Does revised draft NPF4 represent a positive step for health in planning?

30 November 2022
It’s been almost a year since we last heard anything on Scotland’s new National Planning Framework NPF4 but on 8th November 2022 a revised draft version of NPF4 was published and laid before the Scottish Parliament. The revised draft takes on board comments, suggestions and recommendations from a wide range of stakeholders and sets out how the planning system will deliver on commitments to tackle climate change and deliver sustainable, liveable and productive places for everyone in Scotland.

In a previous blog, we reflected that the previous draft version of NPF4 put forward for consultation was not a plan for health and would not deliver the change required for the planning system to improve the food environment. Food and the planning system are intrinsically linked and the previous draft version failed to take account of this. So, what does the revised draft say about health and using the planning system to create healthy food environments?  

Revised draft NPF4 – what has changed?

Positively, the revised draft does more strongly focus on health and the food environment. Policy 23 details that where development proposals are likely to have a significant adverse effect on health, they will not be supported, and a health impact assessment (HIA) may be required. Whilst this stops short of full incorporation of health as a material planning consideration, which we called for in our response to the consultation, it represents a positive development in that HIAs can be used in planning application decisions. However, the policy only states that HIAs may be required, which stops well short of them being a mandatory requirement. This is concerning as it is difficult to know when and how they will be used, despite knowing how effective they can be. We believe the policy needs to state that HIAs are or will be required so they are a mandatory requirement.

There is now also a presumption against drive-through takeaways within revised draft NPF4. Policy 27 states that they will only be supported where there are specifically supported within the local development plan (LDP) for a particular area and can only be located in areas where there would be no negative impact on the principles of local living or sustainable travel. The primary motivation for this addition appears to be climate focused. Clearly, however, this is also likely to have a positive health impact by reducing the number of these outlets in an area, and demonstrates the interconnectedness between promoting health and tackling climate change. However, we need to ensure this mutual benefit is realised and it is not just a displacement of location but a real reduction in number of premises. The policy then goes on to outline that development proposals for non-retail uses, including hot food takeaways, will not be supported if they would undermine health and wellbeing of communities, especially in disadvantaged areas.

As well as restricting developments that have a negative impact on health, it is also important that the planning system facilitates and promotes developments which enhance health and wellbeing, including healthy food outlets, and the revised draft appears to have taken this into account. Policy 28 in the revised draft states that LDPs should identify areas where proposals for healthy food and drink outlets can be supported, and that small-scale neighbourhood retail development will be supported where it can be demonstrated to contribute to the health and wellbeing of the local community. This should help to create more healthy food environments in local areas.

What is most disappointing is that the 6 spatial principles[a] in NPF4, which are overarching principles that will be used to plan future places, have not been updated in the revised draft and so health is still not included as one of these principles. The reason given for not changing or expanding the principles is that other topics suggested for inclusion as principles, such as health, get good coverage elsewhere in the document. Whilst there has certainly been improvement in the coverage of health within the revised draft version, not including health in the spatial principles raises the question of how much it will truly be considered in planning decisions, given that these principles are the overarching principles that will be used to guide decision making.

Health in planning – what can we learn from other areas?

When assessing the Scottish planning context, it’s important to look elsewhere to learn lessons and to adopt best practice where it is relevant. There are examples from England of where health has been implemented as a core principle and focus of the planning system, and where health has been used a reason for refusing planning applications.

Gateshead Council have developed supplementary planning guidance for hot food takeaways[1], and they have even gone as far as taking a blanket ban approach to new applications for this type of business[2]. As well as the traditional criteria of assessing applications for hot food takeaways on the basis of their impact on litter, noise and anti-social behaviour, which are currently included in Scottish guidance, the supplementary guidance also includes as planning application considerations the levels of obesity within the area, proximity to locations where children and young people gather, over supply, clustering, and states that a health impact assessment will be required. With this guidance, there has been a 14% reduction in the number of fast food outlets in the area, and outlet density has been reduced by around 13 fewer units for every 100,000 people.

Similarly, nearby Sunderland City Council implemented a hot food takeaway policy in January 2020, as part of their Core Strategy and Development Plan[3], placing it at the heart of council policies. Like in Gateshead, the policy seeks to restrict takeaways in close proximity to schools, where childhood obesity rates are above a threshold level, and also to prevent clustering of these outlets. Since the policy has been implemented, it has been successfully used to refuse 6 planning applications for hot food takeaways[4], with health and obesity rates given as either the main or one of the main reasons for the applications being refused.

These examples highlight how the planning system can be used effectively to improve the food environment and prioritise health outcomes, and demonstrate a recognition of the need to address the role of planning decisions in shaping the food environments we all experience every day.

Returning to Scotland, a new version of the Place Standard Tool[5] has been published, and for the first-time healthy food is explicitly mentioned in it (in the facilities and services section). By explicitly including it as one of the things to consider when discussing local facilities and services in their place, it encourages local communities to think about their local food environment. An issue is much more likely to be discussed and considered when it is explicitly listed, and this in turn is more likely to result in impetus for and possibly influence change. It is also a positive recognition of the importance of the food environment in determining the quality of places. However, it remains unclear how priorities identified by local communities via the tool, like the need for a reduction in unhealthy takeaways, will be translated into change on the ground and how these priorities link in with the wider priorities of NPF4 which ultimately dictate the direction of travel.

Will NPF 4 deliver for health?

At its heart, NPF4 remains focused on tackling climate change and reversing biodiversity loss with the aim of achieving net zero by 2045. Of course, this is a laudable and important aim but it needn’t be the only focus. Health and the environment are not mutually exclusive and shouldn’t be seen as such. There needs to be a shift in the discourse to view tackling climate emissions and tackling health inequalities as complementary and part of the same end goal.  We know many of the changes we need for planetary health will also deliver improved population health outcomes.

Health does feature more prominently in the revised draft which is of course a positive development and is a clear acknowledgement of the significant impact that the planning system has on health and wellbeing outcomes. However, there is still scope to go further, and the revision has stopped well short of fully incorporating health as a material planning consideration, which is the only way to guarantee that impact on health is considered in all planning decisions.

Our conclusion: some positive developments, but still room for improvement.

References

[1] Gateshead Council (2015) Hot Food Takeaway Supplementary Planning Document https://www.gateshead.gov.uk/media/1910/Hot-Food-Takeaway-SPD-2015/pdf/Hot-Food-Takeaway-SPD-2015.pdf

[2] https://arc-nenc.nihr.ac.uk/news/putting-the-brakes-on-fast-food/

[3] Sunderland City Council (2020) Core Strategy and Development Plan 2015-2033 https://www.sunderland.gov.uk/media/22171/Core-Strategy-and-Development-Plan-2015-2033/pdf/CSDP_2015-2033.pdf?m=637159725864470000

[4] Information supplied directly from Sunderland City Council. Details of planning applications available from the Council’s website - Sunderland Home Page - Sunderland City Council

[5] Public Health Scotland (2022) Place Standard Tool. How Good is Our Place? https://www.ourplace.scot/sites/default/files/2022-11/Our%20Place%20Place%20Standard%20Tool%20final%20version%20-%20Print%2C%20Interactive%20and%20booklet%20details%20-%20Oct%2022.pdf