Draft NPF4: Towards a Joined-Up Response
Hazel Johnson, Policy & Strategy Manager, sets out the initial results of BEFS NPF4 engagement and outlines the work ahead.
Back at the start of November 2021, the much anticipated draft National Planning Framework 4 (NPF4) was launched for consultation. The deadline for responding is the 31st of March – now marked with a red circle in diaries and calendars across the sector. The end of 2021 saw plans laid and conversations begun to allow the new year to start with a bang, as we work towards a joined up sector response, collectively championing the existing and historic built environment within this important planning document. It has been a busy few weeks.
At the start of January, BEFS chaired a roundtable discussion to inform a response to the Committee for Local Government, Housing and Planning Call for Views which was submitted for the 10th January deadline.
This initial response outlines key areas of interest and concerns felt by the sector, and we will be building on this over the coming weeks.
Overview of the draft NPF4
This new draft incorporates elements of previous National Planning Frameworks and Scottish Planning Policy (SPP); it provides a long-term plan for Scotland which sets out where development and infrastructure are needed. The NPF4 will also guide spatial development, set out national planning policies, designate national developments and highlight regional spatial priorities. As such great scrutiny and care will be given to assessing whether the NPF4 provides the coherence, clarity and detail required by decision makers throughout planning.
The draft document is structured in four parts:
- Part 1 – A National Spatial Strategy for Scotland 2045
- Part 2 – National Developments
- Part 3 – National Planning Policy
- Part 4 – Delivering Our Spatial Strategy
The four main themes within the Spatial Strategy are Sustainable, Liveable, Productive, and Distinctive places. The historic environment – whilst well represented within Distinctive Places – isn’t currently as present within Sustainable, Liveable, and Productive Places.
Despite this, there is generally much to be praised in the draft NPF4’s approach to protections for the historic and existing built environment. Where it perhaps falls down is in how it all hangs together and how the different sections relate to each other. Some omissions prompt additional concerns; for example, there is no meaningful reference to the wider policy landscape and other key policies such as the Historic Environment Policy for Scotland (HEPS), Planning Advice Notes and other documents signposted in SPP. This is underlined by a lack of clarity of status, consistency and read-across of Parts 1 and 2 into Part 3.
The sector has an opportunity here to raise up the very real benefit and contribution that the historic and existing built environment make, advocating for their representation across the piece, within sustainable development, homes, climate change, jobs and infrastructure. It is perhaps worth noting that the Position Statement in February 2021 was a much stronger on this, with the draft NPF4 seeming to step back on some of the positive approach seen previously.
The 35 policies contained in Part 3 of the draft NPF4 are well intentioned and the overall direction is to be welcomed. A good starting point for anyone tight on time will be Policy 28 – Historic Assets and Places. Once again though, the issue is one of consistency and coherence; how these polices relate to each other should give us pause to consider whether this could lead them to be ‘traded’, due to the contradictions inherent in them. Over the coming weeks thought will need to be given to clarity of language, and further clarity sought on hierarchy throughout the strategies and policies in NPF4.
At the start of 2021 the Position Statement indicated that the draft NPF4 would include a Delivery Programme. Perhaps not unsurprisingly given the scale and ambition of the document, it doesn’t do this – however the draft does state that a detailed Delivery Programme and Engagement Programme will be produced once the framework is adopted.
Without knowing what this might look like it is hard to draw any firm conclusions, other than to wonder how the somewhat aspirational strategies and aims outlined in the draft document can be adopted post March without transparency on how they will be delivered, including whether the necessary resource, supply chains, skills and budget can be found.
Get involved – a joined up sector response
Further discussion of the draft NPF4 will take place at the next Historic Environment Working Group in February, and we’ll also welcome wider participation from stakeholders at a round table in early March – details of this to follow soon. For any organisations and individuals preparing their own response, that would like to get in touch, BEFS will be glad to hear from you!
There is much to be optimistic about – the draft NPF4 has climate change, good places and sustainability at its heart, and has clearly sought to carry over key protections for decision making for the historic environment. The need to value, enhance, conserve and celebrate the historic and existing built environment is recognised, but within this the benefits of embodied energy, skills/employment and the role existing buildings and infrastructure can play towards meeting net-zero are not yet articulated.
We can build on the many positives; seek to highlight inconsistencies in the draft; show how the spatial strategies and polices can be fully integrated and look towards clear articulation of policy hierarchy. By presenting evidence and a united advocacy for our existing built environment we could see the NPF4 delivering, across the board.BACK