NPF4: a new prioritisation of the environment through planning?

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.


Further reading: more on planning and the environment from The Knowledge Exchange blog:

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Guest post: The 2035 petrol, diesel and hybrid ban – what it means and how we get there

The government has announced they will ban the sale of new petrol, diesel and hybrid vehicles from 2035, bringing forward the original date by five years. In this guest blog, Ian Johnston, CEO of EV charging network, Engenie, discusses the challenges and opportunities that this target will bring.

Since 2017, when a ban on petrol and diesel cars was first introduced by the UK government, there has been growing calls for the policy to have more ambition. Those calls were answered when the government brought forward its ban.

On Tuesday February 4 the government, having resisted calls for more stringent anti-ICE (internal combustion engine) polices for three years, brought its ban forward from 2040 to 2035.

The move was announced almost a year after the Committee on Climate Change (CCC) formally advised that the ban be brought forward to achieve net-zero emissions by 2050, and just weeks after an election dominated by an environmental policy arms race between rival parties competing for the ever-growing climate-conscious vote. This meant that the change of date, as radical as it was, wasn’t wholly unexpected. The real surprise? Hybrids.

The decision to include hybrids and plug-in hybrids (PHEVs) in the ban came as quite a shock to many in the industry, not least for those who had, as recently as late 2018, been offered generous subsidies for these alternatives to dedicated ICE vehicles.

However, considering a series of studies reported that PHEVs could actually be emitting more CO2 than equivalent petrol-only cars due to extra battery weight, it seems to be a policy that has considered the real impact of hybrids and the scale of change needed for net-zero emissions by 2050.

Hybrids have played an important role by getting drivers used to electric motoring but with pure electric vehicles (EVs) approaching cost parity and achieving longer range, they are no longer needed as much as they once were.

Chris Stark, Chief Executive of the CCC, also pointed out that cars are typically on UK roads for 14 years, meaning a ban – inclusive of these polluting hybrids – must happen by 2035 in order to get them off the road in time for Net Zero by 2050.

2035 – what does it mean and how do we get there?

Despite being welcomed by environmentalists and authoritative organisations such as the CCC, a number of motoring groups and manufacturers have described the move as ‘a date without a policy’.

So, we have a date to focus our minds but what do we need to do to get there? Perhaps the most prominent criticism levelled at the new policy is that public charging infrastructure is not yet ready to cope with mass electric vehicle (EV) adoption.

However, this is far from the truth. The private sector has done a great job of developing a huge number of public-access EV chargers in populated areas. In fact, as of last year, there are more public-access EV charging points than petrol stations.

The industry is also rising to the challenge of creating a truly open-access network to give drivers the best possible experience. Regulation, due to come into force this spring, is primed to enshrine this interoperability between charging networks in law.

Yet an issue remains. While the more commercially viable areas of the country which benefit from higher customer demand – shopping centres, retail parks, supermarkets, car parks etc. – have been well served by the private sector, other, more rural, areas of the country with less customer demand naturally deliver less return on investment and are therefore less likely to attract private investment.

The result is under-developed infrastructure in these areas. This is where the government can give real substance to its new target. By offering direct support to these areas, in particular, we can ensure that the rollout of chargers is a strategically managed programme, aimed at enabling mass EV adoption in all areas of the UK.

The idea that there are virtually no public charging points to cater for EV owners is just one misconception that plagues the country’s efforts to develop an established EV market. That’s why a sustained effort to educate the general public on EVs is needed.

If the government is committed to achieving its 2035 target, it must take responsibility for dispelling myths – i.e. lack of charging points, misconceptions about charging behaviour, range anxiety etc. – and educating on benefits i.e. the ease of home charging, lower fuels costs, zero emissions, minimal maintenance and superior driving experience.

Supply and demand

Finally, and perhaps most frustratingly for early adopters of EVs, there is the issue of EV supply. There’s no doubt that demand for EVs is skyrocketing. In fact, the market for EVs is set to expand from 3.4% of all vehicles sold in 2019 to 5.5% in 2020. Despite this, drivers are often discouraged by long waiting times for new vehicles – something that’s severely inhibiting the growth of this burgeoning market.

To tackle this issue, and thus help meet the 2035 target, the UK must cultivate an attractive trading environment for EV suppliers. One effective way to do this is to encourage OEM investment in UK-based supply chains – namely battery Gigafactories.

This will keep costs down for OEMs by shortening supply chains for the UK market and make a compelling case for them to prioritise UK EV deliveries over other countries.

The 2035 target is no mean feat and we have certainly planted an ambitious stake in the ground. The industry has already done much of the hard work but only by continuing to implement meaningful actions and gaining government support in key areas can we give the new target real substance and credibility.


Our thanks to Air Quality News for permission to republish this article.

Further reading: more blog posts on electric vehicles