Policy Spotlight: Revised Draft National Planning Framework 4 – in brief!

Whilst more time is needed to do a thorough deep dive into the draft, a first read presents much to be celebrated.

Context:

In responding to the consultation on the initial draft at the start of the year, BEFS view – which was shaped by contributions from across the sector – was that the document contained significant omissions, such as references to key documents and policies for the historic environment, as well as the clear list of benefits that the historic environment assets deliver across multiple policy areas and towards Scotland’s national outcomes. Further, there was seen to be a lack of read across to the Local Development Planning Regulations and Guidance, in particular with regards to planning decisions that impact the existing and historic built environment.

There was also concern that the rapidity of the consultation and redrafting process – with consultation and Parliamentary scrutiny running simultaneously and not sequentially – would not allow for views and comments submitted as part of the consultation process to be fully taken into account. BEFS response can be found here.

As such, it should be noted – and applauded – that much of the feedback provided by the sector is recognisable within the revised draft.

The draft revised NPF4 – overview:

When eventually adopted NPF4 will replace NPF3 (2014) and Scottish Planning Policy (2014) and will therefore be part of the statutory development plan for any given area, along with the relevant Local Development Plans.

‘This creates a spatial framework for decision making that will support the delivery of a wide range of strategic priorities. In particular, climate change, nature recovery, inclusive growth, the wellbeing economy and child poverty have shaped the approach.’

Tackling the climate and nature crises, through climate mitigation and adaptation, sits front and centre within the policies in the draft. The revised draft NPF4 represents a significant landmark in recognising the role of the historic environment in tackling climate change; historic environment assets sit within Sustainable Places. Policy specifically advocating the re-use of existing buildings, capitalising on the embodied energy present within them, shows an explicit recognition of how the existing built environment is a central asset in reaching net zero – in particular, Policy 9 d) ‘Development proposals for the use of existing buildings will be supported, taking in to account their suitability for conversion to other uses. Given the need to conserve embodied energy, demolition will be regarded as the least preferred action.’

Part 1 – A National Spatial Strategy for Scotland introduces the main National Planning Policy areas: Sustainable Places, Liveable Places and Productive Places (Distinctive Places from the initial draft has been done away with as a separate policy area).

Care has been taken to show how these are all linked; particularly useful is the overview at the end of each introductory section clearly outlining the cross-cutting outcomes and policy links. This goes some way to addressing previous concerns that the historic and existing built environment sit distinct and therefore not fully integrated.

This section also includes details contained within

• National Spatial Strategy (Map)
• National Developments (Map)
• Regional Spatial Priorities

Part 2 – National Planning Policy details the individual policies within Sustainable, Liveable and Productive Places.

Further clarity is given in Part 2 by a new addition to the draft which provides an overview upfront of the policy intent and outcomes attached to the individual policies, alongside LDP requirements to support local decision making.

Issues around omissions of references to other key strategies, such as Housing 2040, have been largely addressed – and the impression is of a document aware of the wider policy landscape within which it sits.

For those that are still to sit down and fully take in Policy 7 – Historic Assets and Places, an overview is included here: 

Policy Intent:

To protect and enhance historic environment assets and places, and to enable positive change as a catalyst for the regeneration of places.

Policy Outcomes:

• The historic environment is valued, protected, and enhanced, supporting the transition to net zero and ensuring assets are resilient to current and future impacts of climate change.
• Redundant or neglected historic buildings are brought back into sustainable and productive uses.
• Recognise the social, environmental and economic value of the historic environment, to our economy and cultural identity.

The list of Policy connections included with each individual policy is a practical – and illustrative – approach to identifying just how integrated the various policies are. In the case of Policy 7, the list is long with the historic environment present or referred to in:

• Tackling the climate and nature crises
• Climate mitigation and adaptation
• Natural places
• Forestry, woodland and trees
• Green belts
• Brownfield, vacant and derelict land and empty buildings
• Coastal development
• Energy
• Design, quality and place
• Local Living and 20 minute neighbourhoods
• Infrastructure first
• Quality homes
• Rural homes
• Blue and green infrastructure
• Flood risk and water management
• Digital infrastructure
• Community wealth building
• City, town, local and commercial centres
• Rural development
• Tourism
• Culture and creativity

 Reference to proposals needing to be informed by national policy and guidance on managing change in the historic environment and the Historic Environment Record (HERs) will be welcomed by many, as will the updated language around potential impact, and strong wording on demolition and the criterion for retention, re-use and/or adaptation.

In summary, first impressions show the revised draft to be a much more accessible and useable document, that seeks to draw clear lines of sight to its own internal policy alignment but also with key external policies and strategies. Efficient use of existing resources is a recurring theme, placing the protection and enhancement of the historic environment centrally within what makes good places.

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Delivery:

Alongside the revised draft NPF4, a Delivery Plan detailing short and medium term actions for 2023 post adoption, has also been published. The aim is for the Delivery Programme to initially be reviewed and updated six months following adoption, and then annually.

Some key takeaways are the focus on successful collaboration and a requirement for clear governance, and the Delivery Programme provides an overview of actions to be taken to support the delivery of NPF4:

•  governance and collaboration;
•  delivery mechanisms;
•  infrastructure funding and finance;
•  skills and resources; and
•  monitoring and evaluation.

This includes the creation of a new a new Planning, Infrastructure and Place Advisory Group:

‘…a cross-cutting external stakeholder group whose primary focus will be to strengthen the alignment of NPF4, the Place Based Investment Programme and infrastructure investment. Specifically in relation to NPF4, the remit will be to oversee and advise on the delivery of the spatial strategy, National Developments and national planning policy.

Read the full Delivery Plan here.

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