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 ensure that new development supports delivery of the vision and priorities set out in the National Transport Strategy.

There was agreement that NPF4 should support NTS2 with a suggestion that this will help to integrate spatial and transport planning, informing investment decisions based on their alignment with NPF4, NTS2, RSSs and LDPs.

The need for regional co-ordination of transport infrastructure was also observed and it was suggested that LDPs and RSSs should be required to demonstrate how they reflect and help to achieve the aims and outcomes outlined in Scotland's seven Regional Transport Strategies. Increased devolution of decision making, budgeting and resourcing of strategic transport governance and operation to a regional and/or local level was proposed.

Points on the relationship between NPF4, NTS2 and STPR2 included:

  • Identification of infrastructure requirements under NPF4 must be linked to STPR2 and the investment priorities that will be delivered through STPR2. The requirement for STPR2 to take account of local circumstances and needs was highlighted, with a specific suggestion that it should not overlook priorities outside the central belt.
  • The wider area impacts of travel as a result of nationally significant city and region economic growth need to be recognised as requiring national, regional and local action in NPF4 as well as NTS2 and STPR2.

For NPF4, alignment with NTS2 was noted to require:

  • A major shift in emphasis from roads and cars to walking, cycling and public transport.
  • Large scale improvements to active and sustainable transport networks across Scotland. This was suggested as a National Development.

A clear policy framework as to how LDPs can achieve the lasting modal shift needed in terms of transport and travel, and how they can contribute to reducing carbon emissions from transport in their area was suggested.

There was a call for all new capital expenditure associated with improvements to transport to be zero-carbon and, particularly in the light of the economic effects of COVID-19, for priority for capital expenditure projects which have greater potential to be carried out by Scottish companies and Local Authorities.

Many transport-related projects were suggested to merit National Development status including bus or rail projects including High Speed Rail and various strategic transport network enhancements or corridors. In relation to active travel there were proposals for coastal paths and cycling and walking networks, including that NPF3's National Long Distance Cycling and Walking Network should continue as an NPF4 National Development.

New housing developments

Some respondents made points on the location and design of new developments including highlighting the need to reduce dependency on cars, calling for an end to car-dependent developments or calling for development of car-free neighbourhoods.

With respect to the criteria for sustainable development it was argued that new housing sites should:

  • Be provided with safe walking and cycling routes. In light of the move towards quieter electric vehicles it was argued that clearly defined pavements are needed for pedestrian safety.
  • Provide shared bikes and e-bikes funded through developer contributions.
  • Have secure cycle parking facilities.
  • Be well-connected to town centres. The potential of greater walking and cycling access to help rejuvenate town centres was also suggested.
  • Have a road layout that is appealing to bus operators in terms of easy access to the main direction of travel, well-placed bus stops, turning bays etc.
  • Maintain up-to-date travel plans to provide good quality advice covering active and public travel options to all new occupants of a development, not just when the development is new.

In terms of accessibility of new housing development to public transport, facilities and services it was argued that suggested walking distances set out in Planning Advice Note 75 are unrealistic for many people, leading to an increase in car use. It was suggested the standards should be tightened and become requirements so developers fund changes in bus services and provide local shops and services within developments.

It was also argued that accessibility to public transport should not be a binary test for sustainable housing development and it was suggested that paragraph 81 of the current SPP should be amended accordingly.

With respect to the current SPP requirement for planning permission not to be granted for significant travel-generating uses in certain circumstances, it was suggested clarity is needed on the thresholds for determining such significant travel-generating uses.

Although facilitating active travel and use of public transport were highlighted by many respondents, an ongoing requirement for cars and for electric vehicles was also suggested, along with the need for new developments to provide electric vehicle charging points. A national standard for such provision was suggested, with one proposal for a minimum of one charge point for five residential units. It was also argued that fast chargers should not be installed in residential areas, rather that smart charging and vehicle-to-grid should be required at houses.

With respect to provision of parking space in new developments it was suggested that:

  • The default position that each household in a new development should have at least one parking space should be removed.
  • Policies should encourage lower maximum parking standards in areas well served by public and active transport.
  • Parking spaces should attract developer contributions to fund active travel infrastructure - additional spaces requiring additional contributions.
  • Convenient parking spaces should be designated for car sharing schemes with private parking spaces located further away.
  • Low car neighbourhoods could be marketed by the developer as part of a wider low carbon image.

However, it was also argued that all new properties should have a parking space, with two spaces for larger properties and additional space for visitor parking. Developments with under-provision for parking were reported to have vehicles parked on grass verges and on pavements.

In terms of where new development should be encouraged suggestions included: sustainable locations; sites within existing settlement boundaries; brownfield sites; and sites near public transport hubs. It was argued that development on greenfield sites near motorways should only be permitted after other options have been considered.

There was also a suggestion that encouraging development in sites where rail transport can be accessed would allow construction materials to be transported by rail freight.

Active travel

Many respondents commented on the need to prioritise or invest in active travel, sometimes observing the benefits physical activity can bring in terms of improved health and wellbeing. It was also noted that NPF4 has a role in achieving priorities from several other national policies and strategies including: the Active Scotland Delivery Plan; the 2030 Vision for Active Travel; and the Active Travel Strategy.

It was suggested that more must be done for people to see active travel as a practical alternative to road transport, especially in rural areas, and that there should be equality between active travel and vehicle travel within local authority transport budgets. Among other issues raised were that:

  • Active travel routes should be part of wider green networks.
  • Routes should be multi-use.
  • Rights of way over road users should be considered.
  • Local authorities should take on maintenance for all new active travel infrastructure built with Transport Scotland funding.

A requirement for LDPs to include active travel policies was advocated and that proposals that would improve and expand existing path networks, provide new connections to the existing path network, reprioritise existing road space and develop new routes dedicated to walking and cycling and public transport should be identified.

It was also argued that local authorities require stronger powers to allow land to be assembled for the delivery of sustainable infrastructure and that presence of a route in an adopted LDP should be sufficient to demonstrate that the land is required to deliver on sustainable objectives. Other suggestions included incentivising rural landowners to allow off-the-road shared use paths to be built across their land and that local authorities should take responsibility for connecting paths where developers do not.


The need to put walking at the heart of urban planning and to create walkable environments that encourage active lifestyles was highlighted. The importance of safe walking routes was also emphasised, including the need to monitor condition and maintenance when levels of funding may be falling. Cars parked on pavements, cyclists using pavements and poor pavement maintenance were identified as important issues.


Comments with respect to infrastructure for cycling included requirements for more segregated cycle paths, and improved cycle lanes, and also the need for people to feel safe while cycling. Making cycle routes central to development and easier to use was also identified as important, and adoption of Cycling UKs 2018 recommendations to the UK Government was suggested.

A requirement for secure cycle parking was also highlighted, including for cycle parking at stations. In existing settlements, providing permitted development rights for cycle sheds or storage containers below a specified size was proposed.

It was also suggested that more bike carriages should be available on trains and that bike transport should be facilitated on long distance bus routes. Other facilities suggested included access to showers and to cycle maintenance facilities.

It was also argued that creating wider networks that cross boundaries between masterplan areas is essential but can be difficult to achieve. Further development of the National Cycle Network producing longer-distance cycling options was highlighted as providing a potential boost for tourism as well as improved commuting opportunities.

Granting pedestrian and cyclist priority on all 'C' class and unclassified roads was also suggested. While vehicular traffic would still be able to use these roads driving would be slowed down to suit the speed of walker and cyclists.

Public transport

There were calls for public transport to be prioritised and to be better integrated including with respect to ticketing and with active travel options. A stronger emphasis on connectivity and multi-modality in policy wording was suggested.

It was also argued that:

  • Public transport vehicles must be converted to renewable energy sources.
  • Public transport should be free or low cost to encourage use.
  • Additional park and ride facilities are required, and consideration should be given to preventing private bus operators abandoning park-and-ride routes if they are not immediately profitable. Creating small areas of parking at road junctions to act as bus interchanges was also suggested.

The importance of multi-modal transport hubs and encouraging multi-method travel were highlighted and it was suggested there should be investment in transport interchanges.

Rail services

Further investment in rail infrastructure was argued to be necessary, including for both additional electrification and increased capacity. The need for continued planning support for electrification work was also suggested: it was noted that while many aspects of development associated with electrification benefit from permitted development rights, some will need planning or other consents that the planning system should provide policy and process support at all levels.

There were calls for faster rail connections between urban areas and for increased capacity or other improvements on specific routes including: the East Coast main line; the Highland main line; the Far North Line; the West Highland Line; the Fife Circle; and to services between Inverness and Aberdeen and between Glasgow and Edinburgh.

Other suggestions included:

  • Reinstatement of local branch lines and opening local stations.
  • Promoting tram, light rail or guided bus services.
  • Extension of Edinburgh's tram system to support expansion of West Edinburgh.
  • Improved station capacity.
  • A rail hub at Perth.
  • High Speed Rail.
  • Improved rail links to international ferry ports to reduce the need for freight transport by road and moving rail freight at night to increase capacity.

Bus services

The potential of buses to relieve congestion and to play a role in longer distance active transport journeys was highlighted and measures to reverse the decline in bus services and enhance public perception of bus travel were proposed. More bus-only routes were suggested on strategic corridors.

It was also suggested that there should be a focus on:

  • Routes where there will be greatest impact, including for the most disadvantaged communities.
  • Stronger regional bus networks, particularly serving smaller towns and rural areas.

Ferry services

It was argued that ferry services require substantial investment to improve performance, resilience and carbon footprint. A specific suggestion was for commuter and other fast ferry services across the Clyde, Forth, Tay and Moray Firths.


There were calls for improvements to the existing road network, including to address capacity constraints and to improve pedestrian routes, cycle routes and bus lanes. While some respondents suggested improvements for specific roads and trunk roads it was also argued that road building should stop, with the resulting cost savings diverted into maintaining existing roads and active travel infrastructure.

Other suggestions included:

  • Regional transport fuel strategies to encourage local renewable energy generation for transport purposes. It was also proposed that transport authorities should be given powers to designate transport corridors according to their environmental status and to restrict the type of vehicles permitted to use them.
  • A presumption in favour of renewable energy projects designed to produce fuel for local transport strategies.
  • A presumption against new petrol or diesel filling stations.
  • Environmental impact assessment for trunk roads, with remediation schemes implemented where necessary.


Measures to reduce or limit the use of cars were suggested to be necessary including that:

  • There should be higher parking charges in city centres and charging for workplace parking should be implemented. Parking capacity in towns and cities should be reduced each year.
  • Congestion charging should be the norm.
  • There should be a 20mph speed limit in towns and cities.
  • There should be incentives for car sharing.

Air transport

There were calls to implement measures to reduce travel by air including by stopping airport development.

However, investment in the Highlands and Islands airport network and in new sustainable aircraft design were also advocated, and good air links were argued to be vital for international connectivity and competitiveness. Electric aircraft were suggested likely to provide sustainable connectivity, particularly on short highlands and islands routes.

Water transport

It was observed that sea transport is less carbon intensive than other forms of transport and it was suggested that investment in port and harbour infrastructure should be supported. It was argued that improving congestion around ports can make sea freight more attractive and also that there is scope for greater connectivity with the rail network for freight transport.

The potential for moving freight on the canal network was also suggested.

Rural and island issues

Several respondents highlighted connectivity challenges for island and rural communities, and it was suggested NPF4 should reflect the support for provision of essential rural transport services set out in NTS2. An integrated approach to public transport where bus services connect with internal and external ferry and air services was argued to be essential and the possibility of fixed links - tunnels or bridges - was also raised.

Allowing sustainable development only in locations that can utilise active travel or public transport was argued to be more suited to urban areas than to islands with a scattered rural population. A more flexible approach that is responsive to the use of electric vehicles or other low/zero carbon travel was suggested as an alternative.

Equalities issues

It was suggested that, while the majority of public transport users are women, Scotland's current transport systems do not reflect the different needs of women, and that these should be taken into account as NTS2 is implemented.

There were additional suggestions that the transport planning system should take account of the needs of different types of travellers including: children and young people - particularly in relation to their need for independence in access to active travel and public transport; and disabled people. Participation of women, people from ethnic minority groups and disabled people in Transport Citizen Panels was suggested as an opportunity to inform the development of infrastructure in NPF4.

Homeworking and reduced travel

It was observed that COVID-19 has revealed that many people can work from home at least part-time, and it was argued that this should be encouraged in the longer term to reduce commuting. It was suggested this will affect not only how businesses think about their locations, but also where the workforce chooses to live and how they choose to travel, requiring a radical transformation in transport planning, modelling and funding.

The need to provide high-quality digital connections to support homeworking was highlighted and the scope for digital access to key services to reduce the need to travel was also noted.

Providing people with high-quality local green infrastructure that connects to a wider network, was also suggested to reduce the need to travel for recreation or to support walking and cycling holidays rather than motor-based touring.

Low carbon transport

The importance of decarbonising transport was noted with a suggestion that, to ensure appropriate infrastructure for the future, clear direction is needed nationally on whether investment should continue to be directed towards electric vehicles or if there should be a move to hydrogen. This was also argued to be important for freight operators looking to invest in switching their vehicles and it was suggested a long-term transport decarbonisation infrastructure roadmap, supported by clear policy direction would help provide confidence for fleet operators.

Electric vehicles

There were expectations that electric vehicles will become the norm and many references to need for a greatly increased charging network. There were suggestions that - in addition to the provisions in domestic settings noted above - there should be charging points in workplaces, new buildings, carparks (including as a condition of providing parking facilities) and along the road network including at new or modified filling stations. The requirement for charging facilities for e-bikes was also noted.

Specific points were made with reference to provision of charging points in rural areas, with existing gaps in charging infrastructure in the highlands and islands highlighted. A rural-first approach to roll-out of electric vehicle charging infrastructure (and/or hydrogen infrastructure in due course) was proposed.

The implications of increased demand on the capacity of the electricity network were noted and an Energy Company respondent highlighted the extent of the legislation with conditions that must be observed in relation to electrical infrastructure. It was suggested that introduction of greater flexibility in the consenting process and the exemption criteria could help to deliver a more positive and responsive planning framework. Further, it was proposed that current permitted development thresholds for electricity works in non-sensitive areas should be reviewed with a view to extending the threshold development limit.

Another Energy Company respondent noted their own involvement in trialling a model for delivering strategic infrastructure and argued that a framework of support for network operators to deliver roll out of electric vehicle charging will be necessary.

Hydrogen powered vehicles

A clear national policy supporting uses of hydrogen for purposes including as fuel for transport was suggested. The need to plan appropriate infrastructure for use of hydrogen for transport was noted and the roll-out of hydrogen refuelling stations was advocated.



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