National Planning Framework 4 - call for ideas: Key Agencies Group response

A joint statement from the Key Agencies Group relating to the NPF 4 call for ideas.


The Key Agencies Group welcomes the invitation to input to the NPF4 Call for Ideas and the opportunities this brings to support delivery of the National Performance Framework outcomes. We recognise that NPF4 will need to take a radical and innovative approach to support a green recovery to the current crisis in a way that addresses the climate and biodiversity emergencies, delivers culturally vibrant places and a sustainable and inclusive economy that works for everyone.     

The policy framework established in NPF4 will be important in helping to address these challenges but we realise that of equal importance will be how we work together in the spirit of the Place Principle to support delivery. We recognise that the Key Agencies have a crucial role in collaborating with other stakeholders to help meet these challenges head on. We can bring a wide range of skills, expertise, resources and evidence which collectively supports the innovation and creativity needed.  

There are significant benefits to be had through the Key Agencies working with local authorities and other stakeholders to help make sense of the complexity and scale of nationally significant places undergoing change or development. Over the past twelve months we have started to organise ourselves so that we can work in a more collaborative ‘Key Agency team’ approach with stakeholders to deliver place objectives for complex sites. Our early and continued engagement not only helps improve place outcomes but provides opportunities to align resources more effectively and bring greater certainty for developers and communities.

We welcome the opportunity to work with the new planning system and NPF4 to guide development, to shape places and provide certainty within the planning system. The Key Agencies will be providing individual responses to the Call for Ideas. There are, however, some areas of cross Agency interest that we would like to highlight that can help support delivery of the National Outcomes.  

Addressing the climate emergency

Supporting sustainable and inclusive growth and the delivery of housing supply and infrastructure in a way that supports a just transition to net zero emissions by 2045 is both a significant challenge and an incredible opportunity for NPF4. NPF4 needs to lay strong foundations to ensure we are on the right track over the next 10 years. Key to this will be securing the right development in the right place, zero carbon and future proofed design and a circular economy approach to resources and place.  

Spatial strategies for development and infrastructure (including energy infrastructure) have very strong ‘lock in’ effects and NPF4 must ensure that these are underpinned by a need to minimise emissions. To achieve this we would advocate a policy principle that developments and infrastructure must be located and designed for zero carbon, adaptability and longevity, with resources being kept in productive use (materials including existing buildings, water, land, soils and heat). A strong plan led approach is key to this.

NPF4 also has a significant role ensuring communities and places can successfully adapt to the impacts of climate change. Nature-based solutions will help support climate resilient communities, whilst improving the quality of places and contributing to health and wellbeing. These can also help the planning system deliver positive effects for biodiversity and help reverse biodiversity decline.  

Blue-green infrastructure 

One of the most powerful ways NPF4 can deliver future resilience to climate change in a way that supports quality of life and health and wellbeing is to facilitate a strategic, comprehensive and systematic approach to planning and delivering green and blue infrastructure as an integral element of place - from national to site level. Investment decisions for blue-green infrastructure should to be closely aligned to the needs of communities and integrated with wider place objectives, using a place based approach.   

A blue-green ‘infrastructure first’ approach will help ensure active mobility and transport routes both within and between new and existing places, facilitate sustainable surface water management, help reduce flood risk and deliver access to natural and open spaces. It will ensure the provision of safe and permanent facilities in the right place and provide resilience to changing climatic, societal and economic circumstances. It will also help deliver positive effects for biodiversity, one of the key outcomes sought from NPF4.

Planning for a changing economy 

Scotland’s economic profile is changing significantly and there is a real opportunity to ensure this change supports inclusive growth. To improve the prosperity and wellbeing in areas of Scotland which are lagging behind, NPF4 should provide the framework for a more active regional policy including regional prospectuses. The traditional sectoral approach applied by planning policy will no longer be fit for purpose as sectors merge and become more interconnected. The planning system must prepare for and guide development activity and societal transitions if we are to successfully progress to net zero and the digital data driven economy. Events over the past few weeks have heightened the urgency for NPF4 to support a green recovery to help deliver this transition. 

Valuing the special character of place

NPF4 must ensure that planning is better connected and integrated to take a holistic approach to the environment to fully protect the character, variety and vitality of our towns, cities and countryside as opposed to  protecting special places as ‘islands’ within development. Important natural and historic places should be embedded as focal points and catalysts for place and areas of coordinated action can help maximise the benefits of these assets. New developments should be well integrated in to the natural and built environments surrounding them, to ensure that they are culturally vibrant places to live, work and visit. For example, NPF4 can support creative approaches for the ongoing use of historic sites and places to achieve this. 

We trust you find these ideas of use and would welcome the opportunity to discuss how to maximise value from the Key Agencies moving forwards. In these challenging times we recognise a need, more than ever, to collaborate in finding a positive path forwards for Scotland through NPF4.

Yours Sincerely,

Katherine Lakeman - Chair of the Key Agencies Group

On behalf of the following key agencies: 

  • Architecture and Design Scotland
  • Historic Environment Scotland
  • Scottish Enterprise
  • Scottish Environment Protection Agency
  • Scottish Natural Heritage
  • Sport Scotland 

The Key Agencies Group was initially established in 2008 and comprises of a group of public bodies that play a pivotal role in supporting the delivery of culture change in planning through improved joint working. These agencies also fulfil a range of functions in the delivery of the Scottish planning system, for example through the provision of infrastructure or as a statutory consultee for certain types of development consent.

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