National Planning Framework 4: delivery programme - third update

B. Monitoring and actions so far

During the last year we have been developing our approach to monitoring and measuring progress on NPF4’s impact. The speed of change will vary both across the country and between policy areas. It is important to monitor long-term change and for the monitoring framework to evolve over time. Given the significant lead-in time for development projects, trends will likely not emerge for some time and will not be wholly attributable to the impact of NPF4: A broad range of influences will be at work, among which planning has a key role in creating the circumstances for, and overcoming barriers to, change.

We have commenced work on an Interim Monitoring Report. Monitoring during the first year post-NPF4 adoption focused primarily on policy implementation. During the second year we are increasing emphasis on progress with national developments.

We have made considerable progress on the broad suite of actions designated in the second iteration of the Delivery Programme, as noted throughout this update.

Spatial Strategy

Since its adoption, the NPF4 spatial strategy and national planning policies have influenced Scottish Government policy and action, as well as local decision-making.

The Planning, Infrastructure and Place Advisory Group (PIPAG) is helping to explore and test collaborative solutions to barriers to delivery of development that would support implementation of NPF4. Further detail about the activities of PIPAG is included in section D.

It is a statutory requirement to take the National Planning Framework into account when preparing an LDP, and LDPs are therefore an important mechanism for the delivery of NPF4. We will be monitoring the impact of the spatial strategy in emerging LDPs. At the time of publication, six LDP Evidence Reports have been submitted by planning authorities to Gate Check, and decisions have been issued on the sufficiency of four of these. Two Evidence Reports were judged sufficient, and two insufficient.

During the life of this Delivery Programme we expect to see a significant number of additional Evidence Reports pass the Gate Check. Annex A illustrates the expected timings of Evidence Reports and adopted new style LDPs, as reported by planning authorities in Q2 2024/25. Ministers have stated their expectation that a full suite of new style LDPs will be in place across Scotland by May 2028, and we will continue to work closely with planning authorities to help enable this. Progress towards adoption of new style LDPs marks a significant step forward for the implementation of a stronger plan-led and delivery-focused planning system.

National developments

NPF4 identifies eighteen national developments; significant developments of national importance that will help to deliver our spatial strategy. Their designation means that the principle of the development does not need to be agreed in later consenting processes, providing more certainty for communities, business and investors. However, national development status does not imply any individual project will be directly funded, and planning permission or other consents are still required before development can proceed.

The national developments include several single large-scale projects and networks of several smaller-scale proposals that are collectively nationally significant.

Since adoption of NPF4, the Scottish Futures Trust has completed initial baseline delivery templates for each of the national developments, and these will be updated over the next 12 months. These initial versions establish a baseline of where national developments are in relation to good practice delivery principles and the infrastructure life cycle.

Several of the national developments are supported by City Region Deals. There are further opportunities to bring planning together with city deal projects and wider opportunities for regeneration to take place-based approaches to delivery. Since NPF4 was adopted there has also been a change of UK Government. Planning in Scotland is fully devolved. Nonetheless, the new UK Government’s own ambitions for planning and development present an opportunity for Ministers and officials from the Scottish and UK Governments to work together to unlock investment and economic opportunity, and explore shared issues such as grid connections and capital investment.

We have carried out some initial progress monitoring of the national developments, with the table below showing recent activity relating to each:

Indicative timescales show that projects will come forward at various times in the coming years and that there are likely to be significant demands on the planning service at different points in time. Many of the national developments are being supported by private investment, although a number potentially involve significant public sector capital spend. Even where private sector investment in being levered in, the public sector is playing a significant role in supporting the delivery of most of the national developments, whether through consenting processes or more proactively as an enabler.

In 2024/25 the Scottish Government will support national development delivery, for example by facilitating liaison between lead partners and the wider Scottish Government and agencies, and by seeking solutions should barriers to delivery emerge.

National planning policy

Monitoring has initially focused on the implementation of the new national policies set out in NPF4. Feedback on most policies has been positive. Where there would be benefit, we have convened discussions with planning authorities and wider stakeholders on how different policies are being applied in practice.

We are mindful of the need to read and apply NPF4 as a whole, and the challenges that this can present. The intent of each of the 33 national planning policies is clearly set out in NPF4 and can be used to guide decision-making. This has been reinforced in communication since NPF4 was adopted.

Support for implementation of national policy since adoption of NPF4 has focused on those issues that have arisen during monitoring. We have issued a number of Chief Planner letters to support the transition to NPF4.

Specific actions we have taken relating to some policies include:

• Policy 2: Climate mitigation and adaptation – We have continued to progress planning and climate change guidance as this has been raised as a priority by some planning authorities. To inform the guidance, we published research findings identifying relevant information sources, tools, methods and approaches that can help demonstrate whether and how lifecycle greenhouse gas emissions of development proposals have been minimised. Over the coming months we will continue to engage with key stakeholders to inform the final guidance, and ensure the overall approach is proportionate, practical and contributes meaningfully to supporting delivery of NPF4.
• Policy 3: Biodiversity – In November 2023 we published our Biodiversity: draft planning guidance to support delivery of policy 3. The guidance was written with advice from stakeholders, and is designed to be a ‘living document’. It will be updated as practice beds in.
  
  In September 2023, the Scottish Government published independent research undertaken by SRUC into Approaches to Measuring Biodiversity in Scotland. The findings and recommendations set out pragmatic next steps to ensure a consistent and cross-government approach to measuring biodiversity at site level. We have since commissioned NatureScot to develop an adapted biodiversity metric suitable for use in supporting delivery of NPF4 policy 3(b). In April 2024 NatureScot launched this work with the publication of a Key Issues paper to inform the development of a biodiversity metric for Scotland's planning system. NatureScot has also launched a dedicated information and updates webpage.

• Policy 5: Soils – The Scottish Government has established the Peatland Expert Advisory Group, including representatives from industry, agencies and academia, to advise on how guidance can be updated to support our peatland and onshore wind aims.
• Policy 6: Forestry, woodland and trees – Scottish Forestry is progressing a review of the ‘right tree right place’ guidance to support planning authorities to produce Forestry and Woodland Strategies.
• Policy 11: Energy –We have hosted discussions with Heads of Planning Scotland and with the renewables sector to explore the application of policy 11(c) in relation to considerations for maximising economic impact, separate from the voluntary arrangements relating to community benefits that sit outside the planning and consenting systems.
  
  The Scottish Government is progressing comprehensive guidance for hydrogen consenting across onshore and offshore regimes, expected to be published in Autumn 2024.
  
  We highlighted to planning authorities, to inform resource planning, information on the pipeline analysis of forthcoming on-shore wind projects and on the National Grid ESO’s recommendations for investment in Scotland’s electricity networks.

• Policy 15: Local living and 20 minute neighbourhoods – Planning guidance was published in April 2024. The case studies in the guidance and further good practice can be updated as they develop.
• Policy 16: Quality homes – In June, following a Court of Session decision and the declaration of the housing emergency, we issued a call for action to planning authorities. We now expect to see an emergency-led focus in decision-making on plans and applications. A Ministerial / Chief Planner letter was issued that provides clarification on implementation of Policy 16, emphasises diversity of tenure and promotes more positive and constructive collaboration across sectors to support delivery. A further letter was issued to planning authorities requiring LDP Delivery Programmes are put in place by the end of March 2025, that will include the sequencing of, and timescale for, the delivery of housing sites allocated by the LDP. Previous versions of the NPF4 Delivery Programme indicated we would track indicative local housing land requirements as included in Evidence Reports. The most recent information is listed in Annex B.
• Policy 17: Rural homes – We convened a session in September 2023 with representatives of HOPS to facilitate a collective view of the implementation of NPF4 policies relating to rural homes. Clarification of the intended permissiveness of the policy has been provided in subsequent Chief Planner letters.
• Policy 21: Play, recreation and sport – we published Guidance on preparing Play Sufficiency Assessments in December 2023.
• Policy 22: Flood risk and water management – This policy has generated some debate. We have convened several discussions involving planning authorities, SEPA, developers and relevant professional bodies, and provided updates in Chief Planner letters. SEPA has published updated Flood Risk Standing Advice for Planning Authorities, Flood Risk and Land Use Vulnerability Guidance and Position Statement on Development Protected by Formal Flood Protection Schemes to support NPF4 delivery. This guidance has been developed with input from planning authorities, the Scottish Government and wider delivery partners. The Scottish Government has commissioned a research project ‘Future climate in today’s decisions’. This aims to support the use of future climate scenarios and hazards in today’s decision-making and is expected to report in November. The Scottish Government and SEPA will review and update relevant guidance, as appropriate, in light of the findings.
• Policy 24: Digital infrastructure – we published Planning guidance on Digital telecommunications in December 2023.

Resourcing delivery

At the heart of our ambitions for planning is enabling and accelerating delivery. We know that this requires investment in planning resources and capacity, both now and for the long-term. Our Investing in Planning consultation explored ways to better resource planning services and ensure proportionality in planning processes to strengthen capacity within the system. Over the last year, we have also:

• Established the role of the National Planning Improvement Champion, hosted by the Improvement Service. In this first year the focus has been on piloting a new approach to performance and improvement monitoring through the national planning improvement framework.
• Introduced the requirement for planning authorities to appoint a Chief Planning Officer, supported with Chief Planning Officers: guidance.
• Worked with universities, the Royal Town Planning Institute and other stakeholders to take forward recommendations in the Future Planners Report.
• Provided 10 x £5000 bursaries for students undertaking postgraduate planning degrees in Scottish planning schools in the current year.
• Established a short life working group looking at proportionality in the assessments required to accompany planning applications.
• Established an expert advisory group, co-chaired by Roseanna Cunningham and the Chief Planner, to help us to develop proposals for reform for Compulsory Purchase in order to make it simpler, more streamlined and fairer for all parties.
• Completed Phases 2 and 3 permitted development rights, to reduce the number of applications in the system.
• Supported the design and delivery of a CPD course entitled ‘An Introduction to Hydrogen for the Public Sector’ with the University of Edinburgh, University of Strathclyde and Aberdeen University, free of charge to local authority planning professionals across Scotland.

This work remains a significant priority and we are continuing to progress priority actions in partnership with stakeholders.