The Scottish Government published the fourth National Planning Framework (NPF4) draft for consultation on the 10th November 2021. Titled ‘Scotland 2045’, the eagerly awaited document outlines Scotland’s strategic approach to planning and land use to 2045, coinciding with the government’s ambitious target of transitioning towards a net-zero society by the same year. Now combined with the Local Development Plans (LDPs), it is a critical publication that will inform future planning proposals for Scotland over the next quarter of a century.
A plan of four parts
NPF4 is an extensive planning framework and it is impossible to fully review the 130 page document in a short post. However, it is made up of four key parts:
- A National Spatial Strategy which sets out the four fundamental overarching themes which future development will aim to reflect and achieve. This is a vision for the creation of sustainable, liveable, productive and distinctive places.
- 18 National Developments of ‘national importance’ that are proposed to support the delivery of the spatial strategy across the country. These include developments such as a Central Scotland Green Network, Urban Mass/Rapid Transit Network and Island Hubs for Net-Zero
- 35 National Planning Policies for development and land use to be applied in the preparation of development plans, local place plans and development briefs; and for the determination of planning consents.
- Delivering the Spatial Strategy through key delivery mechanisms such as aligning resources to targeting investment and an infrastructure first approach.
What does NPF4 include on climate change?
The transition towards a net-zero society through sustainable development is a cornerstone of the draft NPF4. In fact, the wider issues of climate change, decarbonisation, biodiversity loss and nature-based solutions are firmly rooted throughout many of the strategy’s policies.
Policy 2 is dedicated to climate change. It lays out a new requirement for all development proposals to give “significant weight“ to the Global Climate Emergency as planning authorities are to carefully consider every development’s future implications for the climate.
It states that all developments should be designed to minimise emissions in alignment with the national decarbonisation targets and that proposals that do generate significant emissions should not be supported, unless the applicant provides evidence that the level of emissions is the minimum that can be achieved.
Tom Arthur, Minister for Public Finance, Planning and Community Wealth, has highlighted the requirement of giving ‘significant weight’ to climate emissions as a crucial feature within the framework for facilitating future sustainable development.
There is an undoubted sense of prioritisation of the climate emergency within the draft NPF4, as well as recognition of the planning authorities’ role in reducing emissions that was not so evident in previous iterations.
However, the draft concept of ‘significant weight’ remains a loose term that could become open to uncertainty – especially with the wide variety of developments it will apply to in practice. Despite the draft NPF4 illustrating that evidence of minimum emissions is required in certain instances – such as carbon intensive proposals – it remains unclear what this translates to in more typical housing developments, for example.
A host of other policies are also relevant to climate. Policy 19 on green energy states that local development plans should “ensure that an area’s full potential for electricity and heat from renewable sources is achieved”, whilst all forms of renewable energy and low-carbon solutions should also be supported. This includes support for the extension and creation of new wind farms.
Another marked difference from previous iterations of the NPF is the inclusion of ‘20 minute neighbourhoods’ as a viable approach to low-carbon urban living. A key principle of Policy 7 on local living, it is mentioned 18 times throughout NPF4 – making it one of the most prominently used phrases in the document.
Nature and biodiversity loss
As well as acknowledging the climate emergency, the draft NPF4 is clear in its identification of a ‘nature crisis’ in Scotland that is being aggravated by urbanisation:
“Our approach to planning and development will also play a critical role in supporting nature restoration and recovery. Global declines in biodiversity are mirrored here in Scotland with urbanisation recognised as a key pressure. We will need to invest in nature-based solutions to mitigate climate change whilst also addressing biodiversity loss, so we can safeguard the natural systems on which our economy, health and wellbeing depend.“
Policy 3 is dedicated to promoting nature recovery, and again there is a heightened focus on this issue now compared to previous strategies. It states that development proposals should “facilitate biodiversity enhancement, nature recovery and nature restoration“, whilst the potential adverse impacts of development should be minimised as a priority.
Likewise, major development proposals or those where an Environmental Impact Assessment (EIA) is needed should only be approved where it is concluded that the proposal “will conserve and enhance biodiversity, including nature networks within and adjacent to the site, so that they are in a demonstrably better state than without intervention”.
Further areas of importance with regard to nature preservation include the use of ‘nature-based solutions’, which is used in accordance with the spatial strategies, several of the national developments and planning policies.
In some instances, specific examples of nature-based solutions are provided – such as the impressive Central Scotland Green Network national development, which includes a nature-network approach to water management with sustainable drainage solutions in Glasgow and Edinburgh. However, it could be argued that the draft lacks an abundance of smaller scale examples of nature-based solutions, in the practicalities of more routine planning developments.
Moreover, Policy 33 on soils aims to give peatlands greater protection and restoration. The draft states that development upon peatland and carbon rich soils should not be supported unless for meeting essential criteria, whilst “local development plans should actively protect locally, regionally, nationally and internationally valued soils“.
What’s next for NPF4?
The consultation period for NPF4 is well underway, with the Scottish Government inviting feedback and scrutiny on the document until 31st March 2022. The draft is subject to several parliamentary committees engaging with planning stakeholders and the general public.
Committees are encouraging demographic groups who do not typically engage with planning matters – such as young people and the elderly – to take part in NPF4, underlining the desire for more inclusive involvement in planning decision-making.
Following the declaration of a national climate emergency, the announcement of world-leading decarbonisation targets and the hosting of COP26 in Glasgow last November, NPF4 certainly provides a starting vision for how environmental targets will translate into action through planning.
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