Fourth National Planning Framework - position statement: consultation analysis

A Plan for Scotland in 2050

The Position Statement explains that NPF4 will include national planning policies, providing a clear and coherent plan for future development and will have the status of development plan, informing day-to-day planning decisions. It will embed the UN Sustainable Development Goals^[3] and Scotland's national outcomes^[4] and will have the Place Principle^[5] as a key driver. The long-term strategy will be driven by the overarching goal of addressing climate change and is expected to focus on achieving four key outcomes: Net-Zero Emissions; Resilient Communities; A Wellbeing Economy; and Better, Greener Places.

General points

There was broad support for:

• The general direction of NPF4 and the ambition for climate change to be the overarching priority.
• Embedding UN Sustainable Development Goals and Scotland's national outcomes.
• The four key outcomes set out in the Position Statement.
• Focus on the Place Principle.

Respondents also made a number of general points highlighting the importance of:

• Consistency of approach and of alignment of NPF4 with other plans, strategies and policies including the Climate Change Plan update, the Infrastructure Investment Plan, the National Islands Plan, the National Transport Strategy 2 (NTS2), the Land Use Strategy and Regional Spatial Strategies, and with city/growth deals. Alignment with other levers such as taxation was also suggested.
• Collaborative working across policy delivery areas, including across planning and other sectors and statutory bodies.

There were general calls for use of stronger or more robust language setting out clear requirements rather than simply encouraging change. This was suggested to be important to give local authorities the confidence to make development management decisions focused on the types of development that NPF4 aims to deliver.

There were also calls for clarity around definitions and wording and the need for consistency of interpretation between the Scottish Government and key agencies. A specific request was that NPF4 should differentiate 'culture' and 'the historic environment'.

It was noted that the strategy necessarily lacks detail at present with several respondents looking forward to seeing application of the concepts set out in the full NPF4. However, it was also observed that the lack of detail makes it difficult to encourage communities to respond to a consultation of this type.

The need for resources was also an issue highlighted across a number of responses with financing, upskilling and enforcement of planning controls all identified as necessary for delivery. It was suggested both that review of the Climate Change Plan should include consideration of local authority and statutory body resourcing and that planning fees might be ring-fenced as a resource.

A requirement for flexibility was also suggested, given the diversity of geography, society, economics and environment across the country and a requirement to differentiate between the needs of urban and rural communities was highlighted. Points with respect to the applicability of certain policies in rural areas are covered elsewhere in this report, particularly in the sections on integrating land use and transport and on 20-minute neighbourhoods.

COVID-19

Some respondents expected to see more on the response to COVID-19 in the Position Statement, for example with respect to new working patterns that may become established and on priorities for supporting the post-COVID recovery. It was argued that there must be a green recovery with the principle of net zero embedded at its core.

Other themes

Respondents also highlighted what they would like to see as central approaches to NPF4 including that:

• The focus should be on its purpose as a land use planning document constituted as part of the statutory Development Plan.
• Climate change and biodiversity crises should have equal recognition. Although it was acknowledged that the Position Statement recognises climate and nature crises to be 'intrinsically linked' it was suggested there is little mention of the nature crisis or action to address it elsewhere in the document.
• A place-based approach should embed public health and wellbeing at the centre of climate change decision-making.
• Planning for waste management and the circular economy should form a key pillar of NPF4.
• Consideration should be given to opportunities that would be offered by a 'biodiversity net gain' policy approach' including mirroring 'natural capital' planning approaches adopted elsewhere in the UK.

Other suggestions with respect to general themes and specific topics that some respondents felt were missing from the Position Statement or required much greater emphasis included:

• The role of solar power.
• The role of aquaculture.
• Connectivity.
• Reducing energy use and demand for carbon-intensive activities and high-carbon goods.
• Integration of land reform.
• Improving air quality.
• Delivering a circular economy.
• Importance of the electricity transmission infrastructure.

There were also calls for greater involvement for communities in planning decisions and for the planning system to address a perception that, at present, developers can steer the process for their own benefits.

Finally, although not specifically referenced in the Position Statement, several respondents noted their support for retention of the presumption in favour of sustainable development. It was argued NPF4 should recognise a presumption in favour for net-zero developments within the context of plan-led development.