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 promote the alignment of development and infrastructure at the local, regional and national level by identifying infrastructure capacity, need and what is required to support its delivery.

Respondents often noted or expressed support for the recommendations of the Infrastructure Commission for Scotland,[27] particularly with respect to:

  • Taking an infrastructure first approach.
  • Prioritising investment decisions based on their contribution to the delivery of low carbon infrastructure or meeting net-zero targets.
  • Making use of existing assets.

There were calls for infrastructure to be planned and delivered at a national level or for a more strategic or joined-up approach to ensure delivery is less fragmented. The need for collaboration between local authorities, developers and infrastructure providers was suggested, with the role of utility providers highlighted as being of particular importance.

It was also suggested that it will be important to align infrastructure investment with other strategies and frameworks including: The Land Use Strategy and Regional Land Use Frameworks; NTS2 and Regional Transport Strategies; and the updated Climate Change Plan.

There were calls for:

  • An Action Programme for infrastructure requirements to be developed for each region.
  • Creation of a National Infrastructure Agency or another arms-length public agency with powers similar to the Countryside Commission for Scotland.
  • Recognition of the link between economic, health and natural infrastructure requirements and the need for planning to work collaboratively with key agencies and partners in health and social care, education, infrastructure provision and transport.

Other suggestions included that NPF4 should:

  • Target 'infrastructure-deprived' areas. This was sometimes expressed as 'rural infrastructure first' or with reference to a particular area felt to have missed out on previous infrastructure spending. It was noted that infrastructure will also play a critical role in promoting the inclusive growth agenda, opening up deprived areas to employment and inward investment opportunities.
  • Consider provision in a holistic way - for example not looking only at education provision but how these facilities can deliver other community needs.
  • Recognise landscape as a vital component of infrastructure and not just an asset.
  • Require the carbon impacts of all new infrastructure to be considered, with full lifecycle carbon emissions taken into account when prioritising investment.
  • Shift the emphasis from taking infrastructure to development sites to focusing development on existing infrastructure - for example transport hubs.
  • Consider a Compulsory Purchase Order process or an agreed, time-limited process to prevent long or expensive legal delays to infrastructure projects.
  • Consider an infrastructure self-certification scheme, whereby developers, in conjunction with service providers, establish the infrastructure requirements for their proposals and the costs of provision. It was suggested this would help ensure that infrastructure requirements and deliverability are fully considered at an early stage and would allow infrastructure costs to be incorporated into the decision-making processes of both developers and planning authorities.

It was also argued that developments that are not financially viable or which cannot deliver the required infrastructure should not be supported and that this principle should be applied from initial site allocation in the LDP through to the approval of planning permission.

Respondents who commented on the Infrastructure Commission's recommendation with respect to making use of existing assets sometimes suggested that a whole-life based approach should be a key consideration in the creation of new infrastructure or that there should be a strong presumption for reuse and repurposing over new build. Consenting repowered onshore wind developments was suggested as an example of making use of existing assets, as was use of the existing canal network as a component of 'smart' water management systems. Protection of existing infrastructure relating to culture and heritage was also proposed.

With respect to future-proofing development plans it was suggested NPF4 and LDPs should take account of emerging technologies and be flexible in how these might be delivered in the future.


Respondents also identified numerous specific types of infrastructure they felt should be prioritised. Many of these topics have been addressed under other themes, particularly Energy - electricity, Green infrastructure and Transport, so are noted only briefly here. Types of infrastructure identified included:

  • Mains water supply or drainage/sewerage. It was argued mains water infrastructure in rural communities must be improved to ensure everyone has access to a reliable supply of safe, clean and potable water. Delays in delivery of housing on vacant and derelict land were reported to have been caused by delays in provision of drainage and it was argued significant investment in drainage infrastructure, well beyond that to which viable developments can contribute, is required to help authorities deliver sustainable development.
  • Elements of blue/green infrastructure. It was argued planning guidance for green and blue infrastructure should be updated to provide regulation for implementation rather than best practice guidance.
  • Large scale renewable energy developments.
  • Repowering onshore wind sites.
  • Electricity grid infrastructure, with specific references to capacity, and waiting time for connections.
  • Electric Vehicle charging infrastructure.
  • Onshore infrastructure associated with offshore wind development, hydrogen production, wave and tidal energy systems and CCS.
  • Hydrogen infrastructure, including investment in manufacture and storage and for infrastructure to support distribution of hydrogen as a fuel for transport.
  • Digital infrastructure.
  • Transport, including improvements to road and rail networks. Increased rail freight capacity and further electrification of freight routes. Improved road and rail connections to ports and airports.
  • Improved public transport facilities.
  • Infrastructure to facilitate active transport.
  • Port and harbour infrastructure, including new and extended port and harbour infrastructure required to support the onshore development associated with offshore wind.
  • Waste management, including facilities to support development of a circular economy.
  • District heating.
  • Education or Health facilities.

Ports and Airports

The national importance of Scotland's ports was highlighted, and it was argued NPF4 should support development for employment uses within operational ports, as well as the maintenance and development of sea transport infrastructure, including port infrastructure. A mechanism for improved joint working between planning authorities and Marine Scotland was suggested to be necessary for situations where there are related consenting regimes.

Several port-related projects were suggested as National Developments. Ongoing National Development status was also proposed for Freight Handling Capacity on the Forth and for Aberdeen Harbour, both National Developments under NPF3.

With respect to airports, operators were suggested to require more clarity with respect to the criteria to be met for a presumption in favour of airport development.

There was also support for Strategic Airport Enhancements (a National Development under NPF3) to continue to have National Development status under NF4.

Developer contributions

Several respondents referenced developer contributions in the context of infrastructure, including that NPF4 needs to provide a framework for developer contributions, confirming where contributions can be sought, and providing guidance on methodology. It was also suggested that requiring developments to pay for the infrastructure needed to deliver them will focus development on brownfield and infill sites where infrastructure already exists. However, it was also argued that the cumulative impact of contributions for developments should be considered alongside development costs and other policy requirements.

Confirmation was sought that that primary healthcare facilities are a legitimate subject for developer contributions.

The complexity of current provisions for section 75 based developer obligations were also noted and a simpler approach was suggested necessary to allow councils to plan infrastructure funding without exposure to significant financial risk. There was a call for NPF4 to support introduction of a local or regional infrastructure levy, but also a request to consider the potential impact on islands where, it was suggested, any infrastructure levy could make new development unviable.

Other funding

General points on infrastructure planning and delivery included the need for adequate resources to be available, or for a joined-up approach to funding, with one suggestion of a ten-year capital investment programme to support NPF4. Concerns were also raised in respect of loss of EU funding post Brexit, coupled with the related risk of rising import costs for the construction sector. It was argued that guidance and good practice advice on the use of prudential borrowing, joint venture arrangements and other collaborative models of delivery might be helpful for planning authorities.

Resource implications for local authorities were also suggested in terms of additional demands on the Planning Service. Requirements for training and support for existing staff or for additional staff were identified.



Back to top