Evidence on the Third National Planning Framework for Scotland

Professor Glen Bramley
Professor Glen Bramley

Professor Glen Bramley was invited to give evidence to the Scottish Parliament, Infrastructure and Capital Investment Committee, as part of their examination of the Third National Planning Framework for Scotland and the revised Scottish Planning Policy, at a meeting yesterday morning. He provided a written note of evidence which is reproduced below.


These comments are deliberately short, and confined to topics on which I have a sufficient knowledge and involvement to comment. Since the publication of Proposed Framework (‘Ambition – Opportunity – Place) coincided with the publication of the Scottish Government’s Position Statement on Scottish Planning Policy, and in view of the interdependence of NPF, SPP and Strategic/Local Development Plans in actually delivering planning outcomes, some of my comments refer in part to that document as well.

City regions

The emphasis on cities and city regions is a welcome development. The document demonstrates the key importance of the major cities for future development, although the inclusion of some recently-designated ‘cities’ is questionable. The Scottish planning system shows marked superiority to current arrangements in England, where there is no national spatial framework or policy and no regional planning machinery.

Roots of economic success

The issue of what lies behind economic success is touched on at various points  (e.g. para 2.8), where it is linked to the notion of a ‘place-based approach’. This can be connected to concerns expressed about SPP in the consultation, that it has not adequately defined the overarching goal of sustainable economic growth. I think the place-based approach is an advance. However, observing events and developments over the last 2 decades I would say that planning practice and associated decision-making, at local and national levels, has not fully got the message. The quality of place (‘natural and cultural assets’) is fundamental to the success of Scotland’s cities, most notably Edinburgh. It is belittling this relationship to suggest that it is just related to tourism and ‘food & drink’ sectors. The strength and vitality of the Edinburgh economy reflects the appeal of this overall environment to what Richard Florida has called ‘the creative class’ i.e. innovators, leaders, highly skilled practitioners in a whole range of sectors, not least higher education, R&D, ICT, life sciences, medicine, health, financial and business services, etc. [REF 1]

I sometimes feel that when someone (usually a developer) mentions‘economic development’ or ‘jobs’, a lot of decision-makers in local and central government leave their common sense and critical faculties outside and fall over themselves to approve the proposal, regardless of the quality of the proposal, its sustainability, its impact on ‘place’ qualities and other sectors. I see continuing examples of this kind of decision-making, even involving national agencies which should know better.

Growing and Declining Areas

The balance of attention and investment between areas of success/growth and decline is a difficult one  (para’s 2.9-2.11). There are dangers of housing oversupply in some areas subject to persistent decline, and throwing more housing investment, or planning consents, at these areas can be wasteful and damaging. The Scottish Government cannot massively invest in all declining places, and some current proposals look fairly high risk (para 2.21).  Some ‘national developments’ seem to adopt an unrealistic approach in suggesting priority to facilities with less prospects (e.g. all 6 airports?). It may be the case, realistically if regrettably, that not all smaller town centres can survive in their traditional form, given the changes in retailing. In relation to derelict land (para 2.20), greening strategies may be a better solution, in the short and longer term, than aspiring to economic developments which are unlikely to materialise.

However, it is not just a case of saying use all the scarce public investment resources in the highest growth locations. Developments in these locations could actually pay a much greater share of the infrastructural costs of their development through a more robust approach to development contributions related to residual land value, enforced through tariff and planning agreement mechanisms. The Scottish Government has been unduly timid on this issue and too susceptible to misleading lobbying by the development industry, not helped by the recent recession.

A Plan-led system?

Previous iterations of planning policy have placed great emphasis on a ‘plan-led system’. The NPF document seems not to use this term, but it does appear in the SPP Response document in its treatment of ‘Issue 2’, because many representations from third sector, individuals and local authorities were concerned that an imbalance between Economic and Sustainable development considerations compromised the plan-led system. The SG response suggests ‘That development plans reflect the presumption [in favour of development] to reinforce the plan-led system’. While this does suggest that SG is still committed to a plan-led system, it seems to be implying that development plans should be more demand-responsive or accommodating with respect to economic development.

I have previously argued [REF 2] that a decade ago Scottish (and to a large extent also English) planning was so ‘accommodating’ of economic developments that it had effectively given up any ability to influence the location of such developments i.e. to ‘plan’ for it. The current state of SPP seems to be going even further in this direction, which I would argue is in some senses the negation of planning.

As in that 2005 study, one can continue to observe major developments, which change the urban structure and footprint of our leading cities, appearing and gaining planning approval, without having ever appeared in ANY of the formal statutory forward planning documents. These developments are persuasively presented with ‘Masterplans’ etc., but they are fundamentally opportunistic developments promoted by particular landowners, or developers working on their behalf. The coherent planning and implementation of major development zones in our capital city (notably the waterfront, as well as West Edinburgh) is bedevilled by the fact that there are several major landowners competing and not cooperating. To add insult to injury, several of the major landowners involved are in effect former public land-owning bodies which were privatised over previous decades.

Housing Land Supply

I agree with the statement that there needs to be ‘a generous supply of housing land in sustainable places where people want to live’ (para 2.17), while underlining that this does not apply to all areas in Scotland. I would, however, argue that this should not be at the expense of a planned approach – the locations of major future housing developments should be determined through the forward planning part of the statutory planning system, not through individual applications or appeals.

A particular issue on new housing developments is density. I do not agree with the suggestion (para 2.19) that ‘further increasing density’ of residential developments is particularly desirable or appropriate, although there is some scope around some public transport nodes. Evidence on social sustainability, general preferences or market values does not support a predominant pattern of high density flatted development, although there is support for medium density mixed housing types [REF 3]. The market for 2-bed high rise flats was saturated in the previous boom. Excessive emphasis on this could increase longer distance commuting.


It is clear that infrastructure capacity constraints have been and remain a major problem (para 2.18). It seems to me that existing mechanisms are inadequate, as illustrated for example by the very delayed development of most of the S E Wedge of Edinburgh (Shawfair).

I suspect that a lot of these problems are around questions of who is expected to pay for it, with a continuing expectation in many quarters that the government will pay for most of it. In my view, this is a problem – there is never going to be enough money.  In high demand/high value areas, the developments should pay for it, through tariffs and planning agreements, as argued above. Once this expectation becomes clearly established, the cost of this will fall on the residual land values, not households or businesses.

The NPF makes particular mention of West Edinburgh, as one of most important areas for Scotland which ‘will require continuing co-ordination and planning’. I absolutely agree with this sentiment, but am much less clear about what is actually  happening and who is in charge. As noted above, there appear to be major developments/proposals appearing which are not in any of the planning frameworks.

Housing in Greater Edinburgh is mentioned as another particular challenge, with the document talking about ‘a planned approach’ and a ‘greater and more concerted effort’; there are references to infrastructure issues like road capacity but the implications are not clear. There is an established city-region planning structure formally constituted which has gone through a first planning cycle – why were these problems not resolved by SESPLan at that stage? This looks like the new planning system failing at its first serious test. However, it may be unfair to blame this local authority-based body for some of the infrastructure deficiencies, as it is unclear whether they have got the resources or powers to deliver the requisite transport infrastructure (e.g. A720 widening & junctions, more quality bus corridors, extend tram network (!!)). These mainly reside now with Transport Scotland/Scottish Government.

Rural development

My main comment about rural development (para 2.24) is that the general principle of not sacrificing longer term growth based on quality of place and environment for short term economic gain still applies. I think that means there is a need for more National Parks, other protected landscape designations, marine conservation areas, and the like. I see evidence from particular cases that the combination of LA decision-making and advice from national agencies may sometimes be insufficient to achieve appropriate decisions.

Careful planning is needed to manage demand in accessible countryside around towns and cities (para 2.24). I strongly agree with this statement, but I am not clear that this is necessarily happening. The opportunity to reform and restructure Green Belt policy was fudged in 2005 [REF 4].  Some city regions have taken a more forward-looking approach to this than others (e.g. Aberdeen vs Edinburgh). Detailed policy on this now seems further submerged in the vaguenesses of the streamlined SPP. I think this is an area of policy characterised by hypocrisy and a systematic misleading of the public.


[1] See especially Florida, R. (2002) The Rise of the Creative Class, and how it’s transforming work, leisure, community and everyday life. New York: Basic Books; and also Harding, A. & Turok, I. (2005) Changing Cities: Rethinking urban competitiveness, cohesion and governance, Basingstoke: Palgrave; Glaeser, E. (2011) Triumph of the City: Basingstoke: MacMillan

[2]  Bramley, G. & Kirk, K. (2005) ‘Does planning make a difference to urban form? Recent evidence from Central ScotlandEnvironment & Planning A 37:

[3]  See Bramley, G. & Power, S. (2009) ‘Social Sustainability and urban form: the role of density and house type’, Environment and Planning B: Planning and Design, 35;  Bramley, G., Brown, C. Dempsey, N.,  Power, S. & Watkins, D. (2009) ‘Urban form and social sustainability: evidence from British cities’, Environment & Planning A; Dempsey, N., Brown, C., Bramley, G. (2011) ‘The key to sustainable urban development in UK cities? The influence of density on social sustainability.’, Progress in Planning;  Bramley, G, Dunmore, K,  Dunse, N, Gilbert, C Thanos, S & Watkins, D (2010) The Implications of Housing Type/Size Mix and Density for the Affordability and Viability of New Housing Supply, NHPAU, London; Ng, E. (Ed.) (2010) Designing High-Density Cities for Social and Environmental Sustainability. London, Earthscan.; Bretherton, J. & Pleace, N. (2008) Residents’ Views of New Forms of High Density Affordable Living, Coventry, Chartered Institute of Housing; Chan, Y.-K. (1999) Density, Crowding, and Factors Intervening in their Relationship: evidence from a hyper-dense metropolis. Social Indicators Research, 48, 103-124.; Jenks, M. & Jones, C. (Eds.) (2010) Dimensions of the Sustainable City, London, Springer; Kearney, A. (2006) Residential Development Patterns and Neighborhood Satisfaction: Impacts of Density and Nearby Nature. Environment and Behavior, 38, 112-139. :

[4]  Bramley, G., Prior, A,  Raemaekers, J.,  Hague, C. & others (2004) Review of Green Belt Policy in Scotland. Social Research Report. Edinburgh: Scottish Executive Development Department.

Picture credits: Picture of the Scottish parliament, as seen from Salisbury Craigs, taken 29 April 2006 by Klaus with K under a Creative Commons License.