National Planning Framework 4 - draft: consultation analysis

Independent analysis of the responses to our consultation on the draft fourth National Planning Framework (draft NPF4), which ran from 10 November 2021 to 31 March 2022.

Executive Summary

This summary gives an overview of some of the key themes to emerge from the analysis of responses to the Scottish Government's consultation on the Fourth National Planning Framework (NPF4).

The consultation

The draft NPF4 was laid in Parliament on 10 November 2021 for Parliamentary scrutiny. Alongside Parliament's consideration of the draft NPF4, the Scottish Government invited comments from all stakeholders. The public consultation was launched on 10 November 2021 and closed on 31 March 2022.

The consultation asked 70 open questions.

In total 761 responses were analysed, with 539 responses from organisations and 222 from individual members of the public.

As with any public consultation exercise, it should be noted that those responding generally have a particular interest in the subject area and the views they express cannot be seen as representative of wider public opinion.

General Themes

Respondents raised some general themes that were not specific to any particular question.

A number of respondents commented on the inter-relationships between NPF4 and a range of other national, regional or local strategies or plans. Being clear about the relationship between NPF4 and these related strategies was seen as offering the best chance of success, with the quality of alignment seen as key.

In addition to some general statements in support of the inclusion of the National Policy Handbook within NPF4, comments included that greater clarity on the weight of the Universal Policies in relation to other policy areas would be helpful.

A frequently-raised issue related to the wording used across NPF4, including the frequent use of 'should'. It was suggested that this is ambiguous, and it is not clear where this means that the relevant policy must be complied with. Another frequent concern was around references to development being 'supported' or 'not supported', and there was a question as to whether this means that development is to be approved or not to be approved?

Part 1 – A National Spatial Strategy for Scotland

The national spatial strategy is themed around Sustainable, Liveable, Productive and Distinctive places.

Most welcomed recognition of the significance of the climate emergency for planning, including reference to the risk to ecosystems and the biodiversity crisis. However, some wished to see a stronger position taken on the climate emergency.

A number of the comments addressed the deliverability of Liveable places, with observations including that there is very little detail on how transformative social and economic change is going to be delivered. Respondents also commented on the importance of communities being empowered to be the key drivers of this change.

There was support for the focus on the just transition to net zero and a nature-positive economy. It was noted that the move to a greener economy could provide opportunities for business development, job creation and investment in communities, through community wealth building. In relation to rural, highland and islands settings, it was suggested that their distinctive socio-economic and market characteristics require a flexible, responsive approach to development, taking account of local context and need.

It was noted that the concept of distinctive places is already well embedded in the planning system and there were concerns around how high level strategy translates into the individual policies required for delivery. There was support for a stronger commitment to placemaking, although it was argued that, at present, the design-led approach and quality outcomes identified do not feed through into policy.

Spatial principles for Scotland 2045

The draft NPF4 sets out that, in order to build a climate-conscious and nature-positive future, our strategy and the policies that support its delivery are based on six overarching principles.

Although views were mixed, more respondents agreed that the spatial principles will enable the right choices to be made about where development should be located than disagreed. It was suggested that the spatial principles seem to encapsulate what NPF4 is seeking to deliver, including by recognising that a 'one-size-fits-all' approach would not be appropriate.

However, there was also a view that, as currently formulated, the spatial principles might not enable the right choices to be made. Related concerns included that the principles lack clarity and definition. There was a concern that it is not clear how this section is intended to be used by stakeholders of the planning system, what weight these principles will have, or how the spatial principles should or would inform consistent decision-making.

Compact growth was the spatial principle that most divided opinion. On the one hand, some respondents supported the approach set out, including by suggesting that it will be key to sustainable development. Other respondents raised fundamental concerns about this principle. These centred around a view that it is not always appropriate to allocate vacant and derelict land for development, and in particular to allocate derelict land for housing, as a priority over greenfield land.

Action areas for Scotland 2045

General comments included that the spatial strategy action areas provide a strong basis to take forward regional priority actions and that the draft NPF4 does appear to have identified appropriate priorities for different parts of the country. A contrasting view was that this section does not add to what can be delivered by NPF4.

One of the most frequently-raised issues was the relationship between the action areas and other spatial areas, with respondents most likely to comment on their connection to Regional Spatial Strategies. It was noted, for example, that considerable work has been put into the preparation of Indicative Regional Spatial Strategies but that the extent to which those have played a part in the preparation of the draft NPF4 is unclear.

A number of respondents thought that, rather than creating new action areas, it might be clearer if Regional Spatial Strategy areas were used as the spatial expression of policy approaches.

Another frequently-raised issue was the relationship between the action areas and local authority boundaries, with concerns raised about some local authorities being split between different action areas.

North and west coastal innovation

General comments included that there is potential for conflict between the different strategic actions proposed for the North and west. In relation to creating carbon neutral coastal and island communities, the recognition that island and coastal communities will need a bespoke and flexible approach to the concept of 20-minute neighbourhoods was welcomed.

Four strategic actions were included for the North and west coastal innovation action area. With reference to reversing population decline, there were questions about the viability of reintroducing people to previously inhabited areas. There was a call for existing communities to be supported prior to the development of projects aimed at reintroducing people to areas that are not currently inhabited.

Northern revitalisation

A number of comments suggested that there is a great deal of crossover between the Northern and North and west action areas. Some respondents proposed combining of the Northern and North and west action areas.

Four strategic actions were included for the Northern revitalisation action area. There was support for the reference to the importance of renewable energy generation for climate mitigation, and the need for the repowering and extension of existing wind farms. However, there were also calls for clarity on what approach will be followed for new wind farm proposals.

North east transition

A general comment was that the North east action area is very much focused on the energy transition, but that there is much more to this region. A connected concern was a view that there is a lack of ambition, vision and understanding of the region.

Four strategic actions were included for the North east transition action area. General comments about the transition to net zero (Action 9) included that it is applicable to whole of Scotland. There was also a call for the action to reflect the potential of the entire north-eastern coastline.

Central urban transformation

Although there were some broad statements of support, a number of respondents raised concerns about either the size of this action area, or the diversity of the communities and places that it covers. There was a particular concern that there is a strong urban focus, and that the challenges and opportunities identified, along with the strategic actions, are not relevant to the significant rural population.

Nine strategic actions were included for the Central urban transformation action area. It was noted that realising a number of the strategic actions will require a regional and catchment scale approach and that the role of the Regional Spatial Strategies to spatially coordinate activities and guide delivery at scale and across authority boundaries, will be key.

Southern sustainability

There was a concern that this action area is not ambitious enough and needs to better reflect the realities of the region. In addition to generally making the language more proactive, it was suggested that the region's contribution to achieving net zero, along with the economic ambitions of the region, should be referenced.

Four strategic actions were included for the Southern sustainability action area. General comments included that the strategic actions could also be more ambitious. Regarding innovating to sustain and enhance natural capital, there was reference to the UNESCO Biosphere and its role in delivery of ecosystem services.

Overall views on this proposed national spatial strategy

General comments included offers of support, or support in principle, for the aims of the proposed national spatial strategy. Others, however, suggested that the national spatial strategy is unclear and that it will need significant refinement and expansion if it is to become a useful element in the Local Development Plan (LDP) for any particular area.

Other comments included that the spatial strategy would be helped by indicating the important relationships with other plans, programmes and policies which are fundamental to delivering the overall ambitions.

In terms of how well the spatial strategy considers the needs of Scotland as a whole, it was suggested that the spatial strategy needs to be more consistent across the regions and recognise the links and interdependencies between them. It was also thought that the spatial strategy and action areas could do much more to address the disparities and inequalities between communities across Scotland.

One perspective was that there is an emphasis on urban needs, with not enough support for the rural parts of Scotland. There was specific reference to the national ambition for appropriate rural repopulation and to considering the needs of remote communities.

An alternative perspective was that there is insufficient emphasis given to urban areas, and a lack of differentiation around towns and cities, which have different requirements and different needs.

National Developments

A number of issues were raised in relation to the implications of national development status, including suggestions that it should carry a presumption in favour of planning consent. It was also suggested that guidance will be needed with respect to how to balance the competing priorities of different national developments, and that it would be helpful to explain how national developments might interact with Regional Spatial Strategies and the NPF4 action areas.

In relation to the selection of national developments, it was suggested it would be helpful to set out the rationale for selecting those chosen and why some are conceptual, and others are existing proposals.

Although respondents were not asked directly, a number did comment on whether they supported some or all of the national developments proposed. A small number of respondents simply offered overall support for all of the national developments, while others referenced their particular support for one or more of them. There were also a number of respondents who appeared to support the overall theme of a national development, but then went on to raise a number of issues or concerns about the national development as currently described. Some of the issues raised related to the location of the national development and were sometimes focused on it being expanded to other parts or all of Scotland. Others were focused on one or more of the classes of development as currently described.

National developments to deliver sustainable, liveable places

Six national developments are set out under delivering sustainable, liveable places.

In relation to the Central Scotland Green Network (CSGN), there was a view that NPF4 should more clearly set out how its delivery will be aided through planning. Greater detail and more guidance on how LDPs and spatial strategies should be used to articulate and deliver national developments was suggested. There were also calls for the CSGN network to be expanded to be a Scotland-wide national development, or for the creation of a Scottish Nature Network.

Inclusion of a National Walking, Cycling and Wheeling Network (NWCWN) as a national development was welcomed, although it was also argued that it has limited applicability for reducing routine car journeys in rural Scotland. The importance of investment to deliver the network was highlighted, including a view that significant infrastructure investment, over and above existing budgets, will be required.

Comments in relation to Urban Mass/Rapid Transit Networks included that this national development should be extended to be a Scotland-wide development. The need for stronger public transport connectivity in rural areas was highlighted and it was suggested that a joined-up strategy should take account of new active travel routes as part of a NWCWN.

While the Urban Sustainable, Blue and Green Drainage Solutions national development was welcomed, it was also argued that the principles apply beyond Glasgow and Edinburgh and should be extended to other cities and urban areas, or should be a Scotland-wide national development.

Some respondents expressed support for the Circular Economy Materials Management Facilities national development, including a view that materials facilities could play a significant role in delivering greater sustainability in the construction and demolition industries. There was also a call for clarity around how this national development will be delivered to avoid unintended outcomes.

Comments on the Digital Fibre network were largely limited to expressions of support. The importance of connectivity was highlighted in relation to remote access to services, Mobility as a Service, and reducing unnecessary travel.

National developments to deliver sustainable, productive places

Seven national developments are set out under delivering sustainable, liveable places.

General comments on the Islands Hub for Net Zero included that it is not clear why net zero projects are national developments only if they are proposed in the Western Isles, Shetland and Orkney Island groups, and that consideration should be given to their support more widely. It was also suggested that this national development has the potential for significant impacts on nature and that it will be essential that development can be assessed for impacts on nature, in particular the cumulative effects on Special Protection Areas and marine mammals.

Industrial Green Transition Zones were welcomed, although it was also suggested that Aberdeen, Sullom Voe, Opportunity Cromarty Firth and industrial and service bases within the Inner Moray Firth should be added. Carbon capture and storage (CCS) was considered by some to have a crucial role in decarbonising industry. However, other respondents expressed opposition to the production of blue hydrogen, and it was argued that the use of CCS should not be supported.

Comments in relation to Pumped Hydro Storage included that it should not be described as 'all Scotland' in view of the specific requirements of topography and landform. There was a view that prioritising Cruachan pre-judges delivery timelines for other schemes and it was argued that all pumped hydro storage above 100 megawatts (MW) in capacity should be considered as a national development.

Regarding the Hunterston Strategic Asset national development, it was suggested it would be helpful to reflect the national scale of opportunity of a blue economy centred at Hunterston. The need for careful planning was highlighted in relation to potential negative effects on a number of nationally important natural assets.

Comments in relation to Chapelcross Power Station Redevelopment included that there should be a greater emphasis on renewable energy to take advantage of the transmission lines and national grid infrastructure. Other points related to protection of the natural environment including that retaining and enhancing an extensive area of nature-rich unimproved grassland will provide benefits for the local community.

Strategic Renewable Electricity Generation and Transmission Infrastructure was the national development that attracted the highest level of comments. Although aspects of this national development were welcomed, some respondents called for clarity that, in the planning balance, there should be significant weight attached to development that contributes directly to achieving net zero. The requirement that renewable energy generation developments should exceed a threshold of 50MW capacity in order to qualify for national development status was questioned. An alternative view was that the threshold should be raised, since the benefit of large-scale projects can clearly be seen to be of national importance.

While High Speed Rail was supported, comments often related to areas of the country that will not benefit from current proposals with references to southern Scotland, Dundee, Aberdeen, and Inverness. Other points raised included that the relationship with second Strategic Transport Projects Review recommendations should be set out, including the need for further work to determine the future of high-speed rail in Scotland.

National developments to deliver sustainable, distinctive places

Five national developments are set out under delivering sustainable, distinctive places.

National development status for Clyde Mission was welcomed, including as aligning with the Glasgow City Region Climate Adaptation Strategy. It was suggested that combining this national development with the Urban Sustainable Blue and Green Drainage Solutions national development would help the area adapt to the impacts of climate change. It was also argued a proportionate response to flood risk is required, recognising both the hazards posed by different types of flooding and that different approaches may be acceptable, depending on the nature of the risk.

Comments on Aberdeen Harbour included that the area to which the designation applies is unclear and that greenfield land near the south harbour should be explicitly excluded. There were also calls to reference delivery of the proposed Energy Transition Zone and to broaden the national development to reflect the Freeport zone being considered.

Continued designation of Dundee Waterfront as a national development was welcomed. However, a shift in emphasis from economic revitalisation to include a more balanced place-based aspiration for Dundee Waterfront was suggested. The opportunity to create an outstanding and strategically important vibrant green and blue space that could serve as a regional hub and catalyst for a Tayside green and active travel network was highlighted.

General comments on Edinburgh Waterfront included that there should be read across to the CSGN, NWCWN and Urban Sustainable, Blue and Green Drainage Solutions national developments. It was argued that a focus on Leith to Granton needs to be set in the context of the wider coastal environment and that the potential for negative effects on landscape and seascape need to be addressed.

In relation to the Stranraer Gateway, it was suggested that there should be a greater focus on quality of life, wellbeing and sustainability, and that 20-minute neighbourhoods, blue-green infrastructure and active travel should be considered.

Part 3 - National Planning Policy Handbook

The National Planning Policy Handbook sets out 35 policies. Across the policies, there were frequent requests for greater clarity, including through the inclusion of definitions of key terms and/or by providing further information or guidance. There were also a number of references to polices being strengthened, including by requiring, rather than permitting, their application. This latter point was often connected to the more frequent use of 'must', rather than 'should'.

NPF4 set out six Universal Policies (Policies 1-6) that should apply to all planning decisions. There were a number of comments about how the application of these policies relates to the application of other NPF4 policies, and in particular whether the Universal policies are expected to take precedence.

Policy 1 – Plan-led approach to sustainable development: Most of those providing comment expressed their support for a plan-led policy approach, and the role of LDPs in guiding use and development of land in the long-term public interest. However, some questioned the value of Policy 1 as currently drafted, taking a view that it does not add significantly to requirements already set out in legislation.

Policy 2 – Climate emergency: In relation to all development proposals giving significant weight to the Global Climate Emergency, most of those commenting supported this policy objective. Respondents suggested that transformational change is required across the planning system, and some felt that the policy is not strong enough to deliver this change. Not supporting development proposals that will generate significant emissions unless it is proven that the level of emissions is the minimum that can be achieved was seen as vital to ensuring that planning can contribute to climate change and nature recovery.

Policy 3 – Nature crisis: There was support for recognition of the nature crisis within NPF4 and for the emphasis on improving biodiversity. One perspective was that the policy should be strengthened further and should require planners to give significant weight to the nature crisis when considering development proposals. An alternative view was that the approach should be more flexible, or more proportionate to the type and scale of development proposed.

Policy 4 – Human rights and equality: Some respondents described NPF4 as an opportunity to build on existing legislation, while others suggested that it is not an appropriate vehicle to meet human rights and equalities duties. It was also suggested that respect for human rights and promotion of equality should be considered across all parts of NPF4, rather than being limited to a single policy.

Policy 5 – Community wealth building: There were some concerns that 'community wealth building' is not a well understood concept, including reference to differing interpretations across planning authorities and other stakeholders. It was also suggested that the policy lacks sufficient detail to ensure effective and consistent implementation. There were calls for practical examples of how development plans, and the planning system as a whole, can support community wealth building.

Policy 6 – Design, quality and place: The focus on ensuring good quality design and the importance of design for quality placemaking was welcomed, although some suggested that considerations of viability and delivery can often over-rule quality of design. The reference to 'high quality' design was seen as by some as too subjective and it was suggested that further detail is required to support a clear and objective approach to design, and to ensure consistency across planning authorities.

Policy 7 – Local living: Most of those commenting on Policy 7 saw a need for further detail on how the principle of 20-minute neighbourhoods can be applied across the diverse urban and rural areas of Scotland. Many commented that the policy seems to apply primarily to urban and accessible areas, and there was some scepticism as to whether the principle of 20-minute neighbourhoods can be applied meaningfully to rural areas.

Policy 8 – Infrastructure first: Some respondents expressed their support for the infrastructure first approach, including supporting delivery of the infrastructure required by 20-minute neighbourhoods, providing an opportunity to improve active travel infrastructure, and reference to the importance of energy and other infrastructure for delivery of carbon reduction targets. It was suggested that effective delivery will require significant investment, both in terms of strategic infrastructure investment, and ensuring sufficient resourcing of the planning system.

Policy 9 – Quality homes: Aspects that respondents liked included that there is more of a focus on deliverability and that the overall approach has the potential to reduce the variety of approaches taken across planning authorities. A different perspective was that as drafted the policy contains a range of definitive statements, which if taken on their own, could be used to justify inappropriate development.

A number of respondents noted the lack of reference to Housing to 2040, and there was a concern that it is not clear how NPF4 links to its ambitions. There were also a range of concerns relating to the setting of Minimum All-Tenure Housing Land Requirements (MATHLR) and to managing the Housing Land Pipeline. A number of respondents also raised concerns about the lack of priority given to the housing needs of older and disabled people.

Policy 10 – Sustainable transport: Most of those commenting supported the principle and overall direction set out, although there were concerns that some parts may not be workable in rural and island communities. There were also calls for clearer financial commitments to provide the investment required to support the policy, especially around active travel and public transport infrastructure, and achieving a modal shift from private car use.

Policy 11 – Heating and cooling: There was reference to the contribution that this policy can make to the decarbonisation of heat. Reference was made to the Heat in Buildings Strategy, and there were calls for greater consideration of the affordability of zero emission heating and cooling, for example through links to the Fuel Poverty Strategy. Others raised issues regarding the potential scale of resources required, for example in the assessment of technical proposals.

Policy 12 – Blue and green infrastructure, play and sport: Most respondents were supportive of the policy, although it was suggested that 'blue and green infrastructure' should be separated from 'play and sport'. Some respondents addressed the issues of 'overall integrity' and 'net loss' and there were concerns that if small amounts of fragmentation are allowed, over time the impact will be cumulative.

Policy 13 – Sustainable flood risk and water management: While most respondents agreed with the overall ambition of developing transformative approaches to future flood risk management, some were concerned about gaps that could undermine the policy aims. Other general concerns included that Policy 13 only addresses future development, whereas strategic, solution-based approaches are needed for areas already at risk of flooding.

Policies 14 and 15 – Health, wellbeing and safety: There was support for health and wellbeing being part of the planning process, and an appreciation that the planning system could do more to support healthier places and tackle health inequalities. Some were looking for an explicit statement that development proposals detrimental to active lifestyles and wellbeing will not be supported.

Policy 16 – Business and employment: There were mixed views on the policy. While there was general support for its ambitions, including the linking of investment with the transition to net zero and supporting a nature positive approach, there were concerns that the policy, as it currently stands, will not achieve its aims. There were calls for guidance on how critical aspects of the policy, such as net economic benefit, could be demonstrated and assessed.

Policy 17: Sustainable tourism: Whilst most respondents recognised the importance of sustainable tourism and supported the key principles set out, there were mixed views about the proposal that LDPs should be used to support the tourism sector and identify proposals for tourism development.

Policy 18 – Culture and creativity: Many respondents welcomed the inclusion of a specific policy covering culture and creativity, including because of the recognition this gives to our important and diverse creative and cultural sector. However, some were concerned that the policy silos culture, and does not embrace the ways in which cultural activities can support the delivery of other NPF4 policies.

Policy 19 – Green energy: Respondents were relatively evenly divided between those who thought the policy will meet the stated objectives and those who thought it would not. It was argued that it lacks detail on how the planning system should support renewable energy development or the implications of such an approach where a range of planning considerations need to be balanced.

Some respondents considered that, in the absence of a development management test that recognises the status of the climate emergency and the national importance of renewable energy developments, much of the approach will be 'business as usual', while others argued that Policy 19 could potentially represent a backward step.

Policy 20 – Zero waste: In terms of an overall balance of opinion, respondents tended to support the policy. However, there were calls for a stronger focus on developing a circular economy. Reuse of existing buildings was highlighted as an important element of the circular economy that currently has limited coverage. Suggestions included that it might be preferable to draft a circular economy policy, with zero waste as a component part, or that a standalone circular economy policy would allow many other aspects to be explored more fully.

Policy 21 – Aquaculture: Most of those commenting supported the focus on the sustainability of aquaculture, including minimising environmental impacts. Some suggested that the policy is too focused on supporting investment and does not give sufficient priority to the environment. Others suggested that the policy could be more supportive of growth in the aquaculture industry and wanted to see new aquaculture activities supported by the planning system.

Policy 22 – Minerals: Reasons given for supporting the policy included the need to ensure an ongoing supply of minerals and that, without a steady and adequate supply, the delivery of housing, infrastructure, other developments and manufacturing cannot be assumed. Others had broad concerns, including that there does not appear to be an assessment of the level of need for the products extracted. There was a call for more emphasis on minimising the use of new minerals in line with the principles of a circular economy.

Policy 23 – Digital infrastructure: Most supported the focus on ensuring all of Scotland's places are digitally connected and felt that the policy provides a positive framework against which delivery of digital infrastructure can be assessed. There was also support for the particular focus on areas with no or low connectivity. Respondents highlighted the importance that all parts of Scotland have access to suitable digital infrastructure, with reference to the negative economic impacts of poor digital connectivity, particularly in rural areas.

Policies 24 to 27 – Centres, retail, town centre first assessment and town centre living: There were positive comments on the role of LDPs in creating sustainable futures for cities, towns and local centres, alongside the principles of 20-minute neighbourhoods. There was also support for the focus on town centres and the recognition of their importance in many aspects of placemaking, health and quality of life. The further restrictions on out-of-town shopping proposals were also supported.

Policy 28 – Historic assets and places: Many respondents welcomed the protection and enhancement of the historic environment, and there was support for the reuse of redundant or neglected historic buildings. However, there were also concerns that the policy could prevent developments that address climate change issues from going ahead.

Policy 29 – Urban edges: There was general support for the policy, with respondents welcoming the use of green belts to help regulate development outside urban centres and limit urban expansion. However, some respondents had concerns, including that it refers to the green belt. The connected concern was that this may encourage planning authorities to adopt a brownfield-only approach.

Policy 30 – Vacant and derelict land: There was broad support for this policy, which was seen as critical to protecting greenfield land and the reuse of underused land. A number of respondents noted the challenges associated with the reuse of vacant and derelict land and buildings, including around costs limiting the market's ability to develop sites. It was noted that public sector investment is often required, and also that many of the more straightforward sites have already been developed, with those remaining generally needing more significant remediation.

Policy 31 – Rural places: Some respondents welcomed the inclusion of a policy specifically for rural places or indicated support for the intent and ambitions set out. However, it was also suggested that the policy is too broad, or that the support for new development in rural areas risks undermining sustainability and climate change objectives. There was also a view that, as drafted, the policy will not deliver the outcome of increasing the population of rural areas.

Policy 32 – Natural places: Respondents were relatively evenly divided between those who broadly supported the policy and those who sought extensive changes. There were calls for a greater focus on protecting all biodiversity, following the mitigation hierarchy and stronger, plan-led action. With respect to the relationship between Policy 32 and other parts of NPF4, comments included that the fit with Policy 3 (Nature crisis) is unclear and that there are significant inconsistencies with Policy 19 (Green energy). There were also calls for linkages to be made between this policy and the Biodiversity Strategy.

Policy 33 – Peat and carbon rich soils: There was broad support this policy, although some thought it should go further in protecting peatlands. It was suggested that it should be strengthened in terms of peatland restoration and that a proactive approach to restoration should be adopted. In terms of development on peatland, some argued that, as drafted, there are too many exceptions or too much leeway for developers. Other respondents welcomed the absence of a blanket ban on development.

Policy 34 – Trees, woodland and forestry: General comments included that the acknowledgement of the importance of trees and woodland in meeting climate targets and reversing biodiversity loss is welcome. It was also suggested that the protections provided could be strengthened further, and the importance of preserving native woodland was emphasised. An alternative perspective was that proposed protections go too far in protecting woodland at the expense of development needed to deliver net zero.

Policy 35 – Coasts: Respondents tended to support the policy, although there were concerns that the emphasis is on the immediate and short-term climate change risks at the coast. Respondents were looking for more of a focus on protecting the marine environment, restoring blue carbon habitats as a nature-based solution and on creating and supporting sustainable coastal communities.

Part 4 – Delivering Our Spatial Strategy

A number of respondents commented that a delivery plan would have been helpful to support the draft NPF4. The importance of the delivery strategy was highlighted, including to provide confidence to all sectors involved in the built environment and to demonstrate that the relevant actions, mechanisms, and responsibilities are clear.

It was agreed that a collaborative approach that aligns interests will play a central role in delivering the spatial strategy. It was described as a crucial aspect of how a radical and ambitious strategy can be effectively delivered by the practitioners tasked with management and delivery.

There was broad agreement that monitoring will be an essential part of the NPF process, and also that it will be a significant and challenging undertaking. In terms of overall responsibilities, it was suggested that monitoring of NPF4 should be led and undertaken by the Scottish Government as the coordinating authority.

Part 5 – Annexes

Annex A – NPF4 Outcomes statement

In terms of development under NPF4 contributing to the six statutory outcomes identified in the Town and Country Planning (Scotland) Act 1997, there was a call for stronger emphasis on the delivery of sustainable development. It was also suggested that the delivery of statutory outcomes should be integrated with other NPF4 components, such as the four spatial strategy themes and the six spatial principles.

There was particular support for the inclusion of health and wellbeing as a statutory outcome for NPF4, as well as for the focus on increasing the population of Scotland's rural areas. However, there were concerns that the draft NPF4 does not provide a sufficiently comprehensive or detailed framework to address the priorities of Scotland's rural areas.

Annex B – Housing numbers

With regard to the MATHLR numbers set out, the majority of 'Local Authority' respondents reported that the Scottish Government took an inclusive approach to arriving at MATHLR numbers and that they agreed with the MATHLR for their area.

However, other respondents raised significant concerns, including that the methodology and Housing Need and Demand Assessment tool used to inform the MATHLR figures are inadequate and flawed. There was also reference to a lack of ambition, with alternative and higher MATHLR figures suggested for some Local Authority areas. In contrast, some respondents considered that the approach to the MATHLR has artificially inflated housing figures and has not taken account of population declines.



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