NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.


Proposed key objective of NPF4: To support the management of waste in line with the waste hierarchy (waste prevention; reuse; recycling; energy recovery and waste disposal) and to guide development for new infrastructure to appropriate locations.

There was broad support for development of a circular economy and embedding of zero waste principles in NPF4 although it was also suggested that the relationship between the Zero Waste Plan, the Making Things Last Strategy and the planning system is not clear.

Conserving natural resources, reducing dependency on imported materials, reducing the need for landfill, triggering investment in design of innovative materials and creating demand for local, renewable materials were all highlighted as potential benefits of improved waste management, and it was suggested the public sector could lead by example through revising its procurement and stewardship processes.

It was noted that reducing waste will require changes to working practices for many businesses who will need support during this transition. Providing tax incentives to environmentally friendly companies promoting biodegradable and recyclable no-harming products was suggested, as was creation of a sovereign wealth fund as a rolling fund to develop a circular economy.

Construction sector

The high levels of resources used by and waste generated by the construction sector were highlighted, and it was suggested the planning process should:

  • Include a presumption in favour of enhancing, re-purposing or maintaining existing infrastructure to make continued use of existing assets. Repair and re-use of existing buildings should be promoted before new development.
  • Require building materials to be re-used where possible or set re-use targets at regional, local, corporate and project levels, along with a requirement for monitoring and reporting. Pre-demolition audits, materials and buildings passports and collaboration between stakeholders were all suggested. A link was also made to policy on mineral extraction.
  • Include targets for waste management both on site, off site and in use as planning conditions. Require uses for surplus waste soil to be considered at the design stage.

With respect to new development it was proposed that the principles of the circular economy should be integrated into building design, creating buildings to be adaptable and long-lived, with materials that can be re-used. Assessing the carbon footprint of any new development was suggested as was encouraging use of local renewable materials.

The need to design settlements to allow easy access to local repair and refurbishment facilities, as well as widespread and comprehensive recycling opportunities was highlighted. Suggestions included:

  • Providing adequate storage space within property boundaries for domestic recycling bins.
  • Ensuring the layout of commercial development supports waste management to avoid commercial refuse being left in the street.
  • Providing space for composting and stimulation of community composting schemes.

It was also argued that sustainable waste-water treatment should be in place before any development takes place and that maximum capacity must be considered when adding new developments onto existing infrastructure.

Waste management infrastructure

Several respondents commented on requirements for appropriate infrastructure for a circular economy and sustainable waste management.

Enhanced infrastructure for collection of high-quality recycled materials was suggested to be necessary, with more sorting, processing and manufacturing facilities required to collect such material and optimise its value. The Deposit Return Scheme was cited as an example.

While the importance of waste prevention, re-use and recycling was noted, it was also observed that waste management options towards the bottom of the waste hierarchy still have a role to play. There was a call for NPF4 to recognise the importance of Scotland's waste management infrastructure, and to ensure that planning authorities make provision for waste management capacity across all levels of the waste hierarchy. It was also suggested that a stronger link between planning and the circular economy would assist the waste management industry to invest in the infrastructure needed.

National Development proposals included for a country-wide network of planned, complementary, full spectrum material and resource management facilities to support Scotland's circular economy and net zero ambition.

A requirement to increase capacity at existing sites or to provide additional facilities to manage segregated waste streams was suggested. With respect to where such sites might be located, it was suggested their strategic importance means planning authorities should apply added weight when considering special circumstances for proposals located within the greenbelt.

It was also noted that operators may see landfill sites as locations with potential for other waste management uses, with a potential impact on planned restoration and it was suggested guidance on this would be useful.

In the longer term, it was suggested the planning system needs to be flexible enough to allow the waste and recycling industry to adapt to new business models as the circular economy evolves.

Energy from waste

It was argued that the support for EFW provided under NPF3 should continue and that the forthcoming ban on biodegradable municipal waste being sent to landfill will increase the need for EFW plants. Comments included that:

  • LDPs need to be able to address requirements including the continued use of some landfill sites, an increase in EFW plants, and where they are best located.
  • Traffic impacts on communities must be considered as waste from multiple authorities will need to be transported to plants to supply sufficient 'feed stock'.
  • Anaerobic digestion is generally more suited to (semi) rural rather than urban environments and, as argued above, proposals for sites located within the greenbelt should be considered.
  • EFW plants can contribute to local heat networks.

There were calls for a moratorium on building new incinerators, particularly in the context of the ban on biodegradable municipal waste being sent to landfill. Concerns regarding the role of incinerators in both carbon emissions and generation of toxic ash were cited and it was argued that there should be no place in Scotland for burning valuable resources. Further, it was suggested additional incineration capacity could reduce the incentive for reduction, re-use and recycling of waste materials.

The potential for conversion of sewage into energy while recovering bio-resources, and for recovering heat from sewers was also noted.

Cutting plastic pollution

Roles for NPF4 in promoting responsibility for local litter collections and in keeping rural and coastal communities free of waste, particularly plastic pollution, were suggested.

There were calls for action on the use of plastics, and of single-use plastics in particular, with specific suggestions including:

  • A ban on single-use plastic in takeaways as part of licensing/change of use permission.
  • A ban on new plastic production facilities.
  • Integration of measures such as plastic bottle deposit schemes and no single-use plastic into a green supply chain for publicly funded buildings such as schools, libraries and council offices.

There was also a suggestion that use of biodegradable/recyclable products in manufacturing should be promoted and that more emphasis must be placed on the packaging industry.



Back to top