects. The first is that we want to reduce the need for travel. That is about building up wealth within communities, and job opportunities. You will note that one of the universal policies—from memory, it is policy 5, on sustainable places—is about community wealth building. I know that South of Scotland Enterprise is very interested in that. By promoting greater community wealth building through the planning system and using other levers as well, we can help to reduce the need for unsustainable travel.
However, we also recognise that, in many cases, travel is unavoidable. That is reflected in the spatial strategy for the south of Scotland. Equally and analogously, the action plan for the north of Scotland, which is known as northern revitalisation, recognises the key role that our roads play and also the necessity for car use, which I mentioned to the convener. Part of how we respond to that will be about increasing EV infrastructure to support low-carbon travel, but we also have to see this in the broader context of our wanting to reduce car kilometres by 20 per cent and reduce unsustainable travel. Paragraph 5 of the spatial strategy reflects the fact that, for sustainability, addressing the issues around public transport and indeed cross-border transport will be significant.
I do not know whether Fiona Simpson wants to expand on any of those points.
Through the spatial strategy, we are trying to explore new ways of living in rural and urban areas. There are lots of ideas about community hubs and different ways of arranging settlements in the future to accommodate different patterns of working and living together. The national planning framework tries to provide a framework that will allow that innovation to grow from a regional scale as well as through the local development plans.
My question follows on from Alasdair Allan’s and Rachael Hamilton’s questions. This is a complicated area, particularly in rural settings, because it is cross-cutting and it involves different land uses and different demands on the same land. How is the Government looking to marry all those things up?
On land availability and land prices, the price of hill land is going through the roof because we are planting more trees on it and we are doing peatland restoration, which is driving the price up. On connectivity and 20-minute neighbourhoods, what are we doing about more public transport? Does the plan include anything to look at that? Is there anything in the plan that will ensure that we get broadband rolled out? It is about creating infrastructure that will work for the communities in rural settings. How are you bringing all that together? Sorry—I know that that is a complicated question.
I am happy to kick off on that. There was a lot in the question, but I will try to answer it as best I can.
On your last point, and returning to what I said at the start, I note that this is all about trying to create thriving local communities and thriving communities in rural areas. Enabling the development of the infrastructure that we need for that to happen is the premise of NPF4. There are lots of different strategies and pieces of work going on across the Government to try to address the issues that you mentioned, including on land, transport and our digital connectivity, but I highlight that none of those pieces of work is being done in isolation. For example, our third land use strategy, which was published last year, makes explicit reference to NPF4, and it has featured in previous national planning frameworks.
You talked about digital connectivity. We have opportunities with home working, which could help to enable people to live in remote and rural parts of Scotland. Of course, we need the digital infrastructure to enable that to happen. The digital fibre network is listed as one of the national developments in the framework because we recognise its importance and we want to enable that development to take place.
The key point that I want to emphasise is that we are not looking at each of the issues in isolation. We are making sure that, as we develop strategies, there is read across to NPF4 and, likewise, that it aligns with the other strategies that we are developing in these areas. I am sure that the minister will want to add to that.
If you are talking about home working in rural areas, land has to be available so that we can build houses to allow young people to stay there.
Exactly. What is proposed in the draft NPF4 allows for that flexibility. I do not think that it can be too prescriptive but, if you look at the types of development that are enabled there, you will see that it talks about allowing development for succession planning, for example. It addresses some of the issues that have been in place before. It is about trying to strike the right balance. I am sure the minister has more to add on some of those points.
The cabinet secretary has covered a lot of the ground. Increasing the population of rural areas in Scotland is one of the statutory outcomes that is required of NPF4, as stipulated in the 2019 act. I highlight that policy 31, on rural places, is expansive. It takes a holistic look at a lot of the different areas and shows how they work together. I am conscious that it can be easy to say “rural communities”, but every rural community is unique.
I return to the point that we must not be overly prescriptive and that there is flexibility. However, there are clear expectations around what we require. For example, policy 31 states:
“Local development plans should set out proposals to support the sustainability and prosperity of rural communities and economies ... Development proposals that contribute to the viability, sustainability and diversity of the local economy should be supported”.
That is reflected in the policy aspects. It is important to remember that NPF4 is unique and that it brings the spatial strategy and what was Scottish planning policy together in the one document. This is part of the statutory development plan.
Our expectations are clear, but I recognise that, to realise those aspirations, there will be some variance between different rural communities. I am sure that Mr Fairlie would have something to say if I was to suggest all rural communities are the same and require the same response.
Indeed. Thank you.
Thank you for coming along. I attended the engagement event on Monday that Rachael Hamilton referenced, and I am interested in how the framework will support the growth of island communities. We took some evidence from Orkney, and the point was made that it used to be the case that a house and work were needed to encourage people to live there. Given what we have seen with the pandemic and the ability for people to work from home, it is now just the house that is needed. I am interested to know how learning from the pandemic is reflected in NPF4.
A specific question was asked about policy 31 and the infrastructure first approach. There was a suggestion that, in rural and island communities, there should be a buildings first approach, because there are a lot of derelict buildings that could be re-engineered to be homes. I would also like to hear your thoughts on that.
I want to see the outcome of your engagement event on Monday, because hearing those views and all the issues that came out of that will be really important in helping us to develop the final draft.
In relation to infrastructure, you talked about the use of vacant and derelict properties and land. That is a key factor in the draft NPF4 as well. There is a key focus on the fact that, rather than continuing to build new infrastructure or to build outwards, it is important to utilise the infrastructure that is already there. I am sure the minister will want to elaborate on that.
As you will be aware, the spatial strategy is underpinned by six principles, one of which is the conserving and recycling of assets. That is reflected through policy 30, which is on vacant and derelict land. This speaks to our clear aspirations around climate change and a circular economy. We do not want to release the embedded carbon that is already there. We want to make use of existing assets.
That has huge applicability in a range of contexts. We will all be able to think of examples in densely populated urban environments where there are underutilised assets that can perhaps be brought back to life. A range of work goes on to support that through our place-based investment programme and asset transfers via the Community Empowerment (Scotland) Act 2015, so that is already under way. NPF4 helps to strengthen that position and it is very clear and explicit. The policies around looking for brownfield land first are also relevant here.
Two other aspects of the spatial principles that complement that approach are compact growth and local living. Taking those things together holistically, we are aiming to encourage more growth and reuse of existing assets. That is applicable to rural environments, but I think that we all recognise that it has applicability to densely populated urban environments as well.
I do not know whether Fiona Simpson wants to comment.09:00
The only thing that I would add is that there is an emphasis on working with our assets to achieve resilience in island areas. The spatial strategy tries to bring that out clearly.
On Jenny Minto’s point about home working, I refer to the points that I made about the digital fibre network being a national development, and the work that has been done on transport. NPF4 is about enabling those developments to take place, all of which add to what the minister has set out.
I heard the minister talking about the understanding that all communities are different. However, NPF4 refers numerous times to remote, rural and island communities without acknowledging that there are significant differences between many of those communities. That concern has been raised in a number of the evidence sessions that I have been part of. Many of those communities are facing radically different circumstances. An example is the action area that covers the Western Isles, Orkney and Shetland. The point has been made to me that there are nuances in those areas and that they do not necessarily sit well together in that action area. How will the Scottish Government ensure that the diversity of the different parts of our rural, remote and island communities will be recognised through NPF4 and other policies that it proposes?
I am happy to take that. Thank you, Ms Burgess. I look forward to discussing the issues with the Local Government, Housing and Planning Committee, which you convene, in due course.
Your point is important. The first thing that I would say is that this is a draft NPF. We are in a consultation process and we are incredibly grateful for the interest being taken by the committees and the Parliament more widely, and indeed, by all the individuals and groups who want to participate and share their views. That is part of the process.
On how we got to this position, I do not want to go over the ground that we covered earlier, but I am clear that the process has been collaborative and we have had a lot of consultation on specific policy areas while working in partnership with communities on the input that led to the spatial strategy and the specific action areas that have been developed. We will take into account any feedback that we receive via the consultation and the Parliament, and that will be fed into and reflected in the NPF4 that we bring back to the Parliament for final approval.
Again, I do not want to repeat myself, but I want to make a key point about the balance between giving a clear steer and flexibility. That is also important. Planning authorities will still have that vital role in relation to local development plans but, crucially, also local place plans, regulations on which have now come into force. That will give local communities more of a say in shaping their LDPs.
It is important to bear it in mind that there is still the means to achieve the specificity that is required in localised situations. That is not just for LDPs; it has also been enhanced through local place plans. We are seeking to articulate here the broad vision at a very high level, so even within a spatial strategy for a particular area, it will not necessarily be universally applicable to every single community within that area. We also want to see partnership working at a regional level beyond the work with LDPs and local communities.
Fiona Simpson might want to add to that.
I will give a bit of background on the regional scale working that we did to inform the action areas that are set out in the national planning framework. We worked for more than a year with authorities that were working, either on their own or with other authorities, to prepare indicative regional spatial strategies. That work was brought together and, over a week, we held a set of good collaborative workshops at which we set out where those areas that are set out in the national planning framework reflected shared common themes, challenges and opportunities.
We have tried to provide the national planning framework without trying to cover all the detail or the more specific nuances within each of the individual regional spatial strategies. That will be for authorities to implement as they prepare strategies for their areas.
I am conscious that we are rapidly running out of time. Rachael Hamilton has a brief supplementary question.
Should the islands be recognised separately in NPF4, and why is the Isle of Bute included in the central belt regeneration area?
That has ultimately come about through a collaborative process, as outlined earlier. As I said, we are open to suggestions about how things can be refined or changed. That is part of the consultation process and engagement. This is a draft document, and we are ultimately in a process of engagement and collaboration that has led us to the draft spatial strategy within NPF4. We are keen to hear views on how it can be refined and, if there are areas that you are suggesting are inconsistent or will not realise the aspirations, that can be reflected on and potentially acted upon through the process of finalising the framework.
Fiona Simpson might want to add something specific about particular action areas within the spatial plan and how they were formed.
The maps are indicative and very much open for comment. Some areas could have gone in more than one action area and the boundaries are intended to be quite fuzzy. We were trying to extend the central belt out to include the Clyde coast, given the importance of coastal areas close to the central belt.
I stress that at the heart of this is a place-based approach, and a place-based approach is holistic when it takes everything into account. We are not dividing Scotland up neatly. Clearly, some of the action areas that might be applicable to remote communities might also be applicable to urban communities, while there will obviously be completely distinct areas that do not have the same relevance to others. Although we have identified five action areas in the NPF, again, it is important to look at it holistically and see the complementarity that exists between the different regions and areas.
I want to expand a bit more on that. As Rachael Hamilton pointed out, Bute is with the central belt action area, as is Dunoon. To be parochial about it, my constituency is divided among different action areas. There are islands that I would have expected to have been with other island communities in, for example, the islands hub for net zero project. I am pleased to hear that the map could be redrawn. I asked you about that, Ms Simpson, when you first came to the committee, so it is good to hear that there is a bit of flexibility in the action areas.
You talked about the islands hub for net zero project. The projects came from the Western Isles, Orkney and Shetland. Again, I emphasise the point that the minister made earlier about the framework being flexible and open. If more information comes through the consultation, we would look at that. The draft NPF4 is what has come out of the engagement that has taken place so far in relation to where some of these developments would be emanating from.
I want to pick up on that good example relating to Jenni Minto’s constituency. It picks up on the point that I was trying to articulate—probably not as clearly as I would have liked—to Ms Hamilton. The point is encapsulated in the Clyde mission national development because it stretches from south Lanarkshire all the way along the Clyde until Dunoon, and it takes in a whole range of communities. That one national development articulates the point that, as much as we have these semi-defined spatial areas, the borders will overlap. I am suggesting not that you have to draw a hard and fast line, but that there will be overlap. I recognise that in a constituency such as Jenni Minto’s, a whole range of different aspects of the spatial strategy will be applicable and will vary quite drastically from community to community.
I will change the subject slightly and ask about fuel poverty. I agree with the points that have been made about not considering rural, remote and island areas as one homogenous entity, but I will now do just that. Fuel poverty and extreme fuel poverty are disproportionately impacting rural, remote and island communities. Should NPF4 give more prominence to fuel poverty in those areas to show the Government’s commitment to taking the issue seriously? Should it be a national development?
I completely understand the concerns that you have raised about fuel poverty, and when I have visited island communities, I have heard about the levels of fuel poverty, and how rural and island communities are severely impacted by it. Helping to address fuel poverty and enabling energy efficiency are the principles that are embedded within NPF4. Perhaps it would be helpful if the minister outlined the proposals for national developments and how they have come about.
Ms Wishart, you raise a really important point. Planning is ultimately concerned with development and it has to be able to identify the particular class of development that one is seeking. On specific issues around fuel poverty in relation to planning, we have already done work on permitted development rights around retrofitting and energy efficiency. We have a phased programme of reviewing PD rights and we can continue to take that into consideration.
More broadly, NPF4 is seeking to increase prosperity in Scotland but also to look at some of the specific national developments in, for example, strategic renewable energy generation and transmission infrastructure, pumped hydro storage, and industrial green transition zones.
Those national developments are particularly about promoting not just prosperity, but energy security. NPF4 can specifically contribute towards issues around fuel poverty by supporting more prosperous economies, increasing the number of people in employment and using national developments to provide that strategic underpinning for continuity and security of energy supply.
One of the participants in our engagement event on Monday suggested that rural areas are carrying the burden of delivering a just transition for those in urban areas, because rural areas carry the burden of peatland restoration, hugely ambitious tree planting and, of course, wind farms, for which we see more and more applications coming to the Scottish Government overturning community objections or local authorities not having the capacity to deal with wind farm applications, which are then sent to the Scottish Government through non-determination. The new NPF4 almost assumes in favour of renewables in rural areas. How does that deal with a community’s right to decide what is on its doorstep and listening to the community’s voice? That is a real issue. What is particularly lacking is that in some of the very remote areas that have large wind farms—for example, in Dumfries and Galloway and the Scottish Borders—there is no prospect of the green industrial zones that you talk about.
I emphasise that NPF4 is not about imposing developments on people and it is not bypassing any processes. Any developments that are proposed for rural areas will still have to work their way through the planning process, which, you would hope, would involve relevant consultation and provide the opportunity for communities to make their voices heard throughout. Again, we are not talking about bypassing any processes that we have in place at the moment.
Of course, there are the local development plans, which the minister has talked about, and local voices will be key in the decisions that are made about those plans.09:15
Correct me if I am wrong, convener, but I think that you expressed a view about sharing the burden of a just transition. That is reflected within NPF4. I recognise the point you make about renewable electricity generation. There is also offshore wind, including the recent very welcome announcements in Scotland. If we look, for example, at the key role of the north-east in a just transition, it is a centre of expertise and it is reflected in the industrial green transition zone, which runs down the north-east all the way to Grangemouth. That is another key example of how more organised urban areas will have a major part to play in our move towards net zero.
There is also—and this is perhaps beyond the scope of our discussions today—the huge contribution that will have to be made by urban areas, particularly in the central belt, towards heat in buildings, which will be a significant ask of the population in moving towards a just transition. We all have slightly different and nuanced roles to play in our move towards a just transition, I think that it is clear that there is no part of Scotland that will not have to share in the responsibility of realising our ambitions for 2030 and 2045.
I echo the points that the cabinet secretary made. The national development planning policy is not a top-down policy stipulating specific developments that will or will not happen. Ultimately, it is for local planning authorities to make determinations in the first instance and, when appropriate, to use relevant assessment criteria that is required in considering any application.
Is there anything that Fiona Simpson wants to add?
The conversation that we had during the collaborative process for preparing NPF4 looked at each part of Scotland and what it could contribute to achieving net zero. As the minister has said, there is as much in the central urban transformation zone as in the rural areas. We are looking for synergies and opportunities to support the sustainable development of those areas as a result of the requirements around net zero.
Let me give a quick example. We talked about 20-minute neighbourhoods and a 20 per cent reduction in car kilometres. Clearly, more will be expected of the central belt and it will be expected to be delivered at pace. Whereas, if we look at, for example, northern innovation and the action plan within the spatial strategy, there is a recognition of the increased need for private car use in those areas, so I think that the sharing of that burden is reflected throughout NPF4.
May I come in on that point? There will undoubtedly be challenges, but NPF4 also offers a lot of opportunities for rural areas. I am keen to see the feedback from the engagement event that the committee had on Monday because it sounds as though a many valuable points and concerns came out of it. We are keen to address those as best we can.
There are really exciting opportunities that will enable communities to thrive in our most remote rural areas, especially through some of our blue economy developments. There are also renewables opportunities that offer the chance of exciting new industries that will create jobs, as well as what is being enabled through draft NPF4 and sustaining and ensuring that we have thriving rural communities in the future.
I am keen to hear about the challenges that have been expressed, but we cannot lose sight of the fact that there is also a lot of opportunity here.
A number of European countries have capped their energy cost increase at 5 or 10 per cent, but the United Kingdom has capped it at 54 per cent. Yesterday, I heard a suggestion that it could be significantly higher than 54 per cent in island areas, which already probably have some of the worst fuel poverty rates in Europe. How can the planning system respond to that? I presume that such a savage increase would have an impact on whether people decide to live in island areas and the kind of balance with which that leaves the community. What levers exist in the planning system—whether it be obligations on developers or other measures—to cope with what will undoubtedly be an extreme situation with fuel poverty on the islands?
Dr Allan raises an important matter. We have to look at what planning is about. It is about the regulation and consenting process for development. It is certainly challenging for the planning system to respond at pace. In the medium and longer terms, as the cabinet secretary and I touched on in our responses to Ms Wishart, we can look at how we promote the types of development that, on the one hand, reduce fuel poverty and energy consumption and, on the other, promote jobs, prosperity and security of employment, which can help to alleviate some of the drivers of fuel poverty.
I do not want to repeat myself, but we have done work on permitted development rights to make it easier for people to ensure that their homes are as energy efficient as possible. It is clearly more challenging for the planning system to pull levers at short notice.
Would Fiona Simpson like to expand on my response?
The national planning framework sets out policies on, for example, sustainable materials and design standards. As the minister said, we have looked at permitted development rights, and we can give them further consideration.
The link with building standards is also very important. There are limitations to what the planning system can do on its own, but it can provide a vision that wider strategies, policies and programmes can build on and contribute to.
The framework confirms that the islands will be at the forefront of efforts to reach net zero, but RSPB Scotland has voiced concerns about opening up island areas for large-scale development as part of the islands net zero hub. I challenge those concerns by saying that the Sullom Voe terminal has been in operation for nearly 50 years, and the Shetland Oil Terminal Environmental Advisory Group was set up to look after the interests of the environment around the terminal and the port, so it seems that environmentally responsible industrial activity has been possible.
My question is about the contradiction relating to having the islands at the centre of the work towards net zero. Those ambitious plans will obviously feed into the rest of Scotland. What is the Government’s view on that, in relation to the framework?
Transport is a big factor in relation to Shetland’s carbon emissions from interisland ferries, for example. How does this all link together with transport?
I can come in on the first point. Is it just about how we manage what can be seen as the impacts of—
The framework puts the islands at the forefront, but, on the other hand, there are concerns about having the islands at the forefront of the hydrogen energy hub.
Okay. I reiterate that we are not trying to bypass any planning processes that are in place, which is a point that I made earlier. The islands can be at the forefront of cutting-edge technology for renewables, but we have to adhere to the legislation and regulations when we consider any developments, and none of the processes will be bypassed.
Concerns about protected areas have been mentioned. We have commissioned independent research to look at the impact of the draft NPF4 on current designated areas and proposed designated sites.
Ms Wishart has asked an excellent question that gets to the heart of planning, which is about how we balance competing areas: industrialisation, jobs, prosperity, and protecting and conserving the natural environment that we value. Planners wrestle with such questions every day.
I could attempt to answer the question, but I am conscious that we are joined by the chief planner for the Scottish Government. It would be helpful to get a planner’s perspective on how planners balance those issues and how that is reflected in the national planning framework.
I agree that the central role of the planning system is to understand all the competing aims and objectives, and to think about how they apply to different places and the objectives that it makes sense to deliver for a certain place. As has been mentioned, there has been an iterative process of integrated impact assessment, which has helped us to understand the impact that the choices that we make will have on, for example, the environment or island communities.
All the work that we have done aims to achieve that balance in the context of net zero and the broader objectives that we are trying to achieve. Consideration of statutory outcomes, in relation to increasing the population of rural Scotland, has been part of that work. The planning system is set up to look in the round at all the competing priorities and to think about the assets of a place and how to work with those.
Alignment with the second strategic transport projects review has also been important. The planning system can set out land use implications and has been developed in alignment with STPR2.
The strategy also recognises the aspirations for a net zero aviation zone by 2040.
My final point relates to the centrality and importance of the local planning authority and of local communities having the opportunity to feed into the development of local place plans, because, ultimately, it will be for local communities to shape the direction of travel for their area.
My question was also about the contribution to the just transition and net zero.
I will make a point about hydrogen. We are undertaking a review of all the regulations and legislation on the safe production, storage and transportation of hydrogen to ensure that we have the correct framework in place. That work is on-going.
Is the continued existence of Gaelic-speaking communities among the aims of the framework?
I am sorry, but I missed the tail end of that question.
Is having Gaelic-speaking communities in the future one of the aims and objectives that you have set yourself in the framework?
I appreciate the question, Dr Allan. That aim is not explicitly set out in the national planning framework, but one of the indirect consequences of supporting and increasing rural populations would be the direct benefit to Gaelic-speaking communities. However, I am conscious that Bòrd na Gàidhlig has highlighted some useful ideas, which we will consider and reflect on ahead of bringing a finalised NPF4 back to Parliament later this year.
The fact that Bòrd na Gàidhlig has engaged in the process, as the minister rightly mentioned, indicates that the future of Gaelic is indirectly bound up with issues such as who gets to live in those communities and whether there are housing opportunities and other opportunities there. Do the points that Bòrd na Gàidhlig and I have made about Gaelic point to the need for interconnectedness between NPF4 and other plans?
That is a fair point. I very much value that suggestion and the ideas that have been put forward. I assure Dr Allan that we will give them full consideration as we work towards producing a finalised NPF4.
I have a question about strategic land use, which my colleagues will also ask about in a while. It is probably directed to the Cabinet Secretary for Rural Affairs and Islands. Respondents have noted a lack of clarity on how NPF4 will relate to developing agriculture policy. Will the agriculture reform implementation oversight board be informed by NPF4 in its development of agriculture policy? Will the committee receive an interim report on progress to ensure transparency and coherence regarding the relationship between NPF4 and agriculture policy?
I am sorry, but are you asking about an interim report on ARIOB?09:30
There were two parts to the question. The first part is about how ARIOB is looking at the relationship between land use and the aim of NPF4. Then there is the question of how the committee can track that. Will we receive an interim report so that we can guarantee that there is transparency over the direction of travel for ARIOB?
In relation to the work of ARIOB, its terms of reference have been set out and we have been developing an immediate programme of work. That has been the board’s focus. I am happy to write to the committee to outline some of the work that has been taking place. It has focused on developing the immediate test programme that was announced just prior to COP26, and the immediate work in trying to roll out carbon audits and nutrient management plans, as well as a more detailed pilot to test what conditionality will look like for future payment schemes.
That has been the immediate focus of the work of ARIOB. It is also helping us to shape our future policy—we very much want to co-develop that, and the work of ARIOB will be critical as we look to the future. Of course, a number of pieces of legislation will be coming up in the coming years. We will have the agriculture bill, legislation on land reform as well as a natural environment bill. There will be a lot of crossover between those areas, not all of which I immediately lead on, so obviously we want to make sure that there is alignment. Wider questions may well come into some of ARIOB’s work, but we have not yet reached that stage in our future planning, because we have had the immediate focus on developing the national test programme and making sure that it is ready to launch.
Does it concern you that there is no mention of land use strategy in NPF4?
NPF4 is not being developed in isolation from the land use strategy and other pieces of on-going work. In my response to Jim Fairlie, I referred to the regional land use strategy, the outcomes of which make explicit reference to the national planning framework. The issue has been referred to in previous NPFs. As I said, the two are not being developed in isolation from each other. We obviously want to ensure that there is alignment of outcomes.
There is a lot of cut-across. There are explicit links between NPF4 and the third land use strategy, which was published last year. NPF4 refers to green and blue infrastructure, talks about optimising vacant and derelict land and has a focus on nature-based solutions. The two are not being done in isolation—there is a lot of cut-across and alignment.
I want to move on to the role of planning decisions when it comes to the long-term public interest. We know that forestry management is delegated to Forestry and Land Scotland and that the approach is dictated by the economics of a global market. Long-term plantations of single species do not create local employment, so how can the Scottish Government’s climate change policies, including on the plantation of forestry, sit well with NPF4 when it talks about ensuring that we increase the number of local people in employment and the development of houses and so on?
I again emphasise that we are not doing this in isolation. A number of other pieces of work are under way. For example, the pilot regional land use partnerships have been established. They are still in the development stage, but they map the areas that have been set out in the regional spatial strategies. It is about making sure that both of those align.
The purpose of regional land use partnerships is to ensure that we are having discussions and collaborating at a regional scale on future land use. That is a collaborative process. At the heart of the process is making sure that we have discussions with communities, landowners and farmers as we try to address some of the issues at scale. Phil Raines might have more details.
You mentioned the regional land use partnerships. My colleagues will speak more about those, but there are only two mentions of them in this enormous draft NPF4, which is disappointing.
The document is out to consultation at the moment and we are keen to hear the feedback. However, as I said, we are not doing this in isolation, and we will not develop the policies or strategies independently of one another. I emphasise that, as I said, the regional land use partnerships align with what we have set out in the regional spatial strategies.
Ms Hamilton’s point talks to the wider point about how the different activities will benefit rural communities, which was picked up earlier in the session. As the cabinet secretary said, a number of initiatives are going on to think about how we ensure that the benefits come through. You mentioned the just transition. You will have noticed the Scottish Government’s response to the just transition commission’s recommendation. The intention is to bring forward just transition plans, which will absolutely have that issue front and centre, not least with respect to land use policy.
Also, we have a land-based review of learning under way to think about what skills will be required and the processes by which those skills could be put in place across rural areas in the next couple of decades to address the issues.
That is helpful.
I have a question about national planning policy 3, which puts a duty on developers to facilitate biodiversity enhancement but does not explain how they should demonstrate that. Will a framework or mechanism be established for developers to demonstrate that they are meeting that obligation, or will guidance be provided?
We already have a suite of guidance and processes in place in the planning system. Of course, we will reflect on and refresh that as required. On the specific technical point, I ask Fiona Simpson to come in.
Cara Davidson might want to come in on this. A lot of work has been done to prepare the policy, and there has been a lot of collaboration, including with NatureScot.
That is what I was going to add, because I believe that NatureScot has been developing guidance on that specific policy. Cara may have more detail.
The journey to develop policy 3, which is on the nature crisis, has involved extensive collaboration. We kicked off by commissioning NatureScot to produce research on the opportunities and policy mechanisms that could be deployed through NPF4 to secure positive effects for biodiversity from development. The research has directly informed the development of draft policy 3, as has our engagement through a stakeholder working group that has been set up and that met four times in 2021, as well as earlier this year.
Policy 3 takes an approach to mainstreaming biodiversity. We want the designing in of biodiversity enhancement measures to be considered from the outset, but we also recognise that the planning system deals with a breadth of development types and different scales of development. Our most stringent measures are targeted at developments of a larger scale or those that will have significant impacts on the environment.
NatureScot has put out to consultation draft guidance in support of policy 3(e), which applies specifically to local development. That guidance is available for comment now. On policy 3(d), as the minister said, we will give close consideration to what guidance might be required to support the implementation in practice of NPF4 once it is finalised and adopted.
Jenni Minto has a supplementary question.
I want to follow on from that question. I have had correspondence from constituents about the consideration of biodiversity benefits in decision making. People have asked why there is an exemption for fish and shellfish farming.
Fin-fish and shellfish farming are not completely exempt from the policy. Policy 3 has five points, and fin-fish and shellfish farming are exempt from the last two, not the first three. It is critical to outline that.
Fin-fish and shellfish farming are a bit of a funny one, because they are the only part of marine development that is covered by the Town and Country Planning (Scotland) Act 1997 and by terrestrial planning processes. In relation to marine biodiversity, it is important that we look at marine ecosystems as a whole and that that is considered through the national marine plan as well as the forthcoming biodiversity strategy. I assure you and other members that such farming is by no means exempt. Work on the issue will be on-going through other pieces of work that we are carrying out.
In planning on aquaculture, how will the views of all stakeholders in communities on the development of aquaculture be considered?
Throughout the process and in the lead-up to decisions, it is critical that the community’s voice is heard. There are a number of means by which community voices can be heard throughout the process, whether that is through the consenting processes or licence applications for aquaculture. As the minister stated, NPF4 gives importance to community wealth building. Do you want to elaborate on that point, Tom?
Yes. I would add that policy 5 is a universal policy and that all development has to be considered through that community wealth-building lens. That agenda will grow and intensify throughout this parliamentary session as we work towards introducing legislation on community wealth building.
Some of the universal policies will have varying degrees of relevance and applicability. Aquaculture is one area where there will be significant interest. Although we are specifically discussing the role of the planning system in NPF4, these conversations could be expanded into the community wealth-building space, and I look forward to having them in due course.
I will add a brief point. We will also deliver our vision for sustainable aquaculture this year, which will put an enhanced focus on the issue. I just wanted to give the member that assurance.
I will bring in Beatrice Wishart.
Hold on a second, Ms Wishart, your microphone is not live. We will move on to Mercedes Villalba while we sort out the mic.
What is the Scottish Government’s view of how the precautionary principle could be applied in relation to planning applications for aquaculture and other coastal and marine installations, where knowledge and information are incomplete?
We have had a consultation on that issue, which I think has just closed recently. The consultation was on the statutory guidance for ministers and other public authorities, who must have due regard to the five guiding principles on the environment in the UK Withdrawal from the European Union (Continuity) (Scotland) Act 2021. The guidance sets out our strategic approach to environment policy, including the precautionary principle as it relates to the environment and how that should be used and applied by decision makers. The consultation has just closed, and we will consider the responses to it closely.09:45
Thank you. We are now able to bring in Beatrice Wishart—we are cooking with gas, as they say.
I will ask about aquaculture planning. We know that the Griggs report is coming out shortly. What assessment has been given for planning authorities’ needs for additional skills and training when considering aquaculture planning applications and how can the national shortage of planners be addressed?
That is something that we are actively addressing as well. As you said, we have the Griggs review that will come shortly. We undertook that independent review to see how we could make the regulation process and development more responsive, transparent and efficient. We will, of course, consider the outcome of that review closely.
Was the other part of your question about the knowledge that is within local planning?
We have taken action to address that. We recently published our response to the salmon interactions working group. One of the outcomes of that was that we identified the Scottish Environmental Protection Agency as the lead regulator for sea lice interactions. That marks a transition away from local authorities managing interactions through environment management plans. SEPA will work closely with local authorities to ensure that there is a smooth transition there. It is also consulting at the moment on a risk-based framework for managing interactions between sea lice from marine fish farm developments and wild salmon. Again, I can reassure you that these are issues that we are working on to address and there is a lot of work going on in this space at the moment.
My question is in two parts. First, how do we meet the challenge of an emerging conflict between the concept of permanent development and an increasingly changing coastline, particularly in light of the severe weather environmental changes that we have been having and will continue to have? How can planning policies for coastal and marine infrastructure take account of existing Scottish Government policies for fishing and the blue economy, including a future fisheries management plan and the upcoming blue economy action plan?
I will happily address that point that was raised in relation to the blue economy action plan, because we will be setting out our vision for the blue economy and, after that, our action plan. Essentially, that will provide a frame and an ambition for Scotland’s marine management policies, our strategies and plans. The national marine plan, regional marine planning and future fisheries management strategy will be key delivery mechanisms for the blue economy because that approach is about looking at our marine industries holistically. It will allow us to achieve our ambition for the sustainable stewardship of Scotland’s blue resources, which is consistent with the international commitments that we have for our marine environment. That is how these plans and strategies will come together under the blue economy vision.
On planning policies for coastal infrastructure, the minister will come in on that.
There are two aspects. First, our spatial strategy recognises the tremendous economic opportunities that are provided by our coastal communities and also the particular challenges that they face and their particular vulnerability to climate change. Within the policies, policy 35 is a specific policy on coasts. I draw the committee’s attention to policy 35(b), which states:
“Development proposals that require a coastal location should be supported in areas of developed shoreline where the proposal does not result in the need for further coastal protection measures and does not increase the risk to people of coastal flooding or coastal erosion and is anticipated to be supportable in the long term.”
Policy 35(c) states that:
“Development proposals in undeveloped coastal areas should only be supported if the proposal is necessary to support the blue economy, net zero emissions or if it would contribute to the economic regeneration or wellbeing of communities whose livelihood depend on marine or coastal activities.”
That particular tension that Ms Adam articulated is reflected with the spatial strategy but also very specifically in policy 35 on coasts. Fiona Simpson, is there anything that you want to add?
I would echo that. The policy has been developed and revisited from previous policy. There is an important link to local development planning and guidance that we are currently consulting on in relation to local development plans. Several of the national developments relate to coastal waterfront areas, reflecting the importance of looking at long-term resilience to climate change.
In NPF3, economic growth and development was a priority. The then Minister for Local Government and Planning, Derek Mackay, suggested that opportunities for altered forestry increased sustainable economic growth, and it led to the Government’s economic strategy. However, this draft of NPF4 does not mention economic growth at all, apart from two times in relation to the national transport strategy. Therefore, it does not appear to have any economic growth strategy. We want to ensure that Scotland optimises opportunities for growth and economic success along with a balance between development and environmental protections. Is that something that has been missed? If not, how have you addressed that in this document?
Let me say straight off that we are working on the national strategy for economic transformation as well, which will be critically important in addressing some of the points that you have raised. I come back to points that I have made previously: we are not considering these strategies in isolation to each other, and there will be strong links and alignment there. The minister may want to come in.
I echo that point. We have the forthcoming publication of the national strategy for economic transformation, and that will be published ahead of the finalised version of NPF4 coming before Parliament. Clearly, what emerges from that work will be reflected within the finalised NPF4. I would also say that the heart of NPF4 in terms of response to climate change, the climate emergency and the nature crisis is a move towards the creation of a genuine wellbeing economy. That is why community wealth is embedded at the heart of our six overarching principles that relate to sustainability. Creating a prosperous economy that works for everybody is at the heart of this document and it is a spatial expression of all of the Government’s policies, including the Government’s economic policy, and will reflect NSET once it has been published.
As the cabinet secretary is aware, we are also taking evidence on the Good Food Nation (Scotland) Bill. Conversely, I will talk about the urban setting in terms of how this planning policy is giving local authorities the opportunity to take due regard of the Good Food Nation (Scotland) Bill in the planning process. This is probably not a question; it is more an observation that that is something that will be vital. You have answered that you are taking a cross-cutting approach and that this consultation is looking at lots of policies. I want to make sure that there is due regard taken of the Good Food Nation (Scotland) Bill so that people in the urban areas can get access to food-growing areas.
That is an important point and I am glad that you have raised it. From the early engagement that took place in preparation of the draft, that emphasis on food and that support for food and drink and the ability to encourage community growing is something that came out strongly. That is reflected in some of the policies that have been set out throughout the draft, as well. For example, policy 14 talks about supporting space or facilities for local community food growing and allotments. There are also a number of other policy areas where we are encouraging that development. For example, policy 31 talks about supporting farm and croft diversification and there is specific mention of enabling that to encourage farm shops to open up.
NPF4 enables that positive development and encourages the ambitions of the Good Food Nation (Scotland) Bill. I know that the committee has been taking evidence on that. Everything that is in the draft NPF4 chimes with what we are looking at through the local food strategy. We had the consultation on that, which closed in December last year, and we are currently analysing the results of that. Planning and food is critically important, and we do all we can to encourage and enable the vision and ambition that we have set out through the Good Food Nation (Scotland) Bill.
Earlier this week, I took part in a visit to the James Hutton Institute and spoke to people from Liberty Produce and Intelligent Growth Solutions about vertical farming. It is interesting to see how that has also developed and how people now look to have vertical farms as part of housing developments. There is so much opportunity there and it is important that NPF4 enables that type of development to take place so that we can become that good food nation.
I want to ask a quick supplementary on the back of the point that the minister made there about crofting. I want to ask again about plans tying together and how she feels that achieving those aims that she set out for crofting would tie in with legislation on crofting.
We absolutely want to make sure that that read-across is there. As part of the engagement that took place in preparing for the draft NPF4, there have also been discussions with the Crofting Commission. These are not things that we are considering in isolation.
Thanks for taking part in this session. Clearly, we could talk to you for a lot longer on this. We are just scratching the surface.
My question is about process. Your consultation will end at the end of March, as you said. What happens then? In the evidence sessions that I am doing in the Local Government, Housing and Planning Committee, it is clear that there is some pull-through and some knitting together of some aspects in relation to clarity. I hear you saying that you do not want to be prescriptive and that you want to be flexible, but I also hear a lot of comments from planners who say that they want clarity. I am concerned about what the process is after the consultation ends on 31 March. This NPF is a draft. When do you expect to bring the final one to Parliament?
I am conscious of time, so I will be brief. We will take into account all responses that we have received through public consultation and that parliamentary committees have received, in writing and orally. We will reflect on those and we will seek to make judgments and seek to incorporate where we think that there are points that we can improve. We will feed that back through our consultation response and into the final NPF4. Our aspiration is to be able to lay the finalised NPF4 before Parliament prior to summer recess for adoption. This work is taking place at the same time as the consultation on the LDP regulations.
I want to be clear to the committee and give a commitment that we very much value all of the engagement. There is still a substantial amount of engagement to take place—I am conscious that your consideration will be on-going. I am heartened to see the amount of community engagement that has started to take place. That is something that, in my ministerial capacity, I am looking forward to engaging in. At this point, we are very much in listening mode and welcome this opportunity to articulate what our thinking has been in preparing the draft NPF4.
We are extremely grateful for all of the contributions that people have made to get to this process and are making now to share their views. I give the undertaking that we will take all of that into account and be clear and transparent about how we arrive at the final decisions that we put before Parliament in relation to NPF4. It is, of course, a matter for Parliament to decide whether or not to approve NPF4, so that it can be formally adopted by ministers.
Fiona Simpson might want to add some more on the process.
Just to add that there is a new requirement as part of the 2019 act where we set out how we have taken into account views that have been received during the 120-day period.
I thank the minister, cabinet secretary and witnesses for giving evidence this morning. I will suspend the meeting briefly to allow a change of witnesses. We will reconvene at 5 past 10.09:59 Meeting suspended.
10:04 On resuming—