National Planning Framework 4: explanatory report
This explanatory report accompanies our National Planning Framework 4 revised draft. It provides a summary of the representations made through our consultation on Draft National Planning Framework 4 and sets out the changes made in response to those reviews.
General Changes
Summary of Representations
A number of general comments referred to the framework as a whole. These are summarised below and the following table documents changes made.
The Analysis Report identified four general themes not specific to a particular consultation question:
- Structure of NPF4
- Strategic hierarchy and relationships
- National Planning Policy Handbook (covered under Part 3)
- Language used across NPF
Structure of NPF4
Summary of representations
Respondents commented on the relationship between the different parts of the draft document, as well as its overall structure. Suggested changes or additions to the document included: setting out the interconnections across the national spatial strategy, National Developments and policy handbook; the use of schematics that illustrate how the different elements of NPF4 come together at different scales through a place-lens; and adding a statement in the early part of the document on how it complies with the various statutory requirements of the Town and Country Planning (Scotland) Act 1997 (as amended), and other related legislation.
Overview of changes
The structure of the document has been revised to better connect the various sections and to provide clarity on the vision and strategy. Changes to improve usability have been made including the addition of an Annex to provide further and more detailed information on how to use the document.
The document has been restructured under 3 themes rather than 4, with Distinctive Places being removed (and policies under this heading redistributed), to focus on the three pillars of sustainable development: environment, people and economy. The narratives for each theme have been strengthened and additional detail on how the strategy will meet the statutory outcomes has been added. The Regional Spatial Strategies have been sharpened, more clearly focusing on the main issue for each area, including the main priorities for action and the relevant National Developments.
The policy section (now Part 2) has also been re-presented to separate instructions for LDPs from development management policy. Extra sections have been added to show key connections to other parts of the document.
The spatial principles have been strengthened and better reflected throughout the document, particularly through highlighting their impact in each themed policy in Part 2 and each National Development.
A diagram has been added to show links between the national outcomes and UN Sustainable Development Goals, the spatial principles, National Developments and policies, plus wider Scottish Government plans and strategies.
| Issue | Change | Reason/Comments |
|---|---|---|
| Comments on the overall 'fit' of the document and how the different parts sit together. | The section setting out 'How to use this Document' has been moved to an Annex (A) and supplemented with additional content. The text in the Draft focused on the structure of that publication. The revised version provides information on the role of the NPF and how it fits with other plans and clarifies the varying roles of each section. It underlines our commitment to a plan-led planning system and the primacy of the development plan in decision making. The 'How to Use this Document' Annex makes clear NPF4 should be read as a whole, as it represents a package of planning policies to guide us to the place we want Scotland to be in 2045. | To respond to stakeholder views by providing additional detail and clarification. |
| Call for a greater focus on the statutory outcomes. | The Act requires NPF to set out a statement of how development will contribute to each of the 6 statutory outcomes. In the Draft we provided a high level summary within an Annex. In the revised document we have strengthened the messages on each outcome, further highlighting how we can deliver each outcome. The statements have also been embedded within the main document to provide greater prominence and to help link the spatial strategy with relevant policies. | To respond to stakeholder views by providing additional detail and clarification. |
| Themes - there was some feedback that the Distinctive Places theme was the least coherent, and that the concept is embedded in planning decisions. | We have made a shift from 4 themes to 3, removing Distinctive Places. The new structure is intended to ensure that the value of special distinctive places, as a place-based approach, cuts across all the themes, rather than as a separate issue. The policies within this section have been redistributed to reflect the three remaining themes. (See Figure 2) | To respond to stakeholder views by presenting a more logical story, based around the three pillars of sustainable development: environment, people and economy. |
| Concern the Draft NPF4 is currently not as well framed as many LDPs, does not appear to have adopted good practice that has emerged through the examination of LDPs by the SG's Planning and Environmental Appeals Division. | Wording has been tightened across the policies and consistency improved. | To respond to stakeholder views. We have liaised with colleagues in the Planning and Environmental Appeals Division (DPEA) who have provided advice on clarity of language in the policy wording and relationships between policies, based on their experience examining LDP policies and their role in the appeals process. |
| Call to set out the interconnections across the national spatial strategy, National Developments and policy handbook. It was suggested that it would be helpful if the framework could be presented in way that clearly articulates the interconnectivity between these, and what this means for planning processes. | New schematic diagram added to illustrate how the different elements of NPF4 come together at different scales and the interconnections. Spatial principles better reflected and referenced throughout document including for thematic policies and National Developments. Key policy connections also identified for each policy in Revised NPF4 Part 2. | To respond to stakeholder views and further strengthen key messages throughout the document, creating better flow, and greater consistency. |
| Call for use of schematics to illustrate how the different elements of NPF4 come together at different scales through a place-lens to support the Place Principle. | No change. | The use of graphics can be a powerful tool and post approval we can take stock of any graphics and visuals that stakeholders would find useful whilst also making use of existing graphics from other partners. These can be accessed via websites, and updated throughout the lifetime of the NPF, which we believe is more practical than embedding within the document. |
| Call for stronger framing of the Place Principle throughout the document. | References to the Place Principle have been strengthened throughout. We have set out an expectation that National Developments will be exemplars of the Place Principle; highlighted that LDPs should be place based and created in line with the Place Principle; clarified that our policies on design and local living intend to help delivery of the Place Principle; and we have added a Glossary definition for clarity. | To respond to stakeholder views and clarify expectations of the planning system in implementing the Place Principle. |
| Calls for a statement on how NPF4 complies with the various statutory requirements of the Act and other related legislation. | No change. | This is addressed by the statements on the statutory outcomes. It was not considered appropriate to add multiple references to all the Planning Act's requirements and those of other related legislation in the development plan. |
| Call to ensure NPF4 locks-in climate positive behaviours. | A new overarching Policy 1 in the revised NPF4 has been added to set out that the contribution of development proposals to the global climate emergency and nature emergency should carry significant weight in planning decisions. | To respond to the UK Climate Change Committee. |
| How will policy be delivered and resourced including skills? | No change. | The delivery of NPF4 is a shared responsibility of all stakeholders. To support this, a Delivery Programme has been published alongside the Revised Draft version which sets out key actions to implement its priorities and policies. |
Figure 2: Shift from 4 themes to 3
Strategic hierarchy and relationships
Summary of representations
A number of respondents commented on the inter-relationships between NPF4 and a range of other national, regional or local strategies or plans. A general observation was that NPF4 misses an opportunity to clearly state where it sits within the overall context of other Scottish Government plans and strategies.
At a national level, it was noted that the aims of NPF4, chiefly the just transition to net zero, adoption of place-based working and delivery of a wellbeing economy, are shared across a number of current and emerging strategies and statutory documents.
Strategies referenced included the National Strategy for Economic Transformation, Heat in Buildings Strategy, Town Centre Action Plans, Land Use Strategy and the forthcoming Biodiversity Strategy.
Being clear about the relationship between NPF4 and these related strategies was seen as offering the best chance of success, with the quality of alignment seen as key. It was suggested that this is especially important when it comes to the successful delivery of those individual planning policies which cross over into other areas and where strategies have complementary aims.
Overview of changes
The narrative for each theme now covers links and relationships with other national strategies and policies. A new schematic (Table 1 in Revised NPF4) has also been added to show key policy links. The new 'How to Use this Document' Annex covers the roles of NPF and other plans in the planning system (including Regional Spatial Strategies, Local Development Plans and Local Place Plans) and also references Regional Transport Strategies.
| Issue | Change | Reason/Comments |
|---|---|---|
| Lack of clear explanation of where NPF4 sits within the overall context of other Scottish Government plans and strategies. | Revised NPF4 aligns with all relevant Scottish Government plans and strategies. Table 1 in Revised Draft NPF4 shows at a glance how all the themes, spatial principles, National Developments and policies fit together as well as how they relate to wider strategies. We have added references to a number of key policies and strategies in Revised Draft NPF4 Part 1, under the narrative for each theme. These updates outline the role that these strategies play and how they link and can help deliver that theme. The Revised Draft NPF4 'How to Use this Document' Annex explains the status of NPF4 as part of the development plan in the planning system. | To respond to stakeholder and committee views. Over the lifespan of the NPF, new strategies will emerge and others may be superseded. The NPF4 Delivery Programme includes detail of the relationship with other key national plans and strategies. |
| Consider what more could be done to enable users of NPF4 to better understand links to other strategies and the synergies between them, so that they can take them into account in decision making. | ||
| Calls for more cross referencing between policies. | ||
| The relationship between NPF4 and a number of other policies and strategies could be more explicit and the NPF4 could elaborate on how conflicts between them are dealt with – which strategies take priority. | ||
| Calls for guidance from other parts of Scottish Government/agencies to be referenced. | ||
| Concern that there is insufficient reference to Regional Transport Strategies. | New text added in Revised NPF4 Annex A on 'How to use this Document' to reference Regional Transport Strategies. | To respond to stakeholder views. |
| Call to clearly set out NPF4's connections with LDPs and Regional Spatial Strategies. | New Revised NPF4 Annex (Annex A) on 'How to use this Document', which covers the roles of NPF and other plans in the planning system (including Regional Spatial Strategies, LDPs and Local Place Plans). | To respond to stakeholder views. |
| Greater clarity on priorities required if the ambitions of NPF4 are to be delivered in a coherent and consistent way – consider whether more could be done to provide decision makers with clarity and certainty. | Multiple changes to structure and wording have been carried out throughout the document to add clarity and clarify intent. Revised NPF4 Policy 1 added to clarify that significant weight is to be given to the climate emergency and nature crisis. | To provide clarity in response to Committee (LGHP) and stakeholder views. |
| Consider how digital tools might improve the accessibility of NPF4 and understanding of the interrelationship between parts of the document. | No change. | LGHP Committee request. Improving digital tools, including the accessibility of NPF4 is part of our wider Digital Transformation Programme. We will explore how NPF4 can be brought together with LDPs in a single development planning platform at the appropriate stage in the digital transformation programme. |
Language
Summary of representations
A frequently-raised issue related to the wording used across NPF4, including the frequent use of 'should'. It was suggested that this is ambiguous, and it is not clear where this means that the relevant policy must be complied with. Another frequent concern was around references to development being 'supported' or 'not supported', and there was a question as to whether this means that development is to be approved or not to be approved?
Overview of changes
The wording, and use of language has been refined throughout the Revised NPF4 document, particularly within the policies, to provide greater clarity and consistency.
Further clarity of definitions of terms provided, with both further detail provided within the Part 3 policies section and with additional terms defined in the Glossary.
| Issue | Change | Reason/Comments |
|---|---|---|
| Use of 'should' | Policies have been reworded using 'will/will not be supported'. 'Will be supported' is often used within LDPs and is considered to be established development plan wording. Further clarification has been added to Revised NPF4 Annex A to clarify that the decision maker must take into account all relevant policies and material considerations. | To respond to stakeholder views by providing clarification. |
| References to development being 'supported' or 'not supported', and whether this means that development is to be approved or not to be approved. | ||
| Policy priorities and spatial principles must be applied consistently throughout the document – NPF4 must be internally consistent. | Edits have addressed consistency, both in terms of consistent wording and policy intent. Within the policies at Revised NPF4 Part 2, details of connections to relevant spatial principles have been added for consistency in policy application. | To respond to LGHP Committee. |
| Work on clarity of definitions of terms – e.g. 'community wealth building' and '20 minute neighbourhoods'. | Text throughout the document has been reviewed and strengthened. Glossary definitions have been refined and additional definitions have been added. | To respond to Committee (LGHP, RAINE, NZET, HSCS and UK Climate Change Committee). |
| Work on certainty and clarity in language throughout framework. |
| Issue | Comments |
|---|---|
| A number of calls were made for further guidance on a range of issues and policy topics. |
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| Consider how mappingcould be included in future iterations of NPF. |
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| Calls for training for elected members. |
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| Calls for more resources. |
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| Role of communities. |
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| Planning Skills - calls for a resource and skills strategy to be prepared. |
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| Calls for more details of/funding to support delivery of NPF4. |
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Contact
Email: Chief.Planner@gov.scot
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