A stronger Fourth National Planning Framework for nature, climate and people

The Scottish Government recently published a revised draft of the Fourth National Planning Framework (NPF4) which is currently undergoing scrutiny in the Scottish Parliament. Niamh Coyne, Conservation Planner at RSPB Scotland, explains why NPF4 is so important and why this redraft has the potential to deliver transformative change for Scotland’s planning system for nature, climate and people.

Back in March 2022, RSPB Scotland submitted a response to the consultation on the draft NPF4. As a national policy document and strategic plan, this will guide and inform all sorts of infrastructure and built development projects across Scotland for the next decade and beyond. Along with many others across numerous sectors, we were disappointed with the draft. There was a serious lack of clarity in wording, a failure to recognise the nature crisis as equally important to the climate crisis and lack of robust policy wording in relation to our legally protected nature sites. Alongside our response, we handed in postcards to the Local Government Housing and Planning (LGHP) Committee at the Scottish Parliament to show how many people value nature and don’t want to see it damaged by inappropriate development.

What makes NPF4 so important?

At first it may not sound terribly exciting! But NPF4, and, more widely, planning, is absolutely vital in the realisation of a nature rich future. Planning decisions and planning policy affect so many aspects of our daily lives in ways we might not notice. From the shops and cafes in our towns and cities and the homes we live in, to wind farms that generate clean, green energy and the protection of significant wildlife and habitats in Scotland – planning has the potential to make this the best it can be. But to do this, we need strong planning policy at a national level. This is where NPF4 comes in.

A stronger-looking revised NPF4

We are pleased that most of the concerns we raised during the consultation have been addressed in the revised draft NPF4. For example, it now requires ’significant weight’ to be given to both the global climate emergency and the nature crisis when decisions are being made on planning applications. This is a hugely positive change which recognises the nature and climate crises are intertwined and a great win for the many environmental charities who campaigned tirelessly throughout the consultation process for this dual recognition. There is also a requirement for developments to deliver biodiversity enhancement which is a very exciting change and, along with nature networks, means planning has the potential to make a real difference to halting the current alarming rate of biodiversity loss.

Overall, we welcome the positive changes made to NPF4 since the earlier draft. Nevertheless, we are disappointed and concerned about the policy wording in relation to protected European Sites in Policy 4(b). European sites are made up of Special Protection Areas (SPA) and Special Areas of Conservation (SAC). These areas are protected for their threatened animals, birds, plants and habitats of particular international importance. These designations support conservation and are some of our best places for nature.

Our concern is that the policy does not make it clear to developers or the public that criteria specified in legal documents has to be met before development of European sites can be approved. These concerns are in the context of threats to the Habitats Regulations from the UK government via Retained EU Law Bill 2022 (REUL). You can read more about this here.

What next?

Unfortunately, there is no opportunity for further public consultation on the revised draft and so, there is no way to make amendments at this stage.  Once the six-week parliamentary scrutiny period is complete, the Scottish Government can ask Parliament to vote to approve the revised draft NPF4 or reject it. Assuming it is approved, NPF4 can then be formally adopted and will become part of future Local Development Plans across the whole of Scotland.    

However, there is still much to do to ensure the positive words and ambitions of the revised draft NPF4 are realised: RSPB Scotland will continue to engage where possible with delivery of NPF4 in the future, as we expect to see a range of guidance coming forward to support the document and its delivery programme. The real test of NPF4’s success will be the planning decisions that are made in the coming years. We hope that in ten years’ time the real benefits for people and nature will be evident, and Scotland’s planning system will be at the forefront of action to deliver a nature-positive, net-zero nation.