NPF4 – Focus on Climate Change

18 Dec 2023

Cornerstone Climate

Johanna Boyd

In the second of two blog posts, associate member Johanna Boyd, who is the Chief Executive of Planning Aid Scotland, explains how NPF4 aims to ensure that Scotland’s future communities will be net zero, nature-positive places that are designed to reduce emissions and adapt to the impacts of climate change, whilst protecting and restoring the environment in Scotland.

Read the first blog post here.

NPF4, adopted by Scottish Ministers in February 2023, sets the National Spatial Strategy for Scotland until 2045. It consists of 6 spatial principles (just transition, conserving and recycling assets, local living, compact urban growth, rebalanced development and rural revitalisation), 18 National Developments and 33 National Planning policies.

Outcomes for Scotland

NPF4 is required by law (section 2(4) of the Planning (Scotland) Act 2019 (the 2019 Act)) to contribute to 6 outcomes for Scotland:

  • meeting the housing needs of people living in Scotland including, in particular, the housing needs for older people and disabled people,
  • improving the health and wellbeing of people living in Scotland,
  • increasing the population of rural areas of Scotland,
  • improving equality and eliminating discrimination,
  • meeting any targets relating to the reduction of emissions of greenhouse gases, within the meaning of the Climate Change (Scotland) Act 2009, and
  • securing positive effects for biodiversity.

There are three overarching themes contained in NPF4 of sustainable places, liveable places and productive places. Each of the 33 National Planning policies and National Developments are grouped underneath one of the three key themes.

33 National Planning Policies

It is important to note that the 33 National Planning policies will be used across the whole of Scotland in the determination of planning applications, by developers in promoting development proposals, in representations/objections to planning applications and in the determination of planning appeals.

Here we can see policy control in Scotland shifting from 34 planning authorities (32 Councils and 2 National Parks) to the Scottish Government (SG). Time will tell whether this shift in who sets planning policy has a positive impact in terms of meeting Scotland’s net zero targets.

In ordinary times any centralising step taken by SG is met with resistance from Scottish Local Government (via COSLA) but this does not seem to have been the case here. Perhaps this is an indication of the urgent need for a unified approach across the two spheres of government in the face of the colossal global challenge that is climate change.

Training, brave decision-making and climate leadership

The interpretation and application of policy remains the job of Council planners, Councillors, reporters (or planning inspectors as they are known in England and Wales) and the courts. This raises an important question around the depth of understanding of all decision-makers in the planning system of the policy intent behind NPF4. It will require expert training (a key part of Planning Aid’s work) and brave decision-making.

Mandatory elected member training was included in the 2019 Act which means that Councillors are prohibited from carrying out certain planning functions if they have not completed training specified by Scottish Ministers. The consultation on how this could be implemented is now closed and we await the outcome from representations (including ours) made.

The Centrality of Climate Change in NPF4

The Ministerial Foreword to NPF4 itself makes clear that: “Planning carries great responsibility – decisions about development will impact on generations to come. Putting the twin global climate and nature crises at the heart of our vision for a future Scotland will ensure the decisions we make today will be in the long-term interest of our country.”

And in paragraph 1 of Part 1 of NPF4 (page 3) it says, “The world is facing unprecedented challenges. The global climate emergency means that we need to reduce greenhouse gas emissions and adapt to the future impacts of climate change. We will need to respond to a growing nature crisis, and to work together to enable development that addresses the social and economic legacy of the coronavirus pandemic, the cost crisis and longstanding inequality.”

The central importance in NPF4 of tackling climate change could not be clearer. It is foundational to the framework. The reduction of greenhouse gases is the first cross-cutting outcome to be found (page 8) and again makes clear that the global climate emergency and the nature crisis have formed the foundations for the spatial strategy as a whole.

It is therefore no surprise that Policy 1 of NPF4 deals with tackling the twin crises and makes clear that LDPs “must address the global climate emergency and nature crisis by ensuring the spatial strategy will reduce emissions and adapt to current and future risks of climate change by promoting recovery and restoration in the area.” Policy 1 itself provides that: “When considering all development proposals significant weight will be given to the global climate and nature crises.”

Policy 1 is also unique when compared with the other National Planning Policies in that it is the only policy that cuts across all others within NPF4 (page 36).

Contrast with English Position

This very strong and clear policy wording (although given its infancy untested as yet to its meaning and application) can be contrasted with the considerably weaker position in England.

When determining individual planning applications, English planning authorities can (but are not obliged) to take account of the need to mitigate against and adapt to climate change. If DP policies require those matters to be taken into account, then decision makers must do so (section 38(6) of the Planning and Compulsory Purchase Act 2004) but no particular planning weight is afforded to those considerations when placed in the planning balance.

Material considerations (such as the recently updated National Planning Policy Framework) might assist but do not mandate net zero considerations in all decision making.

Climate Ambition for Scotland

At present Scotland’s climate ambitions can be summarised as:

  • Net zero by 2045
  • 70% waste recycled / end to landfill of bio waste by 2025
  • 20% reduction in car km by 2030
  • 50% buildings with zero emissions heating by 2030
  • 20GW renewable electricity by 2030
    • 8-11GW offshore wind
    • Further 12GW onshore wind
    • 2GW community owned energy
  • 5GW hydrogen production capacity by 2045
  • Carbon capture and storage
  • Peatland restoration at scale
  • Woodland expansion at scale

This now sits within the context of the recent UN Environment Programme annual Emissions Gap Report which has found that we are headed for a temperature rise above the Paris Agreement goals unless countries deliver more than they have promised.

UK Audit of 4 UK nations on Net Zero

A recent publication by the UK audit offices is the first time that there has been an audited process of how the four nations are performing collectively and individually on achieving net zero.

Some interesting statistics can be noted from the report when comparing highest-emitting sectors across the 4 nations. Energy supply is the #1 emitter in Wales and #2 in England versus #5 in Scotland. Transport ranks #1 or #2 in all nations except Wales where it is #4. Agriculture ranks #5 in England but #1 in Northern Ireland.

Overall Scotland’s emissions fell by 49.9% between 1990 and 2021. However, this came up just short of the 51.1% target set. In England, emissions fell by 48.8% against a 1990 baseline. There were no distinguishable interim targets for England.

It is notable that that whilst there is a fairly detailed discussion in the audit report about the strategies and policies in Scotland underpinning decarbonisation, there is no mention of NPF4. Given its importance, this should be rectified in follow-up audit reports.

In the fight against climate change, NPF4 and planning have a pivotal role to play. We now possess a solid policy foundation in Scotland upon which to build. Alongside well-trained, brave decision-makers, I believe we can realise our climate change ambitions, inspire and show leadership to all nations within the UK.