Comment

Scottish National Planning Framework 4 Interim Statement: Implications for climate, wellbeing and resilience

The Scottish Government has published an interim statement for the proposed NPF4 which seeks to confirm how future Scottish Policy will address Energy Transition and a move to net-zero.

Regrettably, this not the Draft NPF4 publication and consultation has been delayed due to COVID-19 until autumn 2021. The climate emergency has not been delayed due to COVID-19 and the urgency for the planning system to adapt to deliver a net zero Scotland by 2045 and recognise the “new world” post-COVID-19 has never been greater. However, it does at least show the current direction of travel of national policy, and provides a flavour of what the new NPF4 development plan document is likely to contain.

Publication of this statement follows an earlier call for ideas and an analysis of the responses to inform further discussion on key themes for energy which include: addressing climate change; achieving net zero targets; supporting energy transition; adopting an infrastructure-first approach and recognising the role of planning for health. An overview of the key themes is provided below:

Addressing climate change through energy transition

• The whole planning system will need to be rebalanced to make climate change the guiding principle for all development plans and planning decisions, to achieve a net-zero Scotland by 2045.
• NPF4 is expected to treat the Global Climate Emergency as a material consideration for applications for appropriately located renewable energy development.
• NPF4 will consider whether national development can help deliver emission reductions and our view is that national developments are likely to focus on those schemes which deliver energy transition.
• Supporting renewable energy development and recognising the role of re-powering and extending existing wind farms, grid improvements and developing carbon capture, storage and hydrogen networks.  
• An update to the current spatial framework for onshore wind – allowing development outwith National Parks and National Scenic Areas subject to site specific assessment.
• Recognising new energy technologies within policy.
• Facilitation of decarbonised heating and electricity generation and distribution.
• Facilitating a culture change towards low-carbon living and the low and zero carbon design and energy efficiency of buildings.

Wellbeing economy

• A shift from a growth economy to a wellbeing economy – ensuring development occurs where it has greatest benefit for society as a whole.
• Collaborative spatial planning to take place at all levels including at a national, regional and local scale.
• Promotion of strategically important locations for investment and growth. 
• Seizing the opportunities created through the transition to a net-zero circular economy.
• Support development which contributes to a wellbeing economy and fair work.
• Enable new ways of working focusing on localism.
• Protect and facilitate our food and drink, sustainable tourism, and culture and creative industries.
• Re-imagining town and city centres as vibrant, creative and enterprising locations with a wider mix of uses.
• Action zero waste, sustainable resource management to ensure a circular economy.
• Recognise changes to global markets including Brexit – with a view of protecting strategic transport connections, links and gateways: informed by the second Strategic Transport Projects Review.  Securing links between Scotland and the rest of the World.
• Decarbonising our transport system.
• Secure the roll-out of digital infrastructure to stimulate innovation and investment.

Resilient communities

• NPF4 will move from a 5 year housing supply to consider a long term view of the homes required to 2040, considering location, quality and the type of homes needed.  
• New principle of 20 minute neighbourhoods to embed an infrastructure first principle - ensuring homes are built beside local infrastructure including schools, community facilities and working hubs, shops and healthcare. 
• A new focus on ‘place’ and reducing the need to travel – through detailed place-based policy.
• A brownfield first approach – preference for re-use of existing building, brownfield land and actively bring forward vacant and derelict sites.
• Maintaining natural infrastructure and promoting multi-functional blue and green networks, incorporating allotments and community growing spaces.
• A new policy to promote play and playability.
• Enabling greater participation into the design of spatial strategies and improving equality and eliminating discrimination to ensuring housing meets the needs of everyone.
• Focus upon health and wellbeing – promoting active travel and securing better air quality, minimising environmental hazards and pollution through quality design in sustainably accessible locations.
• Securing access to green space for mental and physical health.
• Tackling the impact of short–term lets in pressured areas through a framework for planning decisions.
• Promoting rural living and working, including a review of Wild Land policy to enable repopulation of rural Scotland whilst protecting the environment and landscapes.
• Updating Green bBelt policy – providing clarity on uses acceptable and its role as natural infrastructure.

The vision reflects the declared climate emergency and announcements from Scottish Government and Infrastructure Commission on the need for a Green Recovery. Indeed many of the key themes greatly assist the planning system adapt, with climate change/Global Climate Emergency, particularly for renewable energy development, becoming a material planning consideration in the determination of applications and the preparation of development plans. Moves to revisit the spatial framework for onshore wind, with potentially less restrictions (focusing only on the cited protection of National Parks and National Scenic Areas) are welcomed, as is a further commitment to consider Wild Land policy (albeit the focus of this is to allow rural repopulation) which has been a contentious restriction particularly in those parts which do have numerous man-made features. Recognition of the need to address new technologies and address strategic issues such as grid improvements within this new development plan document is also welcomed.

We are working with a range of clients with leading interests in energy, housing, food supply and strategic infrastructure, and are keenly aware that the new NPF4 will better support their visionary proposals to deliver energy transition, a move to net zero, deliver homes through a place-based approach and support a green recovery. Sadly these critical investments cannot be delayed as they wait for the planning system to evolve and the risk is that the current system will not support them in the same way. Our view is that every effort should be made to bring forward the new NPF4 to consultation stage without further debate, particularly given that consultation has already taken place.  

What does need to be debated instead is how the vision can be delivered. There is a general lack of resource and expertise within local government to address emerging technologies and the steep increase of application numbers which will be required to secure the energy transition and net zero targets. There is also an important shift required from decision making based on short-term visions set in the current development plan structure. Whilst there is a move to localism in the system, there must also be recognition that there are some difficult discussions and decisions to be made, that old Star Trek chestnut comes to mind “the needs of the many outweigh the needs of the few”, which is the key argument in balancing the impacts of strategically and nationally critical development on local communities and built/natural heritage interest in order to deliver targets.  

Responses to the interim statement are requested through the Scottish Government consultation hub until 19 February 2021. If you would like assistance in preparing a response to the Interim Statement, please get in touch with Lisa Russell.

2 December 2020