NPF4 call for ideas: analysis of responses

Climate change

Proposed key objective of NPF4: to ensure planning policy results in spatial and land use change that facilitates Scotland's ambition to have net-zero emissions by 2045 and other statutory emissions reduction targets whilst supporting communities and businesses in making the changes needed to meet the targets.

Many respondents addressed the challenges presented by climate change somewhere within their responses. These comments often related to how other aspects of the planning system - including in relation to sustainable travel, the circular economy, protecting and enhancing biodiversity, taking a nature-led approach, and renewable energy generation and use - can help Scotland meet its climate change targets. These issues are all covered in greater detail under the relevant themes. The focus of the analysis presented here is on other issues raised.

A number of respondents addressed the urgency of tackling climate change and it was noted that the Scottish Government has declared a climate emergency. There was an associated suggestion that NPF4 offers a real opportunity to place the planning system at the heart of the climate change agenda, and that NPF4 is crucial in ensuring that all decisions from now on, made at any level in government, have the key consideration of getting to net-zero by 2045.

As discussed under the Sustainability theme, it was suggested that climate change and sustainability objectives must be placed at the centre of NPF4 with all other policy topics a secondary and subservient tier to the principle of addressing the climate emergency. Another perspective was that achieving climate outcomes and wellbeing should take precedence in decision making. There was a call for all policies and national developments to align with and contribute toward addressing the climate and nature emergency.

There was a call for NPF4 to be fully aligned with Scottish Government's Climate Change Plan and with the Climate Change (Scotland) Act 2009, including by supporting the delivery of local climate change adaptation frameworks. It was also suggested that a more overarching and joined up approach, that better reflects current understanding than SPP now does, will give planning authorities a better basis to include achievable and realistic policies in their LDPs.

It was also argued that localised climate change frameworks that enable place-based decision making will be required. A specific suggestion was that NPF4 should set local or regional carbon targets and require them to be incorporated into LDPs.

The connection was also made to a range of other strategic planning processes and key documents, including to ensuring that national planning policy and placemaking objectives are aligned. It was proposed that NPF4's message should be linked with the following:

• NPF outcomes relating to: Community Resilience; Supporting Infrastructure; Inclusive Economic Growth; International Partnerships; Climate Justice for Vulnerable Groups; Increasing the Resilience of the Natural Environment; and Protecting and Enhancing Scotland's Coasts and Marine Environments.
• The Environment Strategy for Scotland and, where relevant, the Marine Strategy Framework Directive.
• The work of the Scottish Infrastructure Commission, in order to create a spatial framework for carbon emission reduction.
• Regional Adaptation Strategies.
• The Land Use Strategy (covered further below).

Given the nature and scale of the emergency faced, it was also suggested that policy should:

• Encourage all with an interest in addressing the climate emergency to change their practices. Climate change policies must be essential requirements ('must haves') not optional ('should haves').
• Remove the obstacles to developments in Scotland that drive forward decarbonisation wherever possible.
• Allow local authorities to require developments to contribute to net-zero.
• Introduce a requirement for LDPs to demonstrate how they are contributing to Scotland's climate and nature targets with a report on their carbon budgets to include the carbon impacts of consented development.
• Encourage local authorities to make interim amendments to key policies rather than just waiting for replacement plans.

Other comments referred to the importance of land use to tackling climate change, including through the alignment of NPF4 with the Land Use Strategy. One perspective was that there is a clear function for NPF4 to help deliver the Land Use Strategy for Scotland and it would be useful to see the connections laid out in the framework.

It was explained that Scotland has been set a more ambitious climate change target than the rest of the UK because of land. There was a view that the decisions that are made over the next few years about how Scotland's land is used will underpin and determine the effectiveness of Scotland's response to climate change. It was reported that land use currently accounts for around one third of current carbon emissions in Scotland and that it will be important to understand the relationship between the necessary reduction in carbon and other greenhouse gas emissions and issues such as woodland creation, peatland restoration, natural flood management, improving biodiversity and habitat protection.

It was suggested that, if Scotland is to meet its emissions reduction targets, it needs to deploy a more purposeful land use planning approach to encourage more development that supports inclusive growth, wellbeing and the sustainability agenda. It was suggested that NPF4 should promote the integration of relevant plans, and specifically their land use elements, into planning. There was particular reference to the alignment of RSSs with other regional activities (such as City Region Deals, Regional Economic Partnerships and Regional Transport Partnerships) being critical if low carbon objectives are to be integrated and achieved.

By establishing an overarching spatial strategy for Scotland, it was suggested that NPF4 will play a critical role in guiding land use planning decisions and is therefore uniquely placed to enable Scotland to play a leading role in international efforts to tackle climate change.

Specific recommendations included that NPF4 should identify clusters and activity with the greatest potential to address climate change and that this could relate to a business sector or infrastructure capacity. There was a view that, as NPF4 will provide a national perspective, it needs to show how different clusters of business sectors, population, skills and infrastructure interlink and connect Scotland to provide solutions. There was also reference to creating potential low carbon, sustainability-focused investment hot spots and that if these strategically critical sites are identified in NPF4, Regional Economic Partnerships can then collaborate in relation to sites in their area.

Other comments included that:

• NPF4 should set out a national spatial overview for land use, planning and infrastructure, based on Landscape Character Assessment. This would also be a basis for review at local, regional and national scales to check desired climate change results, such as increased woodland coverage are being achieved.
• Guidance should be provided on the role of the Scottish National Investment Bank in supporting net-zero carbon development and alignment of the proposed Green City Region Deals with the RSSs and LDPs.

Design and energy efficiency of buildings

Many of the comments addressed the critical role of the built environment in the mitigation of, and adaptation to, climate change, including as the sector contributes to 40% of the UK emissions. General comments included that:

• Properties must be low carbon by design. Ambitious targets should be set, including for the embodied carbon and operational energy use for buildings. This could include introducing a change in Building Standards to introduce a zero-carbon standard for all new buildings and extensions to buildings.
• Buildings should be designed to minimise the amount of energy they need to heat and cool them. They should meet the highest insulation standards. Green roofs, green walls and local greenspaces can be used to reduce heating and cooling demands.
• Planning applications for all new buildings must meet EPC Band A rating immediately and have suitable renewable energy mechanisms, such as solar panels or air pumps as standard to meet at least 50-75% of average household energy needs. This obligation should increase to 100% after a set time, for example five years.
• More targeted assessment tools, such as the Building with Nature standards, could be promoted to support green infrastructure and biodiversity policy aims as well as placemaking.
• More homes should be heated by district heat networks. Developers should be required to consider this option and LDPs should have to assess the scope for district heat networks as part of the process for selection of sites.
• All new and refurbished buildings should be tested to ensure they perform as predicted.

There was also a call for NPF4 to require consideration of the carbon impacts of materials used, including their 'embodied' carbon, in developments over which the planning framework has influence. It was reported that the lifetime carbon footprint, or whole life carbon, of a building is made up of its lifetime operational carbon (energy used to heat and power it) plus the embodied carbon of the materials and products used to construct it. Depending on building type, between 30% and 70% of lifetime carbon is in the embodied carbon of a build after construction. It was noted, however, that this position is not static and that as Scotland decarbonises its energy, the levels of operational carbon will continue to decrease, and the proportional importance of embodied carbon will increase.

It was also reported that, as buildings and infrastructure constructed today can be expected to last at least until the time when net-zero is to be achieved by 2045/50, to ensure these materials are available for reuse, buildings and infrastructure will need to be designed and constructed now in ways which facilitate recovery of materials at the end of their first life.

Further comments or suggestions included that:

• For this approach to be effective, it is essential that planning policy, detailed planning guidelines and other drivers, including Building Standards are robust and consistent with NPF4, and that wider Scottish Government policies, particularly on public procurement, are also interlinked.
• It also makes sense to build now with better materials, that can be maintained or repaired and that are built with flexibility and with adaptation in mind to extend their useful lifespan, in line with Making Things Last: a circular economy strategy for Scotland.
• NPF4 needs to send clear messages to the construction sector to ensure that all developments are consistent with delivery of the 2045 net-zero carbon target. To achieve this, it will be necessary to consider and address the carbon emissions that arise from the sourcing, processing, transportation, manufacture, construction and deconstruction of the materials, products and built assets used.
• Grading of material based on its impact on the environment should be considered. Where materials are required for construction and refurbishment of buildings, these must be renewable and non-toxic and put together in a way that allows them to be taken apart easily at end of life.
• NPF4 should make clear that achieving net-zero targets requires increased use of local materials.
• Wider use of quality accreditation or performance standards such as BREEAM, CEEQUAL, Home Quality Mark ONE, WELL and Passivhaus should be considered.

Retrofitting

The value of the reuse of existing buildings over new build was highlighted. It was noted that new development accounts for a very small proportion of building stock, therefore finding ways to retro fit energy efficiency measures for the existing building stock will be essential, including because of the embodied energy they contain and which would be wasted if buildings are demolished.

It was suggested that retrofitting will be required across the majority of the housing stock, and that this will need to apply to both rented and owner-occupied stock, and that all existing homes should be retrofitted to certified Enerfit standard.

Other comments about the nature and scale of the challenge, along with possible solutions, included that:

• It will require very significant resourcing, and the Scottish Government should make resources available. This should include financial support for sustainability measures in the existing homes of less affluent owners.
• Design policies for climate change resilience need to support change in existing areas, including how this can be achieved for conservation areas and listed buildings.
• Permitted development rights need to take account of climate change and guidance and incentives should be provided.
• Flexibility will be required, recognising that bringing all properties up to a 'gold standard' will not be practical, but that the standards and expectations that we have for all properties and premises must nonetheless be improved.
• VAT should not be payable on materials used for energy refurbishment of buildings. The 'new building' VAT exemption should be changed to one that encourages reuse and refurbishment of old housing stock and reserved for certified 'net- or sub-zero' new builds.

New or redevelopment

It was suggested that reducing greenhouse gas emissions over a building's lifetime, and dealing with the climate emergency, needs to be at the top of the hierarchy of factors in the planning permission decision making process. This new priority setting must ensure that new buildings are built to the highest energy and insulation specifications, are maximally energy self-sufficient, and that existing stock is upgraded accordingly.

There was a connected view that at present there is a 'presumption for development' but that this must be changed to one against development unless certain 'sustainable' standards are met. Other comments in relation to new development, including new housing development, included that current policy only allows local authorities to 'encourage' developers to contribute to net-zero, not to 'require' them to do so, and that any changes required will need to be applied across both planning and Building Standards legislation.

In relation to construction, a concern was raised that the construction phase is having a much greater impact on the environment than is generally presented at the planning stage. An Other Representative Body respondent reported that incidences of legal non-compliance and mitigation identified to limit the impact of development are poorly understood, and implemented, during construction. They went on to explain that an Environmental Clerks of Works is sometimes required by planning consents to help support a development, but that the current planning regime limits their effectiveness. They suggested that NPF4 provides an opportunity to make the role more effective, to positively influence and incentivise the construction industry to improve environmental performance and to help protect the special character of our natural heritage and environment.

Another perspective was that the practice of the development industry is already changing as a result of the Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 and forthcoming changes to the Building Standards Regulations. Again, it was suggested that these changes will need to be embedded within planning at the national level, and there was a call for the development of a framework for the transition to sustainable methods of construction.

There were calls for all new homes to be certified to Passivhaus standard and for the benefits of passive housing, and other buildings using modular/offsite methodologies, to be promoted to both the market and supply chain, including the general public, house buyers, general building owners/users, architects and surveyors, and builders/self-builders.

It was also suggested that NPF4 should facilitate strategic consideration of how best to evolve and support the modular construction supply chain and market for Scotland and its regions, including optimising the use of Scotland's better quality regionally grown timber for construction.

In terms of other requirements that respondents thought should be covered by NPF4, and where necessary reflected in revisions to Building Standards, included:

• Requiring new buildings to achieve a high level of energy efficiency (carbon neutral where possible) and to be delivered in the most sustainable way possible with these objectives to be achieved through changes to Building Standards Regulations.
• Setting out appropriate emissions standards for new development, how emissions will be measured, for example using a carbon calculator tool such as SPACE and, where necessary, what measures or schemes are available to developers to off-set emissions. To enable an assessment to be carried out efficiently, there should be a clear requirement for development proposals to be supported by the information needed to measure emissions.
• Guidance on the requirements expected from new development must recognise that carbon reduction technology is rapidly changing, and local authorities should not adopt a prescriptive approach that may impact the viability and delivery of schemes or prevent alternative solutions to reducing energy consumption and carbon emissions.
• Encouraging the use of low carbon technologies and the use of electric vehicles. Local authorities should work with Scottish Government's low carbon team to ensure that these types of applications can be appropriately assessed. Developers should be required to future proof new residential developments for low carbon technologies and electric vehicle charging.
• Requiring a 10% biodiversity net gain on development sites over the course of their delivery. This could be assessed on a percentage of the site area or the level of the quality of the improvements.
• Considering the potential of smaller properties, with a variation of Passivhaus ideas allowing net-zero or better with little effort. It was reported that smaller does not have to mean 'cheap and cheerful' but can allow for high quality and the use of sustainable materials which consider a long lifespan for the dwelling.
• Requiring the better integration of climate mitigation and adaptation measures in redevelopments and new designs, for example with open space, de-culverting water courses, solar shading, permeable surfacing, food growing, larger gutters and grey water capture.
• Removing the ability for developers to construct 'new dwellings' under an historic Building Standard specification by banking building warrants prior to construction.

Finally, it was suggested that more pressure at the national level needs to be put on developers, particularly typical national housebuilders, to develop low carbon homes which are of high quality and a more innovative design.

Carbon capture and storage

A range of issues were raised in relation to carbon capture, sequestration or offsetting. They included that one approach could be offering carbon sequestration opportunities, such as through woodland creation and management, peatland restoration and wetland creation and management. It was suggested that provision could be made for this off-site, through contributions, in a similar way as is the case for Significant Alternative Natural Green Space and that it could be linked to other biodiversity measures, to induce multiple benefits.

NPF3's recognition of forests and woodland as economic as well as environmental assets was highlighted, and it was suggested that forests and woodlands can be part of a just transition to a net-zero economy by providing green jobs, and also be part of the transition to making Scotland's land into a carbon sink and more biodiverse. It was also reported that the right trees in the right place for the right reasons can prevent flooding, improve air quality, provide habitats for improved biodiversity - all while absorbing carbon. However, there was also a note of caution that an approach which results in monoculture of forestry does not offer the benefits of biodiversity.

As part of this, local authorities should commit to a minimum target for tree canopy cover in new developments of 30%. A developer levy could stipulate requirements to reach this target and trees can be planted in advance to provide mature natural infrastructure for when the development is finalised.

Tree planting on vacant and derelict land has also been recognised as a way to use land to absorb emissions. Some of this type of land is close to where communities live and therefore it can provide a range of benefits for a range of NPF outcomes.

Other suggestions in relation to capturing carbon or offsetting included that:

• A framework for accredited carbon offsetting could support an area to become net carbon zero.
• Aquaculture should also be considered for carbon capture given that Scotland is a maritime nation with vast amounts of inland water.

Another theme was in relation to CCS, which was considered by the majority of respondents who commented on the issue as essential to Scotland meeting its
net-zero greenhouse gas emissions targets. A number of the National Development-related comments or proposals called for the continuation of the support for CCS. One of the NPF3 National Developments is a Carbon Capture
and Storage Network and Thermal Generation.

It was suggested that there is no credible scenario for meeting net-zero targets that does not include CCS and it was reported that the Committee on Climate Change stated that CCS is a necessity, not an option, if the UK wants to achieve net-zero by 2050.^[23] There was also a view that Scotland is uniquely placed to take advantage of the opportunities CCS presents, including through its contribution to sustainable economic growth.

It was seen as important that NPF4 takes full cognisance of the potential contribution of CCS to meeting the target of net-zero emissions by 2045, and also of the opportunity for Scotland to take a world-leading role in the application of this technology, bringing together the relevant technical, economic and commercial expertise that has been developed in Scotland over half a century. It was also suggested that NPF4 should support the further development of CCS technologies.

It was reported that at present SPP only requires CCS in the context of energy projects, and there was an associated call for the requirement for CO₂ capture, or CO₂ capture readiness, to be applied to all new developments that are expected to have CO₂ emissions above a certain threshold, unless comparable emissions removal or avoidance can be demonstrated by other means. It was suggested that this should apply to emissions of CO₂ from both fossil and non-fossil sources, to maximise the potential for greenhouse gas removals.

Other CCS-related suggestions or proposals included that:

• CO₂ transport and storage infrastructure would provide a CO₂ take-away service to industry, enabling plants to capture their CO₂ in the way that best suits their process, then pass it on to the operator of a shared transport and storage infrastructure for safe and permanent storage. The development of a CO₂ transport system should nonetheless be a planning priority.
• There is a particularly significant opportunity for Scotland in relation to the permanent storage of CO₂ in deep, onshore or offshore geological formations. It was reported that this could utilise many of the technologies - and potentially some of the infrastructure - that have been developed over decades by the oil and gas industry, and that Scotland is well placed to provide the technological underpinning and the potential repositories needed for a workable CCS policy.
• Crown Estate Scotland could play a key role in future development of CCS through its role in leasing rights to carbon and gas storage on the seabed out to 200 nautical miles.

It was reported that CCS necessarily involves additional costs for capture as well as storage, and it was suggested that with a global market intent on minimising the cost of energy, there needs to be a level of carbon tax that would make such investments viable. It was suggested that CCS only becomes economically attractive if polluters are required to pay a tax or levy greater than the cost of implementing CCS.

An alternative perspective on CCS from one respondent was that the viability of it being implemented on a large scale is doubtful and that it is still a largely unproven technology, despite receiving years of funding. It was suggested that relying on a technology that might never be viable not only runs the risk of delaying urgent action needed today but diverts funds away from more credible solutions such as building the infrastructure needed for 100% renewable energy across heat, transport and electricity.

Research and innovation

As in relation to CCS, the critical importance of innovation and research was highlighted, and it was suggested that Scotland can make huge economic gains by heavily supporting the innovation process and enabling the roll out of new innovations globally.

However, it was thought that the high level of innovation necessary will only happen if there is a mechanism in place that allows for quick and easy access to funding, from the conceptual stage onwards, for the key players such as researchers, research institutions, inventors and companies.

Regional innovation hubs with low-threshold access for innovators, and the ability to access sufficient funds rapidly, were proposed as the critical step that would allow for the transition from idea to development, trial and implementation to be shortened drastically. It was suggested that this will require a government and/or government/industry funding scheme that aims to put Scottish talent at the forefront of a technological revolution.