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.

Annex A – NPF4 Outcomes statement

Annex A sets out how the Scottish Ministers consider that development under NPF4 will contribute to each of the six statutory outcomes identified in Section 3A(3)(c) of the Town and Country Planning (Scotland) Act 1997.

Question 56: Do you agree that the development measures identified will contribute to each of the outcomes identified in Section 3A(3)(c) of the Town and Country Planning (Scotland) Act 1997?

Around 175 respondents made a comment at Question 56.

Some of these expressed their support for the overall policy direction and development measures set out by the draft NPF4, and agreed that these will contribute to the delivery of statutory outcomes. However, most of those commenting raised issues or suggested amendments to better support delivery of such outcomes.

This included views that the policies set out in the draft NPF4 will not result in a significant change in the character of development in Scotland, and specific concerns that it does not give sufficient weight to climate change and biodiversity. Stronger emphasis on the delivery of sustainable development was requested. While there was support for what was described as a positive policy framework, respondents suggested that the policies set out in the document are open to interpretation, and do not include sufficient detail to ensure effective delivery.

There were also calls for this part of NPF4 to be expanded to include other relevant outcomes and targets. Specific suggestions included reference to relevant UN Sustainable Development Goals and their targets, National Performance Framework outcomes, and other duties under the Town and Country Planning (Scotland) Act 1997. It was also suggested that the delivery of statutory outcomes should be integrated with other NPF4 components, such as the four spatial strategy themes (Sustainable places, Liveable places, Productive places, and Distinctive places) and the six spatial principles for Scotland 2045. This reflected concern around a perceived lack of integration across other parts of NPF4, such as between the Action Area regional priorities and National Developments. Some respondents wished to see the outcomes section expanded to map the relationship between all components, and how these address delivery of the statutory outcomes.

Respondents also reiterated concerns raised at earlier questions that delivery against the statutory outcomes will require significant resources and investment. This included concern around the required resourcing of the planning system (with reference to Heads of Planning Scotland's estimate that 700 additional planners will be required over the next 15 years), and investment in infrastructure. There was also reference to the need for coordinated action across a range of stakeholders to ensure delivery of NPF4's ambitions, and a view that more work is required to provide clarity on the role of various stakeholders. Overall, it was suggested that there is a delivery gap between ambitions and policies, and realisation of the statutory outcomes.

The next section of the analysis considers comments on each of the six statutory outcomes in turn.

a) meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people

Respondents expressed support for the role of NPF4 in meeting housing needs, and in particular the housing needs of older people and disabled people. This included citing evidence illustrating the potential scale of older people's housing needs. However, while some agreed that the draft NPF4 will make a contribution to this outcome, most of those providing comment suggested that the measures will not be sufficient to meet housing needs. There was a view that revision to the stated policies is required to ensure housing needs are met.

Many of those raising concerns around delivery of outcome (a) referred back to responses to earlier questions and/or reiterated points raised in relation to Policy 7 (Local living) and Policy 9 (Quality homes). References to Policy 9 most commonly related to concerns that:

  • NPF4 will not deliver sufficient affordable quality housing.
  • The MATHLR assessment approach is not fit-for-purpose.
  • Specific MATHLR estimates are too low in some areas.
  • The HNDA tool does not identify the full range of housing needs.
  • There is a lack of clarity around how a deliverable housing land pipeline will be established.

Respondents also reiterated concerns around how the concept of 20-minute neighbourhoods will apply across the diversity of urban and rural areas, considered in further detail at Policy 7 (Local living).

Other issues raised in relation to outcome (a) included a view that the draft NPF4 does not give sufficient emphasis to the quality and inclusiveness of housing, including in terms of: wheelchair accessibility; the needs of older people; self-build; co-housing; and Houses of Multiple Occupation. Some respondents saw a need to provide stronger direction to ensure that the full range of housing needs are met. It was suggested that older people's housing needs have not been sufficiently integrated within NPF4, and that its policies do not provide a clear framework for planning authorities to assess and meet such needs.

It was also suggested that:

  • NPF4 needs to provide a mechanism to identify new housing allocations if such a need arises.
  • There should be more reference to the importance of existing buildings in meeting housing needs, including delivery of net zero targets.
  • The 'brownfield first' approach may be too restrictive to meet housing needs, including the needs of older people and disabled people.
  • The draft NPF4 does not recognise the spatial factors in how and where housing needs are likely to be met. It was also suggested that it should include positive support for rural housing that meets housing needs, and fits with landscape and settlement patterns.

b) improving the health and wellbeing of people living in Scotland

There was support for the inclusion of health and wellbeing as a statutory outcome for NPF4, recognising the important role of the planning system for health and wellbeing. There was also support for the role of 20-minute neighbourhoods in relation to health and wellbeing. However, there was also a view that the development measures identified will not be sufficient to deliver outcome (b).

Many responses referred back to answers at earlier questions, or reiterated points raised in relation to Policy 14 (Health and wellbeing). This included:

  • Calls for clarity on the approach to health inequalities and the assessment of health impacts.
  • Reference to the role of planning in provision of healthcare services.
  • Issues around air quality and noise.
  • Calls for greater reference to the food environment.
  • Reference to the importance of design and quality of places.

There were concerns that the policies relating to these issues are not strong enough.

Other issues raised in relation to the delivery of health and wellbeing outcomes included calls for NPF4 to highlight links between outcomes (a) and (b), noting the importance of access to a warm and safe home for health and wellbeing. There was concern that development measures relating to outcome (b) do not address health and wellbeing issues related to existing housing and areas of deprivation, and a view that NPF4 will not improve the environment in which the majority of Scotland's population live. Respondents also saw a need for greater emphasis across NPF4 on active travel and supporting people to be more physically active.

c) increasing the population of rural areas of Scotland

Comments on outcome (c) included approval for the focus on increasing the population of Scotland's rural areas, and some responses highlighted the need to address social and economic challenges for rural communities. However, respondents also felt that NPF4 policies will not be sufficient to deliver this outcome, reflecting a view that the draft NPF4 does not provide a sufficiently comprehensive or detailed framework to address the priorities of Scotland's rural areas.

Many of these comments reiterated issues raised earlier in relation to Policy 31 (Rural places), reflecting a view that it lacks ambition for the sustainability of rural communities and does not give sufficient weight to delivery of sustainable growth across rural economies. Other issues raised in relation to outcome (c) included that providing housing is a fundamental part of rural repopulation, and that Policy 31 should more fully support appropriate housing development where it meets local need.

It was also suggested that NPF4 needs to recognise that rural areas operate differently to urban and suburban areas and therefore require a more flexible and specific approach to planning policy.

There were also concerns relating to:

  • The resettlement of previously inhabited areas and reuse of vacant and derelict land.
  • The absence of an allowance for windfall housing development within accessible or pressured areas.
  • The delivery of 20-minute neighbourhoods in rural areas.

The importance of public transport for rural repopulation was highlighted, as were issues around delivery of digital infrastructure across diverse rural places and the funding and investment required.

Respondents also highlighted the need for investment in jobs, economic opportunities and transport alongside delivery of development to support population increase. It was suggested that NPF4 does not do enough to demonstrate that this will be delivered. This included specific concerns that the draft NPF4 does not do enough to address challenges around delivery of sustainable transport and active travel in rural areas. There were calls for clearer links to be drawn between outcome (c) and Policies 7 (Local living) and 10 (Sustainable transport). However, others saw potential for some NPF4 policies – such as Policies 7 and 8 (Infrastructure first) – to hinder rural repopulation.

It was suggested that a new planning tool is required to deliver community-led rural repopulation, including additional development classes and designations. This included suggestions for a specific focus on issues around second homes in rural areas, and a role for assets of community value.

d) improving equality and eliminating discrimination

Several respondents agreed that the policies set out by the draft NPF4 will help to improve equality and eliminate discrimination. However, there was a view that NPF4 could do more to emphasise the cross-cutting nature of equalities considerations, and that all NPF4 policies should identify how they will support outcome (d). It was also described as disappointing that there is not currently a specific Human Rights Impact Assessment.

In connection to Policy 4 (Human rights and equality) there was a question as to whether human rights and equality need to be development plan policies within NPF4 as they are addressed elsewhere in statute.

Comments about Policy 5 (Community wealth building) included that there should be guidance on how this can be fully delivered, including examples of what 'socially productive use of land and property' looks like. It was suggested that it should be about maximising land and assets to support the wider regeneration of communities, but that the policy focus appears to be more on the economics of community wealth building rather than quality of life.

In relation to housing (as covered under Policy 9: Quality homes) it was noted that, although housing is referenced as a human right in Housing to 2040, there is no reference to this within NPF4 or any of the supporting documents. There were also calls for communities to be given the right to appeal against planning decisions which are contrary to LDPs, Local Place Plans, and/or NPF4.

Other issues raised in relation to delivery of outcome (d) included calls for NPF4 to do more to ensure that equality principles are applied to all statutory outcomes, and other components of the framework. It was argued that both the Public Sector Equality Duty and the Fairer Scotland Duty should be better acknowledged and embedded in NPF4, ensuring these apply across all parts of the planning system. This included specific calls for equality to be a strategic priority for LDPs and planning decisions, and for outcome (d) to be a guiding principle for NPF4 alongside climate change and nature recovery. Some also felt that NPF4 could do more to address disparities and inequalities between Scotland's communities, including between urban and rural areas. Respondents also highlighted the importance of monitoring and evaluation to ensure that equalities standards are being upheld.

e) meeting any targets relating to the reduction of emissions of greenhouse gases

Several respondents expressed their approval for the approach to emissions reduction set out in the draft NPF4. These respondents felt that the spatial strategy sets a positive tone for delivery against emissions reduction targets. However, there were also concerns around the scale of change required to achieve the targets. It was suggested that NPF4 will not make a substantial enough contribution to delivery of climate targets, and that the policies set out do not represent an enabling policy framework to support delivery. There was a related view that tackling climate change should be an overarching aim across all NPF4 policies.

Issues raised specifically in relation to Policy 2 (Climate emergency) included concerns that Policy 2 is not strong enough to deliver the required transformational change, and that NPF4 does not go far enough to ensure planning systems take action to embed climate mitigation and adaptation measures into developments. Further comments included that:

  • Some of the measures required may be matters that should be addressed through changes to Building Standards.
  • It is not clear how the 'significance' of emissions will be measured - whether relative to the scale and type of development (and a matter of qualitative judgment) or a fixed threshold?
  • With reference to the circular economy, there is insufficient advice and guidance available to business and local authorities to fully understand and plan for this going forward.

There were also calls for greater support for delivery of renewable energy generation and infrastructure development. Respondents reiterated concerns raised in relation to Policy 19 (Green energy) that the measures set out could hinder renewable energy development and will fail to deliver against targets set out in the draft Onshore Wind Policy Statement.

Concerns were also raised in relation to the inclusion of the Grangemouth Investment Zone in ND8, and around potential use of bioenergy to decarbonise Grangemouth. Links between emissions reduction and improved biodiversity were also highlighted, including the importance of nature recovery in maximising potential to absorb carbon. There were calls for NPF4 to take a single, co-ordinated approach to delivery of climate and nature/biodiversity outcomes.

f) securing positive effects for biodiversity

Respondents expressed support for the role of NPF4 in securing positive effects for biodiversity, and the prominent role given to biodiversity. However, the concerning scale of biodiversity loss in Scotland was also highlighted, and some were of the view that the wording of NPF4 should be strengthened to ensure that the opportunity to deliver positive effects for biodiversity is not missed.

There was also concern that the summary of Policy 3 (Nature crisis) provided at Annex A ('…that development plans and proposals that contribute to the enhancement of nature networks should be supported in principle') is not an accurate representation of the policy as set out in the draft NPF4. Other concerns reflected issues raised earlier in relation to Policy 3. There was a view that Policy 3 needs to be strengthened through a requirement for planning decisions to give significant weight to the nature crisis. There were also calls for further clarity around how LDPs and development proposals should facilitate biodiversity enhancement, including concern regarding the focus on restoration and how development proposals can minimise biodiversity and nature impacts.

Comments also highlighted the role of Policies 12 (Blue and green infrastructure, play and sport), 32 (Natural places) and 34 (Trees, woodland and forestry) in relation to outcome (f). This included calls for NPF4 to ensure consistent application of these policies across planning authorities, and for greater flexibility when considering redevelopment of brownfield land under Policy 30 (Vacant and derelict land and empty buildings). It was also suggested that redrafting is required to address overlap and inconsistency between Policies 3 and 32, with some suggesting that these policies should be combined. There were calls for NPF4 to include links to agriculture and forestry policy to support delivery of positive biodiversity impacts.



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