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.

Green infrastructure

Proposed key objective of NPF4: To protect, enhance and promote green infrastructure, including open space and green networks, as an integral component of successful placemaking.

Benefits of green infrastructure

There were many references to the benefits of green infrastructure including, but not limited to:

  • Providing a carbon sink or otherwise contributing to climate change targets.
  • Contributing to surface water management and flood management.
  • Enhancing biodiversity, providing wildlife corridors, reducing habitat fragmentation and restoring ecosystems. The value of green roofs/walls was referenced. The importance of incorporating a Nature Based Solutions approach to policy development was suggested.
  • Improving the quality of places and as an integral element of place, placemaking and sustainable development.
  • Improving health and wellbeing.
  • Connecting new neighbourhoods to adjoining communities and providing opportunities for social interaction and cohesion.
  • Providing communal space, play space, and active travel opportunities.
  • Improving air quality or water quality.
  • Providing growing space, including for local food production.
  • Creating opportunities for generating renewable energy.
  • Knock-on positive effects for local economies and sustainable economic development.

The particular importance of green space in areas of deprivation was also highlighted and the potential for its contribution to narrowing health inequalities was noted.

Several respondents highlighted the central position they felt green infrastructure should occupy in NPF4 with suggestions including that it should be recognised as an important development type in its own right, that there should be a 'blue green infrastructure first' approach, and that green infrastructure should run throughout planning policy in other areas. It was argued that the multifunctional nature of blue green infrastructure should be emphasised, and that it should be placed at the heart of new development and integral to a design-led approach. An emphasis on considering green infrastructure alongside basic requirements such as roads and drainage was advocated.

Respondents also drew attention to the importance of retrofitting and of enabling improvement of existing green infrastructure. The current public health emergency was cited as an illustration of the importance of accessible green spaces and the degree to which this is limited for those living in some urban areas, particularly in flats. It was suggested that some older social housing developments have little green space.

It was also observed that, in some instances, elements of infrastructure that already exist in their own right may be integrated into development proposals, while protecting their cultural significance. It was suggested that, if sensitively managed, canals can add to a sense of place and provide active travel corridors.

With respect to new development it was noted that provision of green infrastructure may be hard to enforce if developers argue that there are viability issues, and the possible conflict between provision of affordable homes and provision of green space was noted. Some respondents argued that green infrastructure should be given equal priority to affordable homes or should be at least equal to other important priorities. It was noted that minimum requirements for open space have the potential to conflict with minimum density policies, and encouraging higher density residential development in order to provide larger areas of useful, multifunctional space were suggested. It was also argued that quality, usable open space and play areas could have a much higher value to a community than a larger area of unused green space.

The importance of linking green spaces together to form networks was also highlighted with one suggestion that there should be powers to connect green networks outwith development sites, potentially over land in different ownership.

Status as a National Development was proposed for:

  • A new Scottish Nature Network.
  • A new National Green & Blue Infrastructure Network.
  • The Central Scotland Green Network, already an NPF3 National Development.

At a more local level, suggestions included the importance of a high-quality green network linking surrounding neighbourhoods with town centres, including to provide better opportunities for cycling.

The importance of paths as elements of green infrastructure was noted, including as connecting open space within settlements to core paths and then to wider access routes. However, it was also argued that there are few core paths and that many are not fit for purpose as they do not ensure safe travel. At the same time, it was reported that other frequently used footpaths and tracks have no protection in planning law, and it was argued that safeguarding such paths should be considered in planning applications.

Planning process

It was argued that the broad definition of green infrastructure set out in the 2019 Act should be used in NPF4 to ensure it captures the full range of potential benefits. The 2019 Act was also noted to require councils to produce Open Space Strategies, and that this may be helpful with respect to maximising the benefits of green infrastructure. It was also suggested that inclusion of key locations for green infrastructure in forthcoming RSSs and Regional Land Use Frameworks would help to ensure coordinated action and prioritise land use changes.

Other suggestions included that:

  • Consideration should be given to a requirement for green infrastructure plans at either settlement, local authority or regional level.
  • Specific opportunities for the protection and enhancement of green infrastructure could be identified in LDPs or planning guidance.
  • Recognising the different roles that open space has is important and should form part of the requirements for evidence base in the LDP process.
  • Planning proposals should be required to demonstrate how they maximise opportunities to enhance green infrastructure through their layout and design.
  • Open space should be phased in accordance with the masterplan's phasing of homes and this should be set out in planning conditions.

It was acknowledged that major development proposals provide the most significant opportunities for improvements in green infrastructure and it was suggested NPF4 could include specific policies for major developments, requiring developers to demonstrate how opportunities have been maximised.

There were also comments on funding arrangements, including that the planning system should make better use of developer levies to provide for green infrastructure. Developer contributions to offsite infrastructure or the wider green network were suggested in situations where there is already sufficient open space available locally. It was also suggested the right to off-set inclusion of green space through financial contributions should be removed. Existing pressure on council budgets for maintenance of green space was noted and it was argued that ongoing funding for maintaining additional spaces will be necessary.

National standards

There was support for setting national standards including to ensure green infrastructure provision is applied consistently, although it was also argued that NPF4 should drive delivery as well as providing coherent policy.

Specific suggestions included:

  • Exemplar Green Infrastructure policies[7] produced by the Central Scotland Green Network Trust and the Glasgow & Clyde Valley Green Network Partnership could provide an appropriate template for adoption by all local authorities.
  • Consideration should be given to the use of an accreditation scheme such as Building with Nature.[8]

However, some flexibility was also proposed since requirements will vary by settlement location, size and type. In addition, it was suggested local authorities should have the ability to influence standards and requirements given the responsibility for maintenance of sites under section 75 agreements.

Allotments and community growing spaces

Suggestions of ways for NPF4 to support allotments and community growing places included by raising their profile and by making clear their potential contribution to other policy objectives including placemaking and health and wellbeing. It was argued that provision of allotments or community growing spaces is particularly important in areas of denser development, and that provision within existing communities is as important as for new developments. It was suggested provision could be made mandatory unless no local need is identified, and also that increased demand is predicted in the aftermath of the COVID-19 pandemic.

Other points with respect to the planning system included that:

  • RSSs and LDPs could identify land suitable for food production in urban and peri-urban areas.
  • The planning system could be used to support delivery of the Good Food Nation objectives.[9]

The importance of community involvement in setting up growing schemes was also highlighted, with a proposal that funding and support should be provided in line with the Community Empowerment (Scotland) Act 2015. The need for a collaborative approach allowing provision to be tailored to suit the requirements of individual communities was highlighted, and an example of robust, weather-resistant community growing facilities being provided through community land ownership and community organisations was cited.

Other suggestions included that sites should be accessible by foot and bike, with limited vehicular access for offloading, and that suitable sites require maximum sunlight.

Using derelict land, parks and unused golf courses to provide growing spaces were all suggested, as was a larger land area around each house to enable food planting by households.

The value of integration of urban forestry into green networks was also highlighted and noted to have benefits including potential for creating local employment opportunities and providing a supply of local timber and fuel. There were calls for both the protection of urban trees and for increased tree planting, including water course catchment tree planting. An edible strand to Forestry and Woodland Strategies was also proposed.

Safeguarding areas providing flood risk management services

Many respondents cited improved flood management as a benefit of green infrastructure or referenced the benefits of SuDS. Specific suggestions with respect to the latter included that:

  • NPF4 should establish a clear link between green and blue infrastructure, flood risk management and SuDS.
  • Development plans should incorporate Urban Flood-sensitive Zones where SuDS and other blue-green infrastructure are mandatory.
  • Sustainable drainage should receive greater emphasis than grey infrastructure in the management of drainage from new development, and potential for waste-water recycling should be considered.
  • Ownership/management of SuDs should be addressed since mixed ownership impacts on effectiveness, quality and monitoring of effectiveness.

The contribution that can be made by historic assets was also highlighted in the form of the North Glasgow Integrated Water Management System 'smart' canal, formed across seven local authority areas. It was reported this includes infrastructure projects addressing flood alleviation, river water quality improvement, and environmental improvement schemes.

There was support for safeguarding floodplains, with a suggestion this should be a National Priority. Other comments included that:

  • The most up-to-date climate change allowances should be used to define functional floodplains.
  • Areas where development should be prevented could be mapped as protected in LDP settlement statements.
  • Opportunities to improve floodplains through new development should be highlighted.
  • SEPA Flood maps need to be kept up to date.



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