NPF4 not yet a panacea for the planning system in Scotland

The National Planning Framework for Scotland (NPF4) was published on 8 November 2022 by Tom Arthur, Planning Minister. Timing of the publication co-coincided with World Town Planning Day and was a year after COP 26 in Glasgow. However, given the current economic crisis is this the strategic policy to help take Scotland out of recession?

Three rounds of extensive public consultation have been undertaken to inform the preparation of NPF4, together with parliamentary scrutiny of the draft NPF4 during 2022. The spatial strategy has been reworked based on three pillars of Sustainable, Liveable and Productive Places with different development priorities across Scotland. This ‘final’ version feels different but in policy terms continues to put climate change at the core of decision making.

Despite being welcomed by the RTPI Scotland and although the revised draft has alleviated some concerns raised previously, tensions remain as to whether housing delivery numbers and the Minimum All Tenure Housing Land Requirement (MATHLR), is sufficient in key market areas.

The emphasis is very much on a new approach to planning in order to achieve a net-zero Scotland by 2045. With enhanced legal status it will play a pivotal role in land use decision making; in order to tackle and adapt to the changing climate, restore biodiversity loss, improve health and wellbeing, build up the economy and create great places.

Scottish Government is clear that the planning system must be become an enabler of the net zero transition and respond to the climate emergency. There will be concerns in the development sector that the balance has now over compensated and may prevent enabling infrastructure investment and the delivery of housebuilding targets needed to address the housing crisis.

The new draft brings additional clarity for investors and decision makers alike, and should lead to faster more consistent and cost-effective processes but it will almost certainly need further consideration. A new Planning, Infrastructure & Place Advisory Group has also been announced in order to facilitate development and investment.

The policy document will undertake further scrutiny to resolve some of the prevailing issues, over a 120-day parliamentary period in the run-up to a final debate and vote. However, tensions look set to remain as to whether housing numbers will address market and affordable housing requirements and whether there is enough policy ambition to attract property investment to regenerate our urban and rural areas.

It also generally represents divergence between the Scottish and English Planning systems in terms of policy, process and practice.
Notwithstanding this, the biggest criticism is that NPF4 is weak in relation to resourcing the new responsibilities and duties inherent in the system and the resultant required culture shift. It is well documented that the number of local authority planners has fallen by 33% over the last 10-12 years and fundamental questions remain over budgets and resourcing.

Most practitioners and our clients are acutely aware of the significant budgetary cuts experienced by planning departments resulting in chronic understaffing. Clearly to make the new vision work, appropriate resources for local development plans and development management need to be provided. The first test for NPF4 is likely to be the level of alignment with the Edinburgh City Plan 2030 which is due for examination imminently

Mr Arthur is particularly ‘alert’ to the pressures facing planning authorities stating that it will streamline current practice and make it more consistent freeing up resources for culture shift as part of a more collaborative and streamlined approach to existing processes What this will actually mean in practice is not clear at this point, and local authorities will require the resources from cost recovery to effectively deliver new duties and responsibilities embodied in the framework.