Comment: The new National Planning Framework will alarm some and disappoint others

Part 1 of the Draft National Planning Framework (NPF4) immediately asserts that ‘We must embrace and deliver radical change so we can tackle and adapt to climate change, restore biodiversity loss, improve health and wellbeing, build a wellbeing economy and create great places.’

This call for radical change echoes the call in the UN’s New Urban Agenda (NUA) for ‘a paradigm shift based on the science of cities’.  The NUA identified five pillars for implementation: national urban policies, urban legislation and regulations, urban planning and design, local economy and municipal finance, and local implementation. All resonate within the Draft NPF4. 

The Draft NPF4 currently represents a shuffle along the road to the required paradigm shift. Can the current public consultation and the parliamentary scrutiny convert that to a confident step for planning in Scotland? Can the Scottish Government grasp the messages from urban scientists and move in pace with the UN?

NPF4 consciously tries to better integrate policy and plans and to work with the Place Principle agreed with COSLA, so that actions across a range of public services are complementary to each other.  This has been an aspiration of Scottish Government for some time, with its National Performance Framework.  

This approach makes sense, but is more easily said than done. Different services have different priorities, reflected in the weighting they attach to different National Outcomes. The desired outcomes from the planning system are contested more than is the case for perhaps any other public service. This makes preparation and agreement on NPF4 a significant challenge, and one that has fallen to a small but able team in Victoria Quay to resolve.

The 2019 Planning Act both exposed these tensions and set specific parameters for NPF4. The Bill had endured a rocky ride through parliament before the Conservatives reached an accommodation with the then minority SNP administration to carry it into legislation in the face of opposition.

Despite pleading from lawyers inside and outside government, and developers, the Act defined the purpose of planning as ‘to manage the development and use of land in the long term public interest’, specifying that this means anything which contributes to sustainable development or achieving National Outcomes.

However, this purpose only applies to development plans, of which the NPF becomes a part: development management decisions, which ultimately shape what development goes ahead where, are explicitly exempted from the requirement. While it is claimed that we have a ‘plan-led system’, this loophole and the mindset behind it, undermines the authority of development plans, and weakens the NPF itself, given the ways in which the system of planning appeals (and the threats to go to appeal) favour those with deep pockets when faced by councils with diminished resources.

Ministers decided to incorporate Scottish Planning Policies (SPPs) into NPF4. Such policies are thematic rather than spatial, i.e. they deal with topics like business and industrial development rather than setting out a position on the relationship between different parts of Scotland.  SPPs were last updated in 2014, and much has changed since then, further adding to the challenges and opportunities that NPF4 represents.

The Draft NPF4 will alarm some while disappointing others. It engages directly with the growing concerns over the climate and biodiversity emergencies, and takes planning into previously unknown territory with community wealth building and a circular economy. However, words like ‘should’, ‘encourage’ and ‘except’ leave wriggle room.

The way that a circular economy is perceived illustrates how far NPF4 has come, but also that the journey is not yet complete. The promise is of a just transition to ‘net zero, nature-positive places’ by a strategy ‘to transform the way we use our land and buildings’. However, the same paragraph ends with ‘we will encourage sustainable design and use of resources, including circular economy approaches to construction and development.’ When we know from the science that things need to change quickly, the question for a document focused on 2045 is ‘what if encouragement is not enough?’

Similarly, the way a circular economy is presented is rather limited. The Draft tends to equate a circular economy with waste management and the waste hierarchy – reduce / reuse / recycle. The recognition that this means reusing buildings and infrastructure, minimising demolition, recycling materials and supporting maintenance is indeed welcome. However, it also begs questions about how robust the skills of planners are on issues like embodied carbon.

More fundamentally, a more holistic understanding of a circular economy is needed. According to the Macarthur Foundation, ‘Transitioning to a circular economy entails decoupling economic activity from the consumption of finite resources.’ From a planning point of view, this means a conservation ethos should drive policies, yet for much of the Policy section it is a linear development ethos that leads.

A major challenge for the new NPF, therefore, is how to decouple economic activity from the consumption of land as a finite resource? The focus should be much more on better care of existing development and assets. It’s not just about Historic Environment Policy, though that itself gets rather marginalised. There also seems to be no direct connection to the work of the Scottish Land Commission.

The Housing Policy section, in particular, basically carries forward policies delivery mechanisms that, the evidence suggests, will not result in the kind of outcomes that are sought. For example, build-to-rent is commended, without recognising that steady rent rises driven by shortages of affordable housing are an integral part of the business model that is seeing international investors rushing to enter that market. This will undermine the aspirations for community wealth building, and recycling and local reinvestment.

Hopefully the wide consultation will result in some realigning within the planning policies section, so that NPF4 really does become the vehicle for transformation in Scottish planning.

Professor Cliff Hague is Emeritus Professor of Planning and Spatial Development at Heriot-Watt University. He will be speaking at Scotland: The Recovery - Planning for the Future, a Holyrood event.