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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Putting the green back into planning policy

By Morwen Johnson

Environmental issues weren’t at the forefront of the recent general election – analysis by Loughborough University showed that the environment, despite being a significant issue of public concern, received very little attention in the press or media coverage. So it’s pleasing to see that a number of think tanks and organisations have recently been highlighting the importance of a green perspective in spatial policy.

Greening spatial policy

Professor Deborah Peel and Professor Greg Lloyd (reviewing some of these reports in the latest issue of Scottish Planning and Environmental Law Journal) suggest that the debate in the UK over housing supply is transforming the prevailing view of land assets and the green economy. Combined with European Union-led arguments for greater sensitivity in protecting and enhancing green infrastructure, it would seem that the planning profession need to urgently consider whether (and how) to defend established concepts such as green belts.

Ensuring that the planning system is robust also appears to be a critical task if you look at the challenges of implementing alternative energy solutions, when the national agenda and local public opinion seem to be at odds. The news this week that Lancashire County Council has rejected a major fracking application is just one example. This decision was despite the application having been recommended for approval by planning officials, subject to working hours, noise control and highway matters. The question of green belt development is also becoming increasingly polarised, when what we need is nuanced consideration of the social and economic consequences of changes to planning policy.

Where does rural planning fit?

The RTPI is attempting to stimulate debate. Last year’s project on Promoting Healthy Cities highlighted that the environment in which we live, work and spend our leisure time has a huge impact on our wellbeing. In the policy world however, the rural dimension and rural communities can be forgotten. The focus can easily slip into unquestioning preservation of a (fictional) idyll. This ignores fundamental rural issues such as poverty, social exclusion, access to affordable housing, accessibility of services, and the need for economic diversification. It also assumes a clear distinction between urban policy and rural policy, when in fact there are strong urban-rural interdependencies.

Concluding their article, Peel and Lloyd argue that “it’s time we engaged proactively with some of the ideas around different governance arrangements and interventions for our green infrastructure and developed a stronger appreciation of green assets for the 21st century”. As a profession, planners need to take the lead in developing a rural vision which is modern and fit for purpose. The risk if we don’t is that the green planning agenda will be driven by politics not policy.


Further reading

A green policy agenda? Greg Lloyd, Deborah Peel IN Scottish Planning and Environmental Law, No 169 June 2015, pp52-53

Improving public space debates Greg Lloyd, Deborah Peel IN Scottish Planning and Environmental Law, No 167 February 2015, p 4

The green belt: a place for Londoners. (2015) London First

Greening the machinery of government: mainstreaming environmental objectives. (2015) WWF-UK

Places to be: green spaces for active citizenship. (2015) Fabian Society

Garden villages: empowering localism to solve the housing crisis. (2015) Policy Exchange

City villages: more homes, better communities. (2015) ippr