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.

Coastal planning

Proposed key objectives of NPF4: To recognise and support the unique challenges facing Scottish coastal areas and communities and promote development that supports their needs

There were calls for future planning policy to continue to assert the importance of Scotland's wild coastlines, and for coastal protection including infrastructure to take account of sea level rise /storm surges. The need for an emphasis on safeguarding and enhancing coastal ecosystems and the natural protection services they provide was also suggested as was support for managed re-alignment projects - replacing artificial 'hard' coastal defences with natural 'soft' coastal defences.

The need to give greater consideration to the threat of climate change and erosion to the coastline was suggested and it was argued:

  • Development should mitigate /withstand adverse outcomes.
  • There needs to be stronger policies to prevent development close to soft coastlines where there has been a history of erosion and flood risk.

It was also argued that a one-size-fits-all approach to coastal planning policy would be detrimental to sustainable development for smaller islands where, in some cases, all areas may be coastal in character. In these circumstances it was argued to be more appropriate for the protection of coastal landscapes to be considered within the context of the landscape character of islands as a whole.

Complementing existing policies and guidance

A requirement for improved integration between the flood risk management and coastal protection planning activities of SEPA/local authorities and local development planning was suggested, as was the need for flood risk management strategies to provide more guidance.

The importance of integration between terrestrial and marine planning systems was highlighted, with particular reference to:

  • The National Marine Plan.
  • Regional Marine Plans.
  • Sectoral plans for Offshore Wind and Aquaculture.
  • Ports and harbours.

The RSS was seen as providing an opportunity to establish a spatial development framework to enable an integrated approach to the LDP, Regional Marine Plan and associated development projects.

Additional policy guidance for the marine land interface was thought necessary, including a view that Circular 1/2015 should be updated to reflect the more diverse ownership and activities now happening in the intertidal, coastal and offshore environments. Clear policy direction was suggested to be needed to underpin effective devolved marine planning.

It was also noted that the Scottish Crown Estate Act 2019 will provide further opportunities for island communities to derive enhanced benefits from the assets in their area, and continued support for the Crown Estate Asset Management Pilots was proposed.

Managed coastal retreat

Respondents argued that there should be consideration for policies on managed coastal retreat or roll-back - movement of properties, settlements and infrastructure from at-risk areas to inland sites. In some cases, it was argued, the cost per head of population for coastal protection or remedial works will be disproportionately high and that coastal retreat will be the most sustainable approach.

It was suggested NPF4 should provide a policy (and/or spatial) framework for how managed relocation can be addressed via LDPs and that this could include identifying areas where further additional development may be limited due to flooding and/or coastal erosion, and those to which existing development can relocate.

Other issues

Other suggestions with respect to coastal planning included:

  • There should be polices enabling a landowner or operator of a site to implement coastal defences, at their own cost and subject to satisfying the appropriate criteria.
  • Coastal locations need to be much more alive to recreational and short distance water-based transport.
  • Marine conservation areas should be enlarged, or new Coastal Marine Reserves created.



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