Good morning and welcome to the third meeting of the lower government housing and planning committee in 2022. I would ask all members and witnesses to ensure that their mobile phones are on silent and that all other notifications are turned off during the meeting. The first item on our agenda today is evidence-taking on the draft of the fourth national planning framework, or NPF4. This is the second of five evidence sessions that the committee will be holding on NPF4. The focus on today's session is on planning, and we will be hearing from two panels. On 1 February we will be exploring issues around housing, and on 8 February we will be looking at local government issues. The committee will hear from the minister on 22 February. For today, I would like to welcome to the committee the first panel, and that is Robbie Calvert, who is a practice and research officer from RTPI Scotland. Claire Simmons, who is the founder and chair of planning democracy. Elsa McFarland, who is the director of the Built Environment Forum Scotland. Barbara Cummings, who is the vice chair of planning aid Scotland. Christina Gager, who is the president of the Royal Incorporation of Architects in Scotland. Thank you very much for joining us today. We are going to move straight to questions. Witnesses, if you wish to respond or contribute to this discussion, please add an R to the chat box to indicate this. What we tend to do is have a practice of whoever is asking the question will ask the question and then maybe direct it to someone to initiate, but don't feel that that means you can't come in. Use the R in the chat function and I or the clerk will pick that up. I am going to start with the first question. The draft national planning framework represents a significant shift in national planning policy, with a new focus on issues of place, livability, wellbeing and emissions reduction. Is the Scottish planning system set up to deliver such outcomes? Or are changes needed? If so, what changes would you like to see? I am going to direct that question initially to Robbie Calvert and then Elsa McFarlane. Robbie? Just to set things off, we very much support the travel direction of the framework. There are some very ambitious and laudable elements proposed in it, and we really hope that that lifts the collective aspirations of what the Scotland Think Planners and Planning can provide on a number of outcomes, tackling the twin and climate and biodiversity crisis, achieving inclusive green economic recovery and reducing health inequalities across the country. We very much support the inclusion of an importance attached to the place-based approaches throughout the framework, especially by embedding the 20-minute neighbourhood concept and various things, including having a stronger presumption against out-of-town retail. Throughout the process, we have maintained that success will be in the implementation of the framework, not the preparation. I know that a number of stakeholders are keen to see the delivery plan, which we understand will be published alongside the final framework in June. We understand that Scottish Government is working with Scottish Futures Trust on this, drafting it at the moment. We hope that the process by which the engagement happens to that is as inclusive and as collaborative as the entire process has been so far for the draft framework. We very much believe that to support the ambitions in the plan, we need to have appropriate resourcing in place. All along, we have been advocating for publication of a capital investment plan alongside the final framework, which is what is seen in Ireland, which was published alongside the national planning framework. We also need to consider the resource requirements of the planning system to implement the plan. Although we welcome proposed fee increases, we do not believe that that will sufficiently address resourcing issues in the planning system. Our research has shown that, since 2009, we have had a third in staff numbers and budgets that are diminishing by 42 per cent in real terms. A number of new and unfunded duties are coming through, which we see in the draft framework, but they are also resulting from the planning act. Alongside that, we also have an issue of pipeline of planners. Over the next 10 years, we think that there will be a demand for an additional 680 planners in the sector. We need to ensure that there are enough planners to be able to process the applications. To address that, we have called for a comprehensive resource and skills strategy to be published alongside the delivery programme. That would consider issues that include the capacity issues, both current and predicted, but also the new skills and training requirements that are resulting from the framework. There are a number of examples in there, such as the lifetime carbon assessments and upskilling planners in terms of their climate literacy will be critical. We want to set out the plan to ensure that we have a stronger pipeline of planners, as well as to implement the framework over the next 10 years. A similar strategy has been promised alongside planning reform in England. There has been acknowledgement that the resource is required to deliver it. I will stop there for now. I will let someone else come in. The First Minister Thank you very much. Elsa, I would like to bring you in on this one as well. Because we have a couple of policies in the national policies that focus on climate and nature restoration, I would also like to get a sense of whether you believe that the goals for climate change and emission reductions within the draft framework are achievable and consistent with other policies in the draft. Elsa, if you could pick up on the first question about the planning system being set up to deliver, but also bringing in your thoughts on the climate emissions reduction piece? Thank you very much, convener. I will support much of what Robbie Calvert at RTPI has just said about the delivery regarding the planning system. Regarding the system set up to deliver, I would say that there are some things within NPF4 that do not necessarily point as strongly towards the green names, as we could hope for. I would say that issues around embodied carbon and our existing places are perhaps not fully realised within NPF4, particularly because there are not the clear links to other strategies, such as the heat and building strategy, for example. With that, around delivery, there has been a concern from a number of first members that the national planning framework has the opportunity to link to building standards much more clearly. Through that, it is part of the way that delivery can be met and that those are areas that need to work hand in hand, rather than necessarily be separated. We would also say that the system more generally needs clarity around the hierarchy of policies across the Scottish Government, but also considering policies within the document itself. I am aware that there is not necessarily intended to be waiting across the document, but, unfortunately, that means that a lot is left up to individual planning departments and sets up a potential adversarial planning system quite unnecessarily, because that clarity is not given. That potential adversarial nature does not benefit our places and it does not benefit our communities. One of your initial questions was regarding the fact that NPF4 is much more people and community focused. I would say that community engagement and the potential for local place plans and their integration within the national planning framework is not as fully articulated as we could ensure. Does that help to answer your question? Thank you very much. That is great. I see that Clare would like to come in and then Robbie, I see that you want to come back in, so I will bring you in again. Clare? Yes, thank you. I would just like to say that we are members of BEFs as well, planning democracy, and members of BEFs. I very much would reintroduce what Ailsa has said. Thank you for saying that about communities, Ailsa, and what Robbie is saying around fees. Our concerns about planning being resourced by fees alone is that it needs a little bit more independence because the fees come from the developers, who are seen as the chief customers, and that might translate as them seeing that the priorities need to be to assist them with their planning applications or whatever. I think that we need to have a separate resourcing for allocated for community stuff and for also things like ecologists and so on. I think that that needs to be separate. I think that you were talking about the climate and biodiversity emergencies that are being given priority. We really welcome their prominence in this document, and we do not underestimate the scale of the change that this heightened emphasis requires from taking it from a narrow focus on delivering the Government economic strategy to including priorities on climate nature. That is great, but changing the default orientation of a system that has long seen development as an intrinsically good thing will take some doing. The training and resourcing that comes through that is really crucial. Given that all built development will generate climate impacts, I would emphasise what Ailsa was saying about strong policy guidance, but also on the prevention of non-climate friendly development. We want to scale up the good stuff, such as the renewables, but we crucially need to scale down the bad stuff, so we should not be planning or consenting for any new development that will contribute to climate change or the loss of biodiversity unless it is absolutely necessary to meet social needs. That will set up some sort of battleground, I know, about how necessity is defined, and that is where the skills need to come in and the resourcing. There is one part of the climate policy that I have a concern about, and this is to see. It states that if a development generates significant emissions, it should not be supported unless the developer can demonstrate that it will not be viable, or that it is in the long-term public interest. That reflects the tradition of discretionary planning and loose space for decision makers to justify the development that does not meet the required standard. I am not sure what developments that it is aimed at, whether it is coal-fired power stations or housing on greenfield sites or spaceports or what, but surely the climate emergency is not in the public interest. What kind of circumstances are there where the public interest overrides the climate imperative? We have to be careful that we are not creating a new language game on technical definitions around viability. If a development is not viable, does that mean that you do not have to pay attention to the climate? At what point do you want that development? That is where we need clarity. The outcome of the policy clause will be that it will generate an industry for viability studies and plenty of employment opportunities for consultants to argue the toss on whether development is in the public interest rather than incentivising developers to construct less-carbon intensive development. We recommend that the word needs to be strengthened to make it clear that there is a presumption only in favour of development that is strictly necessary and better to state that the development that contributes significantly to climate emissions is just not acceptable only in very exceptional circumstances. I mentioned that I was going to bring in Christiana and Robbie, but I think that I will go to Barbara because she has not spoken yet. We will go to Christiana and Barbara and then if we have time on that because we have lots of questions, so maybe I will bring you in again Robbie, but I also would like to move on. Thank you for being here. We have covered a huge amount of ground already this morning, so I do not want to go over anything. However, it is more of a slightly broader brush response to your questions this morning. The construction operation and maintenance of the built environment accounts for about 45 per cent of total carbon emissions. When we are talking about climate emissions policy and are the goals achievable, I think that even though this is a spatial plan for Scotland, the alignment to 2045 in terms of our map to net zero as well is also absolutely critical. There are a few key things missing or emphasis is missing in this document that would help that alignment, including our existing building stock and how we are actually looking at the, sorry, I love a statistic, 85 per cent buildings that are standing today will be here in 2045, so how are we addressing them? I feel that the emphasis throughout the document is very light on that approach and it plays a really key role in achieving those goals in terms of net zero and emissions, so that is just something to bear in mind. Another way of looking at this in terms of the question about is the set-up rights to deliver the outcomes that we are looking for. The planning process is the first statutory stage. It is so important, but it is one part of the process. The opportunity to define a route map and targets for industry, which has its head in the sand, especially around climate, is a huge opportunity through this document because it has the potential to effect change within that planning system that is that first statutory stage. The opportunity to embed the ambition at that first stage sits within that document and I feel that that can be really brought to the fore because in the building industry, for example, you have got planning, Elsa mentioned building control, building standards are so important and then procurement, that is the delivery process. The delivery does not just happen at the end in terms of construction, the delivery is the whole thing. It is joining those dots to make sure that the policies and the framework are set up so that the goals that are achievable run through the whole system. Even though this is a spatial plan, I think that as that first statutory stage, it has the opportunity to really grab that opportunity a little bit more than it does at present. Thank you very much, Christina. I really appreciate you bringing that perspective in. I love stats. 85 per cent of buildings will still be standing in 2045. I walk around any town or village that I'm in and I'm just like, how are we going to do this? How are we going to do the heat and homes and things like that? That certainly needs to be addressed. Barbara. Thank you very much and good morning everybody. Thanks for the opportunity to speak on behalf of PAS. We support communities to engage in decision making that affect their places, so I very much echo what others have said. I think that there's been a lot of talk about the additional work that will come to planners and new duties, new requirements and new policies, but actually this is a statutory plan for the whole of Scotland and communities also will struggle with some of the concepts and perhaps some of the lack of clarity around priorities. It's really important that we build trust in the planning system in Scotland because we know and Claire has highlighted this, you know, developers are seen as being the bad guys. Well, we need development, we need the right development in the right place and whilst planning has always been about achieving balance, I think that that lack of clarity in some of the policies around how this will be implemented is really important. The chief planner in her evidence pointed to the fact that local communities can be part of that delivery mechanism. Everything happens in a local place. This might be a national plan, but it all happens in a local place. We want to stop these things, the new requirements being tick box assessments that communities look at and go, well, yes, you said you were going to do this, but actually it's just in a written assessment and it's not happening on the ground. And through ensuring that communities are engaged in the process and involved in what happens, we'll build that trust, but they need to know the basis on which those decisions are starting. So, if the climate emergency is number one, then I think that we should be quite clear about that so that there's no debate and communities are clear that that's where we're starting from. Thank you very much for your response. Robbie, do you briefly want to come back in on that climate question and then I'll move on to questions from the colleagues? Yeah, I'll keep it brief. I'm really just supporting Anne Barber and Elsa's comments there on the sort of clarity of language used in this document. It is part of the statutory development plan and plan is going to have to defend these policies that appeal. So, whilst we appreciate those inherent complexities with planning, still a need to give sort of clear consideration of stress tests on the policies in the framework provide as much certainty and clarity for decision makers as possible. And appreciating the points that Scottish Government made in regards to being too descriptive in the use of definitions, we still feel there's an opportunity to provide further guidance and detail on a number of policies. Regarding net zero ambitions, if you look at, for example, policy 19 on green energy, the planners are to support development proposals unless the impacts are considered unacceptable. Well, unacceptable is not defined within the framework and that could lead to a lot of challenge at appeal and a public inquiry as well. Thanks so much for that. I really appreciate it because of that kind of detail that you're giving us that, you know, policy 19, this phrase, you know, accept the word acceptable, right? That's very helpful for us because we need to understand what you need to know, what people in the sector need to have really spelled out. So, we're all moving together in this in a good way. I'd like to move on and bring in Miles Briggs, my colleague Miles Briggs, and he's got a number of questions for the panel. Thank you, convener. Good morning to the panel. Thank you for joining us today. I wanted to ask specifically a question with regards to public involvement, whether or not the panel felt that the policies set out in MPF4 actually make provision for meaningful public engagement in the development of the plan, but also in developing the management processes as well. I wondered whether or not you felt that there is the opportunity for the public to get involved, and if not, what would you like to see change around that? So, I might be bringing in Claire Simmons and if anyone else would like to come in and are in the chat as well. Thanks. Thank you. Public involvement, I think that with regard to the local development plan consultation is running at the same time at the moment, and I think that's going to set out some of the ways that the public could get involved in these things. I think that with regard to appeals, as we've been saying, I concur with what Robbie was saying about appeals. Have we got a plan-led system? If we're going to get people involved in planning, then we need to stick to the plan-led system, which is policy 1, but that just states what is in the legislation at the moment. We have to have far more monitoring of policies that go contrary to the local development plan. We have to have far more strict language about developments that do not comply with the local development plan. With regard to anybody drawing up a local place plan or getting involved in their local development plan, if the decisions that are made are lots of exceptions to that plan, then that makes a mockery of the public engagement. We really need to ensure that the wording is strict and that we have to comply more with the plan. With that, we think that the right of appeal for communities to appeal any decision that goes contrary to that local development plan is a really good incentive. We asked for that in the planning legislation. I know that it's not within the gift of the committee to introduce it through the national planning framework, but it still remains a point that, if we're going to stick with the plans, we need incentives for developers to do that. Thanks, Claire. I'm going to bring in Barbara. It's always notoriously difficult to get lots and lots of local people involved in the development plan process. The further away that feels from people, the harder it is. At a national level, those concepts are not real to people. It's only when things start to happen on the ground that it becomes real and then they get engaged and then they realise that they've missed an opportunity. I think that's why the local place plans will be absolutely key because it gives communities a route to influencing the plans that happen above them, if you like. The chief planner talked about flexibility within the system to allow things to change so that local communities are actively influencing what's happening, not just in their local area, but how that might affect more broadly a local development plan that's perhaps out of sync with their local place plan. It's really important that the NPF4 supports that process and recognises that process. I was really encouraged to hear the chief planner talking about that because it's not explicit in NPF4 in that regard, but it's implicit and obviously the legislation is in place. Again, that means that we need clarity within NPF4 because local communities will be looking at how that influences the plans that they create. The committee has received a number of written submissions, which express concern. We've already touched on that this morning about possible inconsistencies between the national planning spatial strategy and national planning policies. I think that we know what they look like. Language is sometimes a barrier with different words and different things to planners and the emphasis on what that might mean. I wonder if the panel had any ways of rectifying some of the issues that have been put to us and how we could make sure that both local councils and the national planning strategy match up in delivering what we want to see in NPF4. I don't know if you could bring Robbie in as you had touched upon some of that earlier, and if anyone else wants to. Thanks, Miles. One thing that we said in our response is that there needs to be real consideration of the read across of the document. You referred to the spatial strategy. Part 1, for example, the spatial principles section has some really important concepts in their compact growth and balance development, but we find that it doesn't really pull through the rest of the document through into part 3 into the actual policy section. We think, as a starting point, that any of the spatial priorities set out in section 1 have a clear pull-through into section 3, and we think that that would make planners' lives a lot easier and communities when they are looking at the document. We can reduce potential conflicts of policies there. Again, I understand that there is inherent complexity with every planning application, but an example would be back to policy 19 again, which is a more permissive policy if you had read it at first in terms of delivering renewables. However, compared with policy 32 there, it is potentially a less permissive policy environment for onshore wind in reference to some of the wildland areas. There is quite a lot of conflict and contradiction throughout the plan, so a clear understanding of the read across of various elements will be important to success. Thanks for that. Ailsa, do you want to come in as well on that question? You are on, Ailsa. Oh, no, no audio yet. There you go. It's not you who broadcast handles everything. Well, I pressed the button, so hopefully you can hear me now. Two, three, with what Robbie said about the read across between different parts of the document, and maybe to pick up on a few points of detail that you mentioned. Across the document, we felt that the historic and existing environment is not referenced fully where it could be, which brings in a lot of the things that we have been discussing about various policies, as well as the ability to meet net zero. However, there are specific policies such as one of the successful place qualities, quality six. It mentions adaptability and that our places should be maintained over time. We very much want to say that this is more than a quality of successful places, because it is fundamental to maintain our places so that we can reuse and re-purpose. Those are qualities that are mentioned in the document, but they might not be as fundamental as they might be. Going back to the interconnectedness of various things, infrastructure first is mentioned within policy eight, but the infrastructure commission report specifically mentioned that existing housing is part of infrastructure and that to enhance and maintain existing assets ahead of new build was one of the principles. Within infrastructure, the document almost purposefully manages to just skip over our housing and our homes as part of infrastructure, which means that some of the principles do not tie together as well as they should. Again, the blue and green infrastructure, the long-term stewardship and effective management and maintenance plans are referenced in relation to that, but not perhaps in relation to other developments. Obviously, what Christina MacDonald mentioned earlier about 85 per cent of a built environment will still be existing in 45, is the case that we should be building with maintenance and those plans for stewardship and for the future integrated within that. Just to touch on things that, potentially, as Mr Briggs was asking about community involvement as well, from the historic environment perspective, there are a number of documents that, if they were represented within NPF4, would help local places and the authorities dealing with those places to better represent them. Historic environment records are missing, planning advice note 2 slash 2 0 1 1 is missing. It is not just that the historic environment policy for Scotland itself is not, perhaps, as is clearly referenced in the document, but those two, the historic environment records and the planning advice note, what they do is, currently within Scottish planning policy, they are offering a better understanding and protections for our non-designated assets, which is around 95 per cent of our existing historic environment. They provide a wider understanding of communities' own place and their own appreciation of the historic environment, rather than necessarily focusing on designated assets, which are obviously extremely important, but it is enabling the document to see that balance. I just wanted to take a slightly different tack on that, because we are reading the document as a linear document, and lots of people have said about how you need to read it as a whole, you need to balance all the parts. There will be a degree of conflict, because we like a wind farm, but we do not like it there. There has got to be that, but we can use digital technology to support how everything hangs together. It cannot be beyond the wit of man to have lots of links and connections that, if somebody does not understand what is in front of them, they can click on that, get a definition, get a read-through to the document that it refers to, or to other policies. The Scottish Government is investing a lot of money in digital technology. MPF4 could look very different, and it could help people to navigate that complexity and read it in a more rounded way, so you are not just going through from page 1 to page whatever it is at the end.  We were quite disappointed to see no reference to the Scottish Government's digital planning strategy in the delivery section of the draft plan. To build on my point on how we can support planners to implement the plan, a lot of it is also to do the complementarity that the plan has with other plans and strategies. The devil is in the detail with the plan, but some of the detail exists elsewhere, and some of that detail is out of date. We identified a number of plans, strategies and national policy statements that we consider out of date, including Scotland's national marine plan, which is 2015, designing streets guidance in 2010, creating places in 2013, the development planning and management transport appraisal guidance in 2011, the town centre and retail methodology in 2007. Those were not produced in the same policy context that we find ourselves in now with the twin climate and biodiversity crisis, and they need to be updated to strengthen the plan and support planners in delivering it. Thank you for that. We have a lot of work cut out. Christina, would you like to come in and then Claire? Thank you, that's appreciated. I think that just to go back to Barbara's point, you know that that strong thread that is needed throughout everything will help with any confusion, and I think that it's that clarity in the documentation that exists across the board from historic assets to green energy are actually linked, so you can see that bigger picture. I think that that's a really big part of it, because the document is covering a huge amount of ground, and I think that everything can't sit in one place. There needs to be that hierarchy, but when you have that hierarchy, something needs to have sufficient weight attached to it, so there needs to be a primacy within needs that's helping people to understand where the priorities lie. I think that that's a really key thing to be able to read this document. Alongside that, there's the mention of quality throughout a few policies. What is quality? What does that look like? Actually, there could be examples of best practice that, as this is rolled out because it's a long-term strategy, it's this type of flexibility, and it can be updated to guide people on what that best practice is, what the post-occupancy is, and why is it best practice, so that there can be a level of explanation that helps to support any queries or any confusion about what something might be. That could be added to over time, but again, that strong thread, that digital support to hang everything together, what Barbara said, that is really key, but it comes down to what are the important principles, what's taking primacy, and running throughout is really important. We have a concern—we were talking about the primacy of policies and policies in the round, how we decide which ones are more important, but it feels like that the housing land policies seem to have been developed in a bit of a climate vacuum. Land is a limited resource, and if you care about limited resources, you need to be efficient. It's crucial that we build new housing as efficiently as possible. I'm pleased to hear other people's comments about existing buildings, and maybe we need to be looking at that to resource our housing crisis. At the moment, the way that housing is being done is very inefficient and relies on a generous allocation of land supply to meet housing targets. That doesn't allow you to target where the infrastructure is going. We're talking about infrastructure first. How can you target that if you've got such generous allowances for land, as we've suggested in this document in the annexes? We think that the generosity of the minimum alternative housing land requirement won't encourage efficient delivery. When people move into a new-build house, more than half the lifetime emissions of the building have already been emitted, so we need to think about that in terms of climate. Moving on to the shoulds and the musts that were mentioned by Fiona Simpson in her evidence last week, where she said that where the word must have been used, where there's a statutory requirement, where it's a policy or practice that they've tended to use should, has come up an awful lot when we've been talking to communities and when we're talking about providing clarity. That was a useful comment that Fiona made about why they've chosen that language, but then that needs to follow through, because there's things like the climate and biodiversity policies contain a lot of shoulds, but there are legislative duties on both. For example, the duty on every public body and office holder to further the conservation of biodiversity when exercising their functions is part of the Nature Conservation Act 2004, so that implies that maybe the language should be around must in the document, and that confuses people. Maybe that language needs to be tightened up a bit. Thanks, Claire. Miles, do you still have more questions that you wanted to ask? No, I think that they've all been covered, so I'm happy to have them. Great. Thank you. All right, we're going to move on to questions from Mark Griffin. Thanks, convener. Good morning. I wanted to come back to an issue that Robbie Calvert touched on in answer to the opening question, and that is around a funding document to support some of the excellent aims and principles in pf4. To see some of those realised, some of the submissions have suggested that the pf4 document should be supplemented by a cartel investment programme. I just wanted to perhaps start with Robbie and then go around the rest of the panel to see if they would support that inclusion and essentially the necessity of that thank you. To deliver a lot of the intentions, even if you think about, for example, the national developments within this plan, how are they going to get delivered? Where's the money coming from that? For example, the infrastructure investment plan or the programme for infrastructure investment plan only had three of the national developments within that, and none of the national developments were mentioned in the programme for government. I guess we're concerned. Where's the investment going to come to help to deliver those things? A capital investment programme, from that perspective, would be useful, but yes, absolutely in terms of understanding what kind of resource will be required by the planning system to deliver the intentions of this framework and other things in the planning act as well. For example, local place plans, going back to the community engagement question earlier, there is a strong policy steer under policy 4 for community engagement, but quality community engagement is resource intensive. Unless planning departments get the resource that they require, it won't be undertaken to the level that it could be otherwise, so we would entirely support the capital investment programme that looks at resourcing in the round in terms of capacity required, in terms of skills required, and in terms of bringing on and off planners to process those planning applications when they come through the system. Thanks for that. Does anyone else want to come in on this? No indication, Mark. I think that I've got clear, and then I'll plan the chat. I just wanted to talk about public-led planning, because I was talking about land being a limited resource and targeting housing in the right places. Public-led planning is the way to go on that. We really agree with what the Scottish Land Commission and others have stated that the challenge to achieving affordable housing aims is to move away from a market-led system to a more public-interest-led model of housing development. That is only mentioned as a footnote in the delivery section, but it is crucial that that is properly funded. It is about £300 million or something that has already been given to affordable housing, but if we are really going to get affordable housing delivery, we need to do that through the public-led planning mechanism. That needs to be adequately funded. Thanks, Claire. I will come in with a supplement on that. Sorry, Mark, to jump in. Because you both mentioned community investment, we were with a group called Celebrate Kilmarnock yesterday, taking evidence and learning a lot about their experience. Something that came up was about the local authority processes and a request for them to be improved in a way to accommodate community involvement. For example, things such as consultation fatigue because people get really involved, really engaged, really excited and then takes quite a long time for the results to come through. A question about how we can improve the community process with local authorities. Claire? I think that what we need is that kind of structure and the culture of community engagement. I think that we look to the local governance review coming up that might be able to assist with setting a framework and a culture where people are involved better. In our evidence, we suggested public interest panels as a way of involving people in planning decisions in a way where you have a deliberative debate about it and a meaningful debate. That makes a change from doing vast amounts of written consultations because not everybody has the capacity to look at what people are expected to read through the national planning framework. If you are a busy nurse, how are you going to find that time? We have a nurse at the moment who has come to us. She has four applications for housing developments to get through and they are coming again and again and being changed and she is writing to us saying that it has changed again and I have to comment again. It is incredibly time consuming and you do not know for what. What is going to change? There is no guarantee and to boot you will be labelled as a nimby. I think that we have got to get rid of this culture. When we are talking about community wealth building, what about the public community partnerships that could be developed and deliver better housing through community wealth building model? That is a section that could be developed a lot more again. It is a little bit minimal, but I understand that that is an evolving thing. That could be very exciting if the willingness is there to work with communities rather than just seeing them as somebody who has got to respond to a consultation. I want to come back to you for your next question. I want to say that Paz is part of the key work of Paz in supporting communities in community-led plans. We have been involved in lots of different ranges of plans. Some of them are focused on things such as active travel and some of them are broader. It takes a lot of effort to build that community understanding of what is possible, the system connecting them to people, and to get a lot of local authority support in that. They want to help communities, but it comes down to resources again. There is a need, as was said in previous evidence sessions, about joining things together. It is not just a planning thing. It is planning, housing, transport and environmental health—all of the parts of a local authority. The place-based approach that is in NPF4 needs to be seen by every part of the Scottish Government and local Government as being their responsibility to support delivery of. I take Claire's point about consultation fatigue, but when things start to happen on the ground, that makes a real difference. For example, we were involved in an apple cross community land use plan. They are starting to see things happen, including provision of sites for affordable housing. That gives the impetus for the community to continue to be involved. It is when something is simply a piece of paper that does not do anything that you will get frustration, lack of engagement and that falling off of trust. Thanks for that. I know all about the app. It is fantastic. Christina. Thank you. It was just to go back to the very first part of the question. I think that we would strongly support the strengthening of the regulatory role of planning and setting that capital investment programme and funding to achieve really well-informed decisions as the outcome that we are looking for to support a very thorough process. On the second aspect, there is great work happening, but we have to be very clear. The majority of the stuff that is built is making assumptions about how people want to live and how we want to use the space. The more inclusive we can make and empowering that community involvement can be, it is so important. That is about making sure that the communities are supported and that access to professionals and sufficient guidance is key to that. RIS members are very well placed to do that. A lot of members are already involved in that level of engagement, which is fantastic, but it is about making that mainstream. That helps with that fatigue that can occur if you go to a lot of meetings and you do not see a lot of progress, but the more inclusive that process can be.  I think that all of those things add up. It is about supporting at both ends. When we are looking at that capital investment programme, it is not just about the planning aspect but about taking it right down to grass roots. Thanks very much. I will move on and come back to Mark. He has another question to ask. In the interest of time, I will be a little bit more—I do not know what—a couple of people coming in on some of the questions, unless there is really something burning that we absolutely need to hear. Mark, back to you. Thanks, convener. We are talking about investment and implementation of the strategy of policies and housing targets. The document will be in place for 10 years, as opposed to normal practice, which has been a five-year national planning framework. How do you think that, in that context, implementation and delivery can best be monitored and reviewed over that decade-long plan? Anybody want to pick up that question about monitoring and reviewing? Robby and Christina. Thank you, convener. We will see how the monitoring programme forms, assuming that that will be published alongside the delivery plan. I know that there are provisions in the planning act to make amendments to the MPF4, but also in the local development plan regulations for the local development plan, if significant changes occur. There is room to review things such as housing numbers, if there is a big shot to the system going forward. However, it is always that balance between flexibility and certainty. Ensuring that you have a 10-year housing land supply, there are mechanisms in place throughout the plan in identifying short, medium and long-term housing land supply. The right checks and balances are in place for different scenarios going into the future. It was just to pull in that community aspect. In terms of that 10-year delivery, it is to ensure that those feedback loops are not necessarily financial, but they spread across life cycle assessments, post-occupancy evaluations and that understanding of space using different metrics to finance or housing numbers to make sure that it is a holistic approach. That feedback might need flexibility in the document, because some things might not be successful and they might not be rolling out in the way. If you are tied to something for a long term, it needs to have that flexibility. Again, what Robbie said, it is that balance of flexibility versus that long-term planning, but it is just to make sure that it spreads across a range of metrics. Before I ask my questions, I will refer everybody to my register of interests, I am still a Devon councillor at East Ayrshire Council. I would like to direct my first question to Robbie, if I could, because you are the first person who mentioned it this morning, although it has already been mentioned several times. Submissions have raised concerns about the wording of national planning policies. We think about things mentioned already about 20-minute neighbourhoods, community wealth building, carbon emissions and, indeed, human rights. I brought that up last week with the chief planner. I want to explore whether it is insufficiently clear for decision-making purposes. How can the wording be improved? We have already heard this morning that it could lead to appeals and a very interpretive-based system. Do you have any suggestions or concrete thinking about how that could be improved? I direct that to Robbie first, please. Thank you for the question. I am happy to look at community wealth building and human rights policies. In terms of community wealth buildings, that is quite a difficult one. In my past, I have been a development management planner. Again, as part of the statutory development plan, decisions will have to be made in accordance with the policies in that. When I first read it, I thought, if I get an application, how can I make a decision based on what is within the policy? I have to say that I struggled with the policy. It refers to having to ensure that applications are in accordance with the community wealth building objectives, but those objectives are not set out anywhere. I am digging around a little bit online in terms of literature that is out there. I did manage to find some principles behind community wealth building, but some of those were quite difficult in terms of how I could assess a planning application based on them, even though the intent is very laudable. For example, deciding an application based on the grounds of fair employment and just labour markets might be quite difficult. In our response, we said that this policy might need to be more about aligning local development planning with community wealth building strategies that local authorities are to produce. That would be a more effective way to line things up, as opposed to having development management planners based on that. Similarly, moving on to policy 4, which is the human rights one, might get complicated considering other legislative regimes. For example, the Human Rights Act 1998 and the Public Sector of Quality Act 1998. We have certainly asked for additional guidance on the matter to help to make lives easier for development management planners. That is great. Thank you very much for that, Robbie. My next question is going to be to Christina She's raised the issues already. It's exploring the tension that we've got between existing buildings and places, particularly the need to protect the historic built environment, whilst also allowing the adaptation necessary to reduce carbon emissions. Do you think that the draft NPF4 pays sufficient attention to the tension between the two competing issues? Christina, if you could come in on that, that would be great. Thank you for the question. It's a difficult one to answer because it's a difficult problem that we have. It's also about what does heritage mean. I think that often heritage and our listed stock get separated very distinctively from our existing buildings. The contribution that they have to our communities and to our carbon emissions going forward if they were to be demolished, for example. There is often a real split in approach to heritage and existing buildings. Of course, there are differences, but it's quite important that the quality aspects or the focus that is given to each category is slightly tangible in terms of our existing building stock could have huge value towards a community, for example, and heritage buildings contribute to that further. It's just about understanding how all existing buildings work, but that tension in terms of adaptation, the difficulty is that every building is different and how it needs to be approached is different. What a community feels about that building can be different. I think that nuance of almost a building-for-building approach becomes complex when you have a document like this that is trying to take overarching principles. I think that it comes down to that thread through the documentation on how everything is assessed and how those links provide or make a provision for buildings to be looked at on quite an individual basis, if required. There are a lot of documents that Ailsa mentioned, in terms of whether they were linked to MPF4 around heritage buildings, which would really help to support that aspect. I am happy to go into further detail on that, if you wish, but we will also be submitting a detailed submission later on, where we will go into all those nuances. I think that there are documents that could help to support that heritage side. Ailsa might want to come in and speak a little bit more about that as well. In terms of the tension for adaptation, I think that that exists across the existing building and heritage, but it is on a building-by-building basis generally, which is tricky. With regard to adaptation of existing buildings, it is absolutely key in terms of the standard that has been set in terms of net zero emissions. Existing buildings often and heritage cannot achieve that with a technology-based approach. It needs to be a fabric, so how do we address that? How do we take that forward? How do we just embrace that challenge? I think that it is quite the scary thing to do, but the difficulty is that with heritage it needs to be very carefully done on a building-by-building basis, which is a very different scale to what we are talking about on a policy scale with MPF4. That is the tension. The structure and the opportunity is there throughout the hierarchy to join those dots, as we have spoken about, with policies that already exist that can help to support or that may need to be slightly changed to help to support MPF4. Thanks very much for that, Christina. I can see that Ailsa and Claire would like to come in. I will take Ailsa first, and if you could add bits into it, because we are only halfway through our questions. That would be great. Thanks, Ailsa. Absolutely. Many thanks. I will be very brief. I would back up the fact that, as I have mentioned, our homes and our housing are part of essential infrastructure. If they are viewed that way from a policy perspective, the aspects for maintenance and a fabric first approach can be brought through that policy. Regarding heritage, most specifically, first would support appropriate adaptation. It is, on a case-by-case basis, quite often managing change guidance from Historic Environment Scotland. Again, when appropriately referenced, it absolutely helps to make sure that those changes can be appropriate, helping to meet net zero. My final point on that would be in policy 28, part D. We have made a suggestion that this policy appears to say and to put it quite colloquially, no and, and we would, in fact, like maybe the nuance of language to be around yes, but so it is a case of yes, you can appropriately adapt and change the historic environment and our existing buildings to help meet housing needs, local needs and community needs. There are appropriate considerations to be made, but it should absolutely be a case of those buildings are there to be used, they are a resource that we need to harness. Thanks very much for that. That is a really interesting point that you made there. I think that that is something that we need to take on board. Claire, if you have a thought on that before I move to my last question. I think that what I was going to say has been covered so I'll pass. Okay, that's great. Thank you. I'm actually just going to come back to you, because my last question, I want to direct it to yourself, Claire, and it is round about the minimum all-tenure housing land requirements as set out in the draft at NPF4, which is set out to try and support a consistent, simpler and transparent system planning for housing. I know that you have already submitted thoughts about that, and you have touched on it this morning. Do you think that there are any changes that need to achieve the aims of the simplicity, consistency and transparency of housing land requirements? Your thoughts on that would be great. Thanks. Yes, thank you for that question. We did cover Matlow quite a lot. Matlow being a minimum all-tenure housing land requirement. It's interesting, isn't it, when we're talking about communities and how so many communities have come to us about this housing issue and the amount of land being used for it, and yet the technicalities around it have been difficult to get our heads around, but we have. We've looked at how it's been calculated, which is a several-stage process that has been done with local authorities, and rightly so. The initial figures have been taken from the housing needs and demand assessment, so people need to look at that. The household projections are also estimated by the national records for Scotland, so people also need to be aware of that. The HNDA process is supposed to be factual, but it is clearly influenced by the data used and the subsequent policy and political aspirations that apply to it. The national records for Scotland population projections are very much reliant on previous past trends. The data is only used good as the latest situation, so we don't know about the Brexit and Covid updates, for example, on the population figures. We've got all that initial data, and then there's several uplift that occur. You have to find out about those uplift from the various annexes in the technical consultation on the housing. Those uplift that are given, whether local authorities have argued that they've got a greater housing need, perhaps because there's a homelessness issue, which is fair enough. Others, such as Aberdein City, have used a high migration scenario, so they're saying that they're expecting lots of people to move to Aberdein City, so they've asked for their projections to be increased. Any negative population projections have been asked to be zeroed. When people move out of one city, that's not been calculated, but it's always an upward lift on those figures. We don't know too much about the demand side of those calculations, whether or not they take into account the demand created by second-hand or short-term lets. It's complex, but it's perhaps not immediately obvious that all those figures are uplifts. On top of those uplifts, there's an added flexibility, a 25 per cent or 30 per cent flexibility allowance. We can't find any justification for why it's that amount. People at the Cairngorms national park ask for a 10 per cent flexibility. They want a less flexibility on the amount of land that they're using, because they said that the reasons for selecting a 10 per cent flexibility allowance are based on the fact that much of the land in the park is of European national importance for nature conservation, and most housing sites will have an impact on that. The demand for second-hand homes and short-term lets means that a lot of people in the park are not living in those houses that are being built. They wanted less land allocated for housing in this, but the uplift was still 30 per cent. I've just explained why, in our evidence, we've said about this massive contingency figure. It's quite astonishing contingency figure for the minimum, which is regarded as a minimum or 10-year housing land requirement. If there's one thing that we would like to see questioned, why is it so big? As far as we can see, it's just a panda to the needs of the private sector house building models, business models, which are allowing for their inbuilt inefficiencies. However, it's not going to help us to fulfil the legal requirements to set targets for the housing land requirements. Some of us can do that without adding this massive generosity on it. The only justification that we can see is the cow towns of pressure from the housing builders to allow them to be inefficient with their processes. One more thing. One of the real problems that we have with policy 9A is that it implies that the MATLA is the housing target. Local authorities are always going to be on the back foot and will face continued pressure to continually release more land as those targets are too big to fulfil straight away. That's going to be a little problem with planning appeals. We're going to see the situation much as we're seeing now, where developers will be appealing decisions because of the unmet targets. I can see that Robbie would like to come in on that. Robbie, if you can come in very briefly and just give us some thoughts, then I'm going to hand back to the convener. Thanks for that, Claire. Robbie, please. I'll be brief, even though it is a very complicated matter. We're broadly supportive of the approach that is taken by the Scottish Government for national targets. We hope that that moves the conversation on to more about methods of assessing the deliverability of sites and mechanisms to review housing land supply, but most importantly, on how we deliver quality development as well. One thing that I wanted to flag is, as Claire has discussed, local authorities have been revising targets in many circumstances and revising them upwards. That is a very resource-intensive process, and we believe that there is a big area that the Scottish Government's digital planning task force should address in terms of that collection as a matter of priority. Thanks very much for that, Robbie. It's really interesting because my own local authority revised their numbers upwards, and that was to do with Covid and migration that we're seeing. I think that all those things, the flexibility in that has got to be looked at. Thanks very much, Robbie. I'll hand back to the convener. Thanks, Ariane. Thanks very much, Eleanor. We have a few more questions from Paul. I think that we've got about 20 minutes. I think that we should manage, but yes, we can get to the point. I think that we'll do a great job. Paul, if you'd like to come in with your question. Thank you, convener. Good morning, panel. I refer every day to my register of interests, some seven councillor on diesel then council just now. A couple of questions for me. The first one is really just talking about resource implications. We heard this morning from a few people talking about resource implications for planning authorities. I think that, as colleagues have said, we were speaking to celebrate the moment yesterday. One of the things that Ken came through was additional resources also for also for local groups about how they can develop some ideas that they have, and it's supposed to bring about capacity building. I suppose that the first question, I'm probably coming back to, I'm probably coming back to yourself, Claire, first of all, talking a little bit about that and maybe Barbara after that. Just your thoughts on that, because I think that we can have the policies in NPF4 to try and help communities and groups, but if they don't have resources to implement these, we're kind of going nowhere. So I wonder what the views of the panel are on that, if you don't mind. I'm probably clear now, Barbara, and open it up after that. Yeah, well, bearing in mind, I've just gone on something rotten about the targets. Maybe I'll just keep it cool, but it's short, but yeah, very much resourcing for local groups without a doubt, but also I think it's about just listening and being willing and open to, you know, it is that culture change that I think that we need to have along with the resourcing, and as I said earlier, you know, putting in the structures that allow regular, you know, where's the databases? Who do you ask if you're talking to a community? You know, we need those sorts of structures in place as a society to, you know, enable a more deliberative democracy, if you like. Claire, thank you for that. Barbara, I don't know if you want to come in and just touch on that, obviously, with the work that you do. Yes, thank you. We've been involved with a lot of communities, urban and rural, right across Scotland, and the big thing here is time. It takes time to build that capacity to train local, even to train local authority staff sometimes to engage effectively with local people because it's not been part of their core work in the past. So there's a big upskilling required both amongst professionals and communities for them to engage effectively in their processes. However, that's not under play. If you live in a place, you know it well, you know what the problems are, you know what the good things are about it. Communities aren't stupid, so we don't need to patronise them, and I think they can decide for themselves. In fact, many have come to us in the past with very specific asks about what they need. Not every community will need their hand held to the same extent. Some are very able to often do their own things. So some of the support will end up being then at the local authority stage where they've developed a plan. That needs the support of everybody in the local authority—their councillors and the staff there—to adopt that plan, so that it's given that traction within the system. I think that, again, digital investment could support some of that in terms of showing others what's done. If you go on to the web looking for plans, google it, there will be a plethora of websites. I think that the Scottish Government could really help people to navigate the landscape, so can I look at a local place plan that somebody else has produced to see what they've done so that I can get an idea, and there will be lots of different varieties? I think that there are ways there that we can share good practice and give people the tools to develop their own places. Barbara, thanks for that. I know that Christina MacDonald wants to come in, but this one question is supposed to yourself. With the LDP process—I know that my own local authority is looking at the LDP process on the back of this—there's good community consultation on that from my own local authority. I don't know what your level of satisfaction is in terms of how other local authorities engage particularly in the LDP process, because that's incredibly important when the local authority is trying to look at that. Is that something that you think that's quite well looked at across Scotland, or is it mixed or balanced? I think that it really varies. There are very engaged communities who will influence the local development plan in their place. I think that that's particularly true in rural areas. It can be really hard for city-based authorities to engage communities who are maybe more transient. You've got a high student population, and you're not maybe getting the range in particular younger people being involved in local development plans. After all, we're planning for the next generation, and that can be really challenging. Local authorities try all sorts of innovative things. I know that people have gone to music festivals, supermarkets and all sorts of venues to try and engage people with it. It's really difficult, because, as I said before, this is an abstract concept. Until somebody puts a planning application in your backyard, it isn't real. I think that, again, that's educating people as to how important this is. I know that Christina MacDonald wants to come in and Claire MacDonald wants to come back in. Thank you for that opportunity. I think that, just to pick up on Barbara's comment, it's that there are those unheard voices in communities that are really key. Although consultation at the moment, it can be very good. It's not often as inclusive as it can be, and I think that there's an opportunity through this to reach those unheard voices and communities that maybe don't have skills within them necessarily or feel that they will benefit from this process, because it feels very removed to make it real for them and build that trust, which is another element that Barbara mentioned earlier on. It's easy, transparent, access to information is a big part of that. I know that The Hour Place website has just launched. I think that that's a good start with that initiative, but it's about that ownership of place. There are programmes that are happening across Scotland already that are embedding that trust and that belief in your community. It's putting them on a platform and showing that this is a shift in approach. I've never heard about the festivals idea, but trying various things. Those unheard voices and building that support around this ground up as well as policy down is just so important, so I just wanted to reinforce that. I think that that's the route that's vitally important. I'm going to move on to my question, if that's okay. Yes, I just very quickly wanted to say that it is a 10-year plan. If you're not engaged at the beginning of it, you kind of miss out for the next few years. The review of them is a really important thing. A word on things like schedule falls and development plan schemes. People were very confused. Why are all my views going into this package called a schedule 4? Who are the DPA? That's another organisation that I've got to engage with. Development plan scheme is a timetable. Why do we have to use all these complicated languages? It's just a small point, but it's crucial. Thank you, Clare. The next question is probably one to Robbie yourself. First of all, I'll open it up. We've had some concerns, obviously, at the best of the time skills for consulting on draft NPN4 and NPN4, and we've also got the Parliament and the Scottish Government running current consultations. I don't know if Robbie, if you've got any concerns about that and what implications that has on the stakeholders in the process, then I'll open it up after that, but probably yourself, Robbie, in the first instance. Yeah, it is particularly difficult time. I think that we're all struggling in terms of capacity. There's a number of parts of the planning act that are also being implemented. We've got open space strategies, we've got the developing and nature guidance, which has been consulted on as well. We have the consultation out on the draft local development plan regulations, as well as onshore wind policy statement and other committees. So there is a lot going on, and it is very difficult in terms of our capacity, and I'm sure many other stakeholders have capacity as well at the moment. Yeah, I'd agree with that statement. Okay. Robbie, just on that, I mean, is there a danger, then, while all these studies and consultations are going to get together, that there's almost no coherent strategy behind all that? You know what I mean? You know that you could get some policies' impacts on others. Is there a wee bit more, do you mean, to stand back a little bit and think, right, okay, what's getting done and at what time and how does it impact on other consultations, if you like? Does it impact on that, or is it just a resource issue? I mean, I think it's inevitable that you're going to have a little bit of this happen, and there's definitely something to do in terms of timing and synchronicity between different plans and strategies. You look at the infrastructure investment plan and when's that due for new, because that'll be a pretty important document in terms of setting out investment required for things in the draft national planning framework for. So, yeah, no, that is an issue. I'd certainly recommend that the committee put some space in its diary to scrutinise, for example, local development plan draft regulations, because they're a pretty crucial part of this puzzle. There's a lot that maybe would be in the NPF or Scottish planning policy, which has moved into the draft LTB regulations, so they need to be read alongside one another. So, I think, in that instance, it's important that they are consulted on simultaneously, but there's certainly a capacity issue there for us, and I'm sure many are the stakeholders. I appreciate that. I don't know if anybody else wants to come in on that one. I don't see anybody, and maybe we need to move on. You've got, okay, Claire. Putting our written response to you about the simultaneous parliamentary scrutiny and the public consultation process that finishes on 31 March. I don't know how you are feeling. I mean, it's your scrutiny process, but we just feel that that's, you know, you're scrutinising a draft document rather than the finished one, and if it had been NPS 3, you would have been doing it on the final document. So, we've just raised a concern about that and, you know, how you're going to take in to account the public's comments on the draft. Claire, thank you for that. I think that that's me. I'll pass you back for the last question on this panel. Thank you very much, Paul. I'm now going to move over to Willie Coffey with your questions. Thanks very much, Arianne, and good morning again to the panel. I wanted to start on the issue about resourcing that was mentioned a couple of times, and I'll pick in Robbie, as you mentioned it a few times yourself. Robbie, we visited Comarnock online yesterday, and we heard from local officials and colleagues in the Celebrate Comarnock team who have already been doing some great work down there, creating new public spaces for the communities to enjoy and so on. Much of those achievements are contained within NPS 4 at the moment, and that's without NPS 4 being finalised, obviously. They achieved that through funding, town centre regeneration funding, for example, and some common good money. It was just to make the point that we don't always need to have, beside a document like NPS 4, a huge great big capital investment programme, that some of those matters can be achieved and demonstrated in Comarnock through other means. I was just to get your view on that and whether you recognise that there are other means at local authorities and communities that are disposal to reach out and to deliver some of those achievements. Robbie? That's me off me. I absolutely agree with that, Willie. I think that there's lots of great work that's already been undertaken and has been for many years now. I think that this goes back to the point that I was making about complementarity. In our submission, we were trying to make sure that clear links were made to existing funding packages that are out there, such as city region deals, town centre transformation plans. The national economic transformation strategy will be a particularly important document, so I want to see how that is clearly aligned with the draft NPS 4. Planners can very much sit as the regulatory catalyst for various funding streams and pull them together to intervene in a place-based sense. It's also good to see the inclusion of the place principle. Others said that earlier, but I think that that will be critical to improving places. Planning is important, but many other parts of local authorities have a part to play as well. We've said about the place principle as though we think that that needs to be something that is transparent in how it affects the decision-making process and one that can be enforced. You can imagine something along the lines of the town centre first principle, but it's an enforceable method of decision-making in local government to secure that place-based approach to directing investment. Thank you for that, Robbie. Another issue that came up yesterday in the discussion was that we heard about the difficulties that towns like Kilmarnock and just about any town in Scotland have in dealing with empty derelict shops and buildings and abandoned pieces of land within the urban setting. I might direct that question to Barbara, if I can, but many of those buildings and shops are in private ownership, Barbara. My constituent said to me, why should public money be spent on rescuing a lot of those properties that are deliberately being left in a near abandoned and ruined state that blight our town centres? If we're serious about the NPF4 allowing us to turn this aspect round, there needs to also be a role for the private sector in making a contribution to the whole strategy. Is that something that you recognise and would you agree with? Absolutely. There's a little bit of carrot and stick required here. If it's all stick, then that's no good either. There's always a call for enforcement and notices and things like that, but that just gets people's backs up. I've seen through previous work that engaging with the community and that's the business community as well. We sometimes forget about that and we focus on residents, but engaging the business community on the influence that they can have on their place. When you start to see things happening, for example, in my previous job we provided support to Campbelltown for a town centre scheme. There were grants given to people to do up buildings, and obviously those were the willing few. But when others started to see what was happening and how it was improving, it was improving their footfall, it was improving their look, they started to do it too. I think that there is that carrot element as well. If we can start to make some things happen on the ground and we can see a ground swell, then you will encourage people to view what they've got as an asset, not a liability. That's absolutely critical, because generally, if it's just about their election, then it's all negative. We've got to turn that into a positive and make our town centres more flexible and allow people to do things with them. How do we reach out to the private sector to get them on board with a plan? I don't imagine that they're sitting at the moment reading the NPF for no. How do we get them around the table and make a contribution? How best can we do that? There are lots of forums where businesses are involved with their towns. This is one of the things about a more team Scotland approach to planning. Planning isn't just what planners do, it all happens in a place. It's engaging business community organisations as well and encouraging. This is one of the things that's fantastic about the parliamentary scrutiny process. This is a Scotland-wide document and it's for everybody to contribute to its implementation. I think that message needs to get out, that this is not just about engaging residents who don't want to see housing developments, it's about engaging all sectors of Scotland's community to make our places better. I have a third issue that came up. I will probably try Christina Arreosa on this one. In developing the local plans, we heard from East Ayrshire's officials yesterday about the difficulties that they face in re-using some of the brownfield sites that are again within the urban setting, probably close to rivers. Consequent objections that we get from SIPA and others about that kind of development and the flint risk issue. I think that it's Christina Arreosa that gave us some statistics earlier about 85 per cent of the buildings. We'll still be there in 2045. I'm prepared to bet that 100 per cent of Scotland's towns and villages will still be beside the rivers in 2045. How on earth do we tackle this? Do we just continue to reject town centre developments that could really help to achieve the aims that are set out in MPF4 because of the flint risk issue, or is there a better way that we can try to tackle this in the medium short term? Thank you very much. One of the things that is obvious about how we incentivise the re-useful places is very much about the embodied energy within them and the fact that those sites can very much have a carbon benefit rather than what can sometimes be described as a heritage deficit. Points mentioned earlier about highlighting the need for maintenance and that being part of a longer term strategy for our places and that being built in from the beginning of the process onwards. Obviously the policies coming into place around vacant and derelict land will help, policies around densification again also help. Points that have been raised by best members have also included that the changes that can happen within town centres that currently there are concerns around a lack of immunity space in the transition between perhaps some areas becoming housing. Those are policies where housing exists already. There is often potentially a lack of immunity space but that transition and densification could more usefully be supported through policy. Also within part M of policy 28 there is intent around using the buildings at risk register to help inform and guide decision making again to help the reuse of buildings. There are some concerns that you want to be able to focus on a range of buildings, not just the buildings at risk. It is good to see it mentioned but the intent of that policy perhaps could be broader. I understand the concerns from SEPA but I will say that that is not an area where we have had particular comment from members so I would not want to take away from SEPA's specialist knowledge but I will say that ensuring that balance between useful flood plains might be putting the densification elsewhere and incentivising that use of brownfield land where possible is absolutely essential to our places. Just lastly, since I named checked you, Christina, what can we possibly do about that? We cannot leave our town centres, the brownfield sites in particular, that might be due for rivers. We cannot just leave them because we think they might flood from now on. We have to do something more about it. What can you suggest that we could do to tackle that? I think that it is a really interesting problem and part of the RIS strategy for COP26 was looking at flooding inland as well as coastal so I feel like maybe you saw that. It is about understanding the sites. It is definitely prioritising the protection of existing green space views, daylight, amenity opportunities, encouraging net gain principles, avoiding offsetting in that response, which means that the value changes in the brownfield sites because that is where development is well placed. However, as you say, there are many issues with that. Sometimes it is not just super-influiting other things but it is about understanding the sites before they move forward. It is about working with SEPA. It is about a different design approach. We are talking about MPF4 as a shift. Design architecture is shifting as well. We have to learn to adapt to deal with those sites to maximise the capacity and also to free up that amenity and that protection of green space. They go hand in hand, but it is a challenge for the whole industry and it is setting those targets to make sure that that is what we are focusing on, that is what we are working towards, that is where the changes are happening. There is a huge amount of expertise in SEPA and other organisations that are looking at those sites, but that is a design challenge. That is what architects love. I am coming at this from a different perspective a little bit. That is a challenge that we have to address and face, but it is not just for one person to solve. It is that teamwork aspect in terms of how we have to use this opportunity and how we do it. We would be happy to be involved in those discussions, but it is definitely one of those challenges that we have to overcome. I want to pick up on your previous point very quickly. There is the opportunity for—let me get my terminology right here—to bring together public and private sector. Is the Scottish Council for Development and Industry to make sure that there is a bridge between residential and private ownership in businesses? I want to pick up on your last point. Thanks very much for that, Christina. That is very helpful. Thank you all. Back to you, convener. Thank you very much, Willie. That concludes all of our questions. We have done a very good job covering a lot of good ground. You have all brought very important comments and responses to what we have been asking. I think that it has been a very helpful morning. I want to say thanks for joining us and giving up your time today. I will now suspend the meeting to allow for a change of witnesses. Welcome back. We are going to continue taking evidence as part of our budget—part of the scrutiny of the MPF4. I would like to welcome our second panel this morning, Dr Caroline Brown, who is a lecturer in environmental planning and healthy environments at Heriot-Watt University, Professor Cliff Hague, who is an emeritus professor of planning and spatial development, and also at Heriot-Watt University. He is also the chair of the Coburn Association. I would also like to welcome Professor Lee Sparks, who is the Deputy Principal and Professor of Retail Studies at the Institute for Retail Studies at the University of Stirling. Thank you so much for joining us today. We have already had a very rich session with the previous panel. I am looking forward to what we hear from you. We are going to move straight to questions. What we tend to do is try to direct our questions to one person initially, but if you want to come in on something, please put an R in the chat box. If we start to run out of time, you might be asked to come very quickly to a point so that we make sure that all the questions get answered. I will kick off with the first question, and I would like to direct that to Dr Caroline Brown first. Caroline, the draft MPF4 represents a significant shift in planning policy with a new focus on issues of place, livability, wellbeing and emissions reduction. I would like to hear if you think that the Scottish planning system will be able to deliver those ambitious outcomes. As before, I think that it is a really interesting question to begin with. The shift in focus is really significant, and that will create a challenge. It will create a challenge for the planners working within the system, but also for others that work in development—house builders, developers, architects and things—to understand and interpret the policies and the principles behind them. We have already heard from others about clarity about language and definitions. From my perspective, there are certainly some elements of the MPF4 while welcome that need to be fleshed out in order to provide clarity. The reason that is important is because in a discretionary system where planning officers, developers and others are talking about what should and shouldn't happen in the future, any doubt or terminology that is not crystal clear allows developers, particularly in a system that is struggling for resources, to push against the requirements and to diminish what they deliver. There are many developers who are very ambitious about what they are doing and want to go further than policy and are ahead in some ways of some of those ideas, but there are also many that are well behind them. We have to bring the unwilling along with us. Clarifying those terms is really important to help planners to live at this on the ground. In a system that is currently under-resourced, it is really important because the time for those conversations is limited. With more planners, it is easier, but with fewer planners, it is really hard to make those things stick with developers when you are saying that biodiversity is important, climate is important, health and wellbeing are important, your scheme at the moment does not deliver on those things. We need more and more of that. However, if we have clarity about what we are expecting, it makes it much easier to deliver for everyone. Thank you for that. That was very clear. Thank you so much for that. I would like to bring in Cliff on the same question. I agree with what Karen Gray is saying and with what was said in the earlier session this morning. The only point that I think I would add is that the less the clarity in a system, the more that favours those with deep pockets. It is not just a matter of clarity for clarity's sake. There is an equity issue here. The presentation from Clare in the earlier session about the housing need and demand analysis shows that the more complex it gets, the more impossible it is for any kind of grass-root involvement to be meaningful. Clarity and simplicity are desirable. There would also go some way to freeing up some of the existing human resources that are in the planning system. The complexity and the focus on development management tends to mean that staff are very, very pressed and accept that perfectly. However, if we could make the system simpler and clearer with less recourse to the special pleadings and particularly planning appeals, we could use that existing resource more effectively. Having said that, I think that to engage with the issues that have come forward, particularly the issue of circular economy and the issue of community wealth building, there also needs to be an investment in skills development in those areas to make the system effective in dealing with them. Robbie's comments earlier on where he basically said that he did not really know much about community wealth building were quite indicative of that. It is not a criticism of Robbie, but he is probably reflecting quite a widely held view. However, there is a literature out there. There are practice examples, and some things become very simple. Going back to the housing flexibility issue, that is clearly undermining a notion of community wealth building. It is taking wealth out of the community by adding to the value of land, which is increasingly through developers and people who fund developers, going into the pockets of investment trusts and hedge funds. Far from benefiting the local economy and recycling the material within that economy, it is actually extractive. I could say a lot more, but I am sure that other people want to come in. Thank you very much for that. That was really insightful. You just put in a few bits of the jigsaw puzzle for me of things that I was not wondering about. You talk about planning departments being pressed and some of it is to do with the recourse for appeals. Why do we have this appeal system? The developers can put through planning applications, the guests refuse, and then they can take it to appeal. That stretches a planning department if they are constantly having to do that. I used to give one-hour lectures, so I will try and contain myself. It goes back to the way that the 1947 system was set up and the lobbying of landowners at that stage. Essentially, if you look internationally, not all systems have—many systems have some right of a dysbodriad applicant to appeal, but not that many of them have the kind of extensive system that the UK has. For example, much of Scandinavia, the appeal will go back to the local planning authority, rather than to the much more quasi-legal process and centralised decisions. Basically, it reflects a balance of interest within the system. Of course, there was extensive discussion about that when the 2019 act was being taken through Parliament. The decision basically of the Parliament was to retain that sort of system. Thank you for that, and thanks for keeping it brief. I was digressing a little bit, but I think that it touches in on the point that I keep hearing that planning departments are stretched and it is looking for where are the opportunities to put some ease into the system. I will move on. I would like to bring in Mark Griffin, who has a question for the panel. I ask members of the panel whether they think that the policy priorities set out in the draft plan align with other Government strategies and investment priorities. Do you think that the draft plan would benefit from having its own capital investment programme to make sure that we see some of those ambitions delivered? Perhaps I will bring in Lee, if he wants to come in since he has not the chance to contribute so far. Thank you. I am not sure that I am the best person to address that. I can take the alignment point, first of all. In terms of alignment, there is alignment there, but I think that it could be clarified rather more than it is at the moment. I also think that it is important that other policies that are emerging take the right alignment with MPF4, as it develops. There is more work to be done in Government around that, on the capital elements around that. From the bits that I know about it, I think that there are funds available and there will be more fund, a place-based investment programme. I am not sure that I would add anything in terms of additional funds. I think that complicating the landscape with lots of little funds does not necessarily help us that much. I agree with many of the things that Robbie Calvert said earlier about that. It is really important that there is some clarity about how the Scottish Government intends to implement that and where necessary, particularly on the national projects that are outlined in draft MPF4, there is some clarity about where the resources are going to come from. I note that MPF4 talks about an infrastructure levy, and I think that this is an important potential component. If there is an infrastructure levy going forward, that is the sort of thing that may be used to help deliver an infrastructure-first approach. My understanding of infrastructure first does not necessarily align with what is in the draft plan as it stands, which is about understanding infrastructure needs before you do things, rather than delivering infrastructure before you do things. I think that that is important. It was something that jumped out when I read the draft. Infrastructure first, I am definitely up for that, but I am not sure that the way that it is written is quite how I would put it. In order to deliver infrastructure first, we need to have some capital funds to do that. We need to define what we mean by infrastructure because that does not define it. Are we talking only about roads, which is what most people think of first, or are we also talking about schools and healthcare, but also about the assets in a community that make it a healthy place to live, which could also be described as infrastructure? I think that it is really important that there is money, that there is a plan to deliver this, and if necessary, to bring funds together. I will stop. There is much more that we could talk about on transport, for example, but let us not go there. Thanks, Caroline. I am going to bring in Cliff. Really important question, Mr Griffin. Everybody talks about integration. All we researchers always say what you need to do for effective policy making is to integrate so that one ministry does not undermine the policies of another ministry. In practice, it is very difficult on the ground. What is really going to be necessary is very close working with across Scottish Government areas. The planning and health dimensions need to be pulled together. It would certainly help if there are budget lines attached to elements of the plan. In terms of infrastructure, I echo one of the things that was said earlier this morning, which is that most of the infrastructure for 2045 is already there. A lot of that maintenance money will come out of private pockets. What we need is ways of influencing that. In terms of other areas where we need to connect, the word homelessness does not currently feature in MPF4 draft. Scottish Government has important policies on homelessness. I cannot see how one can talk about human rights, which includes the right to adequate housing, and have a housing section without having some mention of connection into homelessness policies. There is a range of things that need to be done. There is an important message for politicians and for officers about embedding the aspirations in MPF4 widely across the full range of Scottish Government services. I move on from funding to implementation and monitoring. As we move from a five-year plan framework to a 10-year plan framework on the importance of monitoring and reviewing implementation of the strategy policy and housing targets, how best we do that and the importance of it as we move to a 10-year long plan. I am old enough to remember the days when there were research and intelligence teams in planning departments in local government. Information collection research is really important. Local government is the closest to the action in those things, so it needs to revive that kind of capacity. In terms of monitoring, the big question is what are your priorities, and you then focus your monitoring primarily on those priorities. What we tended to do for quite a long time in Scottish planning is have a focus on, if you like, consumer satisfaction surveys, whereas what we begin to need to see here is how the MPF4 begins to impact upon the circular economy and the issues around, as I said earlier, the climate emergency and so on. Pick out the priorities, get key indicators and share the monitoring process with local government. I see that Caroline and Lee would like to come in on the question, Mark. Oh, it's me. Thank you. Yes, definitely we need implementation and monitoring to be going on. It has been something that has been dretched within planning as a discipline, as a profession within local government, central government, because of resourcing issues. I completely support what others have said here, and measuring the outcomes planning, not being very good at reflecting on how well it's performed in the past. I was wondering to myself yesterday if there was a published evaluation of MPF3 that was available, and I couldn't find one. I don't know if there has been anything like that, which has fed into the preparation of this draft. Forgive me if I missed it, but I think that those questions are really important. I don't want to suggest that we should invent a new system for doing this or add burdensome requirements for reporting, but it is really fundamental to knowing whether what we're trying to do is happening and whether the policies that are in place are delivering for us. I absolutely agree with what's just been said by Cliffan Caroline, but there are two other points to develop slightly. I think that we need to understand, particularly if we are going into some of the areas that are new for us in terms of MPF4, what we actually want to measure and how we measure those, because I don't think that we have the right measures at the moment, and I think that the way that we've done it previously, the way that we do it in town, for example, at the moment, is not suitable for the way that we need to think about what we're trying to build in terms of places. Secondly, I'd make a bit of a plea that we have some comparability and consistency about how we measure things, and we don't leave it to 20 or 30 different ways of measuring the same thing across different places. That is really quite important to understanding how we're making progress. Okay, thanks. I'll be back to you. Thanks, Mark. We're now going to move on to questions from Eleanor Wittam. Thanks very much, convener, and I would like to direct my first question to Professor Hague, if I can. 20-minute neighbourhoods have mentioned about 34 times in the draft in MPF4. Indeed, it's something that's on everybody's lips, it seems nowadays, and when I was part of the social renewal advisory board, it was something that was spoken a lot about from lots of different people in lots of different policy areas. What do you think it's going to take to turn this from a policy priority into reality? Action on the ground. We need to recognise again that 20-minute neighbourhood doesn't just apply to new development. We need to look at 20-minute neighbourhoods. In the context of many of our neighbourhoods, we've seen a diminution of public and private services over the past 10, 20 years. That becomes quite critical. It's not just a case of doing a nice design for a new-edge city development but of tackling the legacy that we've got. On the one hand, as people said earlier this morning, it's crucial in terms of embodied carbon and ensuring that everybody lives in a healthy and attractive environment, but it then needs action on those existing facilities. The youth clubs that have been lost and the shops that have been lost cannot say much more about that than I would. We need to recognise the enforcers' transport connectivity between neighbourhoods. We need evidence of where the places where accessibility is actually poor, even if they're within Edinburgh, Glasgow and Aberdeen, and even within the big cities. There are some neighbourhoods that are relatively poorly served by basic public transport. We need to back the idea that they can link into local place plans. You could see a way that that generated the enthusiasm and commitment of people at a local level to taking greater control of their local neighbourhood, but it needs a clarity of framework and resourcing at a local level. Going back to what I said earlier, could we shift some of the capacity in planning departments towards working on regenerating existing neighbourhoods, rather than dealing with applications for new developments beyond the edge of the city against the development plan, which will basically drain on resources of all concern? I would like to take you back to the whole concept of community wealth building, which you have already touched on this morning. How do you see that fitting in with the 20-minute neighbourhoods and keeping that wealth local? I think that what we have seen in a number of neighbourhoods that I should show you familiar with is that there has been this combination of disinvestment from the public sector and from the private sector. You have got to somehow begin to turn that around. That is where there has to be connections with the Scottish Land Commission work, which is surprisingly underrepresented in MPF4, as it stands. You have to find ways that you can, using that and the community engagement act, begin to find different ways whether it be social enterprises, start-ups, take advantage of the cheapness and availability, potentially, of empty property. To generate a level of reinvestment at a local level, it will be different in different areas. There are lots of challenges. You need souls on fire to drive it at a local level. Probably people who have a passionate view, but then you have to back those people with start-up money, pump-priming investment, which will help to pull things together. A local place plan that had a 20-minute neighbourhood focus was tied in to the other streams of involving and generating social enterprises, local start-ups, cultural events or whatever. It would say that it would depend on a particular place, but there is a mindset here that says that we are really serious about the transformation. Thank you very much for that. Dr Brown, if you would like to come in and add a couple of thoughts to that, I can see that you want to do from that. No, 20-minute neighbourhoods is really fascinating. There is a significant danger that it could turn into something that becomes very commercial, so that people feel that if they do not have a costa or a Starbucks coffee shop within a five-minute walk, 20-minute neighbourhoods have failed. As Cliff has just said, it needs to be much more rounded, the idea of 20-minute neighbourhoods, so that we are clear that it is not just about commercial retail opportunity having a coffee shop nearby, it is also about the other sorts of community uses and social enterprises. Circular economy to give one, so it is things like having a repair shop nearby, having a tailor or a cobbler, those sorts of things that were very traditional in a 21st century form, but getting those sorts of things into our neighbourhoods would be a way of making 20-minute neighbourhoods happen. I want to just come back to the point that we were just talking about implementation and monitoring. Next-use development is a long-standing approach within planning, and we have many policies that have attempted to deliver that over the last two or three decades. However, there are many examples of how that fails. I am speaking in Edinburgh, and there are many examples of housing-led development, which has retail units within it to meet the requirements of the policy. However, those units remain empty for years in some cases, and sometimes what happens is that they eventually become housing because no business has been found to take up the opportunity. There is also something about linking up business support, community enterprises, social enterprises and the animation of those opportunities. The plan is very easy to write a policy that says that we want mixed-use developments and we want to provide retail opportunities and other things in neighbourhoods, new and old. However, if we cannot get people to bring businesses or create businesses to occupy those spaces, we fail, and that is the big danger. We need to reflect on how well some of those policies have worked in the past and how we might change that so that they become hubs for local businesses and enterprises, whether those are socially led or commercially led. That is really great. Dr Brown, thank you. It is a really good segue into the question that I have for Professor Sparks, who wants to come in. It is all about the fact that there is a huge driver behind the draft MP4 about living locally. Just with your expertise around retail, Professor Sparks, I want you to maybe give us an idea of whether you think that, as it is set out, it is going to drive that investment in planning locally, or do you still feel as if we are going to end up with out-of-town retail, as opposed to in-town retail? Your thoughts on that, Professor Sparks, thank you. I will try not to do the clips one hour later at this point. As it stands, where would I say that there are many good things in the draft MPF and very supportive of the new fruit? Where am I more worried about it? I am worried about it in terms of the ways that it was back to the early discussion, where I think that there are holes and where people will push back in many ways. There is an awful lot of should, and I would be wanting it to be rather more focused and directive. There are words like additional. In the town centre first assessment, it talks about no significant adverse effect. I can see us having an entertaining discussion about the word significant. If we are serious about towns and serious about the state of towns and bringing things into 20-bit neighbourhoods, I think that we need to be much more focused on saying that out-of-town development does not exist any more. We have to reverse it in many ways, and that was the thrust of what we tried to say over a period of time in the new fruit just about months down. I am pleased that the way that it is going I would make a plea for it to be strengthened, otherwise I think that there will be things and people will continue to try and do things. One of the other panellists said earlier about there are those that are on board in terms of where this is going and it is that latter part that I really worry about. That they are still focusing on what is a model that, in all intents and purposes, has been damaging our town centres and damaging our places. I think that I would try and get MPF4 to push rather more strongly to say that we really have to stop this, and it should stop it, and we must stop it. Thanks very much, Professor Smarks, for your thoughts there. My final question is actually going to be to Dr Brown. It is round about the policies that are laid out in the draft for MPF4. Do you think that they are going to produce an environment that meets the needs of groups, including children, women, older and disabled people? If not, what changes would you like to see made? That is for Dr Brown. Thanks. Yes, another one-hour lecture coming up. I think that there are many promising things in the draft for MPF. I think that one of the things that is missing is any mention of those specific groups and their needs. Clearly, it is really hard to summarise.  I think that it is important to mention some critical issues that affect those groups in which they are currently disadvantaged. For example, if we talk about active travel and cycling, we know that more men cycle than women. Why is that to do with infrastructure? If we have that as a starting point, it helps us to see what sort of policies we need to put into effect and what sort of designs will help us to reduce that inequality. I think that it is the same for children. The place efficiency duty is an amazing step forward. Obviously, that sits alongside this. We have a good precedent from Wales to look at, and that will really help. However, I just think that giving planners, professionals some point us about how those groups are disadvantaged and the inequalities that they currently face can help us to work out what we have to do. We do not mention those groups explicitly in here. We talk about equalities, but if we do not know what the inequalities are, we cannot fix them. We need to say what those inequalities are. I could go on, but I think that I should leave it for you. That is very helpful. Thank you, Dr Brown. It echoes a lot of my own feelings on the issue. I am going to hand back to the convener now. Thanks, Arianne. Thanks, Elena. We are now going to move to questions from Paul McClellan. Thank you, convener. I think that we have kind of touched on this before, and that this is probably to prevent Professor Hague. It is really around the policies in the draft NPF4M to protect our bill heritage, but it is about reaching the right bands between preservation and allowing essential action to reduce carbon emissions. I am just wondering what changes you would like to see made in that regard. I think that I would like to see the historic environment that connected up much more strongly with the overall strategy, not the sort of appendage added on, pretty late on, but recognising the multiple benefits of historical buildings, but also our landscapes and our land. That connects to a circular economy. A circular economy idea is that you do not use up finite resources, and land is a finite resource, buildings are finite resources. We need to see the conservation of the historic environment as part of a much wider conservation focus. If we switch the focus of NPF4 away from how we deal with the increment of development that is going to come between now and 2045, and focussed, as I think the one from RIAS was saying earlier this morning, on the 85 per cent of development that is still going to be there from now, that would be more effective. We need the explicit connections to historic environment policy statements, but we also need to shift around in the focus to put the historic environment and the existing environment. We are all in a sense of living in a historic environment. It may only be a 10-year-old historic environment, but it is a historic environment nonetheless. What we do with those places is how we manage them, how we care for them, the assets and the wellbeing that they provide to people of all walks of life across Scotland is really critical. That is really where we need to see the focus of effort, I think, looking forward. Thank you. You will know obviously what your co-burn association had on, as well as how relevant that is in Edinburgh and lots of buildings going forward. Can I ask the same question to Dr Brown again, your thoughts, and come on to Professor Sparks after that as well? Again, I think that part of the issue is Professor Sparks, and that is obviously if we are looking to develop our town centres and so on, and that may be in old historic buildings. I will ask Dr Brown to come in first and if Professor Sparks wants to comment after that. Dr Brown. That is where it gets tricky, isn't it? I noticed in, and I cannot put my finger right just at the moment, but there is one place where it is talking about, it is on green energy, I think, in talking about balancing proposals for solar arrays against historic environment things. This is where it gets hard, and I live in a conservation area in a lovely villa. If I wanted to put solar panels on my house, which thing is most important? This is why some of the panellists earlier were talking about we need to have some clarity about overarching goals. My view as an environmental planner is that, in many cases, we should put the environmental climate one first over the historic environment one, because I recognise Cliff's elegant point about the circular economy and using finite resources responsibly. However, I think that this question is a really important one, and it is something to be, there is a lot of nuance here about how we reconcile some of these policy objectives. We should recognise that some of the things that we do with our historic environment are necessary in order to meet our objectives for 2030 and 2045 carbon reduction. We have to grapple with some of this detail, and it is gritty and difficult, but that is the task ahead of us. I am afraid to do that. I think that you are right. You have talked about overarching strategies. Where does that come in to NPF4? How is that interpreted? There is that degree of flexibility in interpretation. I think that each local authority might look at it differently. That is one for the committee to grapple. Professor Spars, I do not know if you want to come in on that one as well. In terms of obviously economic development in some of the cities, there may be all the buildings that we need to upgrade, for example, but we have got the impact of possibly essential action to reduce carbon emissions, which might make the building not viable and so on. What are your thoughts on that? A couple of things, if I may. First, I think that that does vary by place, and each place is an individual place. That localness is quite important, because it is the localness and distinctiveness that those historic buildings give that may make that place distinctive. I know that the history part, in one sense, is in that distinctive place, in NPF4, and it could be in other places, as I said. However, there is that feeling that the identity of a place is about what it looks like and what it feels like. Therefore, destroying that for whatever reasons is not necessarily a good thing. If we are thinking about things that are livable and that places are attractive, we need to have that element of the historic environment within it, is it difficult to do things in historic buildings that are more difficult than just being on greenfield sites and elsewhere? Yes, it absolutely is. Is it more expensive to do it? Yes, I think that we could alter that by thinking about how we changed some of the taxation systems and how we think around aspects of that. However, we need to try and grapple with that. We have got those places, we have got those buildings, we have got those centres that people do identify with and they are underused, and we should not be wasting them, so we need to find a way of actually making sure that we use them better than we have at the moment. However, I appreciate the difficulty, and it is easier to say that it is more difficult to do. I suppose that the supplementary guidance is a need for clear supplementary guidance from planning authority in that regard, if from each local planning authority on top of NPF4. It is delivering NPF4, but what do we need beyond that? I do not know whether Professor Haig or Dr Brown will say that. Do we need clear supplementary guidance for each? I am thinking that, Professor Haig, I am thinking that the built environment is there sufficient there just now, or do we need clear supplementary guidance behind that? I think that generally supplementary guidance would help, but I just wanted to make another slightly related point, which I think that Lee Sparks would probably also echo. Historic buildings can be particularly significant in smaller towns. I think that we have not really discussed the overall spatial strategy very much, but the closure of one significant, whether it be a church, a district court, a bank or whatever, those tend to be imposing buildings in the city centre that give distinctiveness to the place. I think that it really is very important that we recognise that unless we can make an impact on the reuse of those buildings, it actually has a detrimental effect upon the vibrancy of the small town itself. Small towns are a really significant part of the Scottish urban landscape, so I see that Lee is jumping in on that, so I will happily paddle over to him. Thank you, Professor Hickinsley. Exactly that. Clifford Macdonald makes a very good point. Those buildings are distinct if we have distinctive urban forms in Scotland. If you take out some of those major buildings, those major historic artefacts, that loses that identity of the place, and that is why those buildings become more important in the smaller towns, because they are so significant. We built that up over a long period of time, and we lose it at our real costs, so that is small town points are really valuable. I want to move to another area, which is about housing. It is the policy approach to housing taken in the draft MPF4, including the minimum housing all-tenure land requirement. Will this result in the homes that people need being built where there is demand? Dr Brown will come to you first, and I will open up after that if anyone of you wants to talk about that. I am not a housing expert, and I have many colleagues who are experts in housing. However, I am a planner and I have a view. There are some useful things in here, but I find it astonishing that the management of short-term lets is not addressed at the strategic level. Short-term lets have, in effect, taken many homes out of the housing market and put them into the tourism market. If there was a development for a hotel, we would require it to have planning consent, and instead short-term lets are allowed to happen without any coherent national level regulation, which I find extraordinary. I find extraordinary that it is not mentioned here the significant impact of short-term lets in many housing market areas at local level, including Edinburgh, but many of our rural communities suffer as a consequence of that. I do not want to take up time, because I am sure that Lee and Cliff will have other things to say, but I find that a particularly extraordinary missing component to the draft, as it stands. Thank you, Dr Van. You will know that we have been discussing this topic in committee the last number of weeks. Obviously, there are measures that local authorities can take. Professor Hayes, I do not know if any of you want to come in and comment on that. I echo Carly's comments. I think that we have lost literally thousands of flats that were broadly speaking provided an affordable accommodation in Edinburgh, particularly in the city centre, which has impacts on the character of the city centre itself, as a living centre, but also in other parts of the city. We do all this juggling with housing demand numbers and the impact of the loss of housing to commercial renting that has been unregulated. I know that that moves in other areas of Scottish Government to address that. I think that there is a bit of a sort of naivety or inconsistency in the housing section. There is endorsement, for example, of built-to-rents as a kind of innovative form that is a good thing and we are going to back it. A very interesting article in The Observer on Sunday, which says that hedge funds across the world are piling in to built-to-rents. It is low risk, it is high returns and it is a long-term guaranteed thing. You could not have designed it better if you wanted to take money out of a local economy and relocate it to a tax haven—it is ideal. We really need to get to grips with those kind of issues. We think particularly of the housing policy section. It is a section of all the MPF4 that shows most continuity with the past policy and least willingness to grapple with the notion that there is a climate emergency and that we are trying to regenerate places and to reinvest the assets of an area to community benefit rather than see them drain away. Professor Sparks will bring in. The question for me is probably a little bit more detail about town centre first planning. I know that the travel section is certainly from guidance from yourself in terms of making high streets and main streets mixed use in terms of people actually living on high streets and so on. Many people want to do that. Again, just coming back to that question, but with your town centre hat on, if you like, what your views are on that. That is very interesting. Clifff's last final sentence there. My notes in terms of draft MPF4 about housing, I just wrote, I am really not sure what it actually was delivering. Certainly, if we think about what we have to do in terms of the elements that you mentioned, Paul, then we—twenty minute neighbourhoods, gentle densification around town centre, milling that community around it, builds that core, builds the high street, builds all the assets in that town centre. We need to pull that together. When I read the sections on housing, I really did not get that sense. I am not a housing expert, so you have to take that in mind. However, I really did not get the sense that it was really aligned with what we have been talking about in the other policy directions. That also ties into some of the ownership aspects around community wealth building, as others have just said. That is where I was probably disappointed in terms of town centres and the link. I would echo what your comments are about the housing side of it. It needs a bit more work on it and a bit more sense of how we actually break what we know is a problem and use the assets that we have. Paul, you are very good to hear your perspectives on it. We are asking everybody about Matlur and trying to get our heads around it. I would like to move on to questions from Miles Briggs. Thank you, convener. Good morning to the second panel. Professor Sparks touched upon that, but I wanted to ask a question with regard to the draft MPF4 being poorly worded. We have on record what you had to say with that, Professor Sparks. I wanted to ask specifically looking at priorities within MPF4. Whether or not you thought language had an impact on that and whether or not that should be laid out far clearer, for example, with a presumption in favour of renewables within planning departments taking those applications forward. I just wanted to get the panel's view on that. Specifically, where language has already been touched upon can sometimes not have a clear meaning. I am happy to ring you back in, Professor Sparks, if others want to put an R in the chat. My comments about language are really focused around the termset. I am sorry, but I am not sure that I can comment as much on the renewables part. I am very concerned about trying to be more balanced than I would be if we are serious about the things that we talk about in terms of planning an emergency 20-minute neighbours, community wealth building and all the good things around it. Health and well being and all the rest of it. I think that we need to be rather more prescriptive about those aspects. I will go back to my comment. I am very taken by the town centre first assessment point about no significant adverse impact. Why are we having any adverse impacts on town centres, given where we are? What is that language and room for argument there? I really would like to see a much strengthening of the language right throughout the document in many ways, and certainly in terms of the way the implementation goes. We just had a position in Stirling last week with an out-of-town development being given planning for me, despite the recommendations of the council to reject it. I just fear that we are going to continue to get that, because it was around sort of language issues and what we have got there. I also noticed in the glossary that if I have got it right, there are no definitions of out-of-town, so we have got riddle room there. There are a lot of things around that and the practicalities that I would like to see strengthened if we could. It is really important, because it affects delivery and implementation. Where planners are tight for time, having a definition that is set out is really helpful in the discussion with a developer about what an adverse impact is, what significant emissions means. We have a discretionary policy, a discretionary system, so anything that is in NPF4 and in the development plan can be discussed and negotiated around. Stronger language is helpful in identifying the red line, which defines what is and is not acceptable. At the moment, we still have a lot of these exceptions, except where there is an overarching need, except where this cannot be achieved by other means. Those loopholes are, unfortunately, loopholes that some developers assist in exploiting. In authorities that have an under-resourced planning team, those loopholes get bigger and bigger. As Lisa said, we continue to get applications that really do not meet the spirit or the letter of design guidance. They do not meet many of the existing policies and yet they still get consent. Sometimes, as Robbie Calvert pointed out earlier, those decisions can be guided by feelings about success at appeal. If we turn it down at this stage, the developer may appeal and how likely are they to be successful, and can we afford, as an authority, to defend that appeal? That is with the unfortunate side of implementation. That is why we need clarity here and a much tighter definition of terms. There are some terms that are not defined in the glossary at the back, and there are many terms that are defined in a way that I am not sure is entirely correct or detailed enough to be able to be defensible. That is helpful. My second question is about opportunities for proper consultation to take place with stakeholders. We have expressed concern that the committee's inquiry and work and the Scottish Government's consultation work are running beside each other during this time. I just wanted to ask the panel if you think that there are any other opportunities for people to feed in and whether or not that is one of your concerns. Especially given the pandemic, I would say that making this a priority for people to be aware of NPF4 and to be able to see what that means for their communities has never been the best time either. I am so happy for anyone to come in on that if there is anything that they want to add. I was struck when I looked at the draft that it is very long, and it is more than 100 pages. It has various annexes and supporting documents, and it is as wordy as anything. I have been a charter time planner for many years now, so reading it to me, I can understand it and I can understand what its intentions are. However, if you are not a planner and if you are not a policy person, if you are a regular resident of a community interested in planning issues, that is extremely off-putting. Much of the information is a geographical assessment of different parts of the country, and that is an interesting section. However, it is extremely wordy, the way in which it is written. We have to think critically about the purpose of those documents. For the national project, it also strikes me that there is no linking in the document between those national projects and any of the outcomes that are also specified. It is not clear if you have just picked up one at random. We have a description of the project and its need, but there is no link through to how this is what national outcomes it is going to help with. There are big issues. There are also not just the blizzard of consultations around all the planning things, but there are many other things happening, too. We have had consultations live on transport issues, so we have the car reduction target route map that has just come out and we have various other things that are also on the table. Organisations working in and around land use services have extremely busy time, so that is tricky. That adds an extra burden for the community. I have some radical ideas about community consultation because of the issues around who talks, how much they say, whose voices are loudest and the overburdening of successive consultations about strategic and then detailed and historic and then transport and air quality and low emission zones and post-colonial slavery legacy. As citizens, we are bombarded with those things, so we should think radically about some of the ways that we do this. Perhaps now is not the moment to share those ideas with you, but I think that there are some really significant questions about the burden on professional stakeholders and citizen stakeholders. We would like to hear those views, so it is maybe something that you could provide to the committee in writing so that we can include that in our work. I agree with Caroline on that point. I just make a couple of points. I think that I have great sympathy for the team in Victoria Key who were putting this together. I think that there was a very difficult hand with the decision in the 2019 act to combine the NPF with the Scottish playing policy, although that has been useful in many ways. A lot of the discussion this morning has been about how you connect those two things more rigorously. It almost guaranteed a document that was going to be quite long and quite difficult to digest, so that is necessarily still a work in progress. The second point that I just made is that with my coven association hat on, we are one of the probably one of the strongest local associations in Scotland with a long history. We are able to employ two staff, the equivalent of two staff full-time, but there is so much going on. It is almost impossible for us to respond to everything and to do that in a way that we would really like to.  Professor Sparks. This may not be the area that you started off with, but at the local consultation level there is a big job to be done. Through the work of the social renewal board last year and also the trans-interaction plan review, the one thing that we heard in common was that communities and people in places did not feel that they had a way of getting their voice heard and it was a very difficult thing for them. Things were done to them rather than done with them on them co-producing that. I think that there is a lot of work to be done at that level of the consultation, probably the wrong word to be used in those terms. I am now going to come back to—I am going to sweep up and pick up a question that skipped over earlier. This is around the MPF4 policies. Do the policies set out in draft MPF4 make provision for meaningful public engagement in the plan-making and development management processes? If not, what changes would you like to see made? I will start with Caroline on that one. There are definitely things that can be improved. I have to confess that that is not something that I have focused on in terms of what I have taken out of looking at MPF4, so I have not really engaged with that process thing. I am not sure that anything much has changed, but there are always things to improve with that. We talked earlier about women and children and disabled groups and underrepresented groups, and I think that there are always questions about how we are able to involve them in the planning system. I do not see anything here that addresses those concerns or difficulties. Thank you for that. Cliff, do you have anything to add on that? That is right. I remember what I was going to say to Miles Briggs, which was that it would be more helpful if the Parliament had a pause between the end of the inputs on MPF4 and its own decisions on it rather than trying to do things together. I think that there is a logic in the top-down approach. We said that we want consistency. We said that those are really important priorities. You have to accept that some of that means that things get fixed in MPF4 that are going to cascade down. The pr