National Planning Framework 4
Posted on: March 31, 2022
Our response to the Scottish Government consultation on its NPF4 draft document
Public Consultation By: The Scottish Government
Overview: This consultation seeks views and comments on the draft National Planning Framework 4 (NPF4). When adopted, NPF4 will set out the Scottish Government’s priorities and policies for the planning system up to 2045 and their ambition to achieve a net zero, sustainable Scotland by the same year.
Opened for comments: 10 November 2021
Closing date for comments: 31 December 2022
(The following is a summary of our response to this consultation, read or download our full submission HERE).
These comments have been developed from substantial debate and deliberation led by the Cockburn’s Policy & Development Committee as well as in discussion and collaboration with the Edinburgh Civic Forum, which is a network organisation of over 100 civic groups, amenity societies, residents’ associations and community councils within the City of Edinburgh Council area. The Forum is administered by the Cockburn Association.
The Cockburn Association acknowledges the challenges in making a national spatial strategy relevant on a local level. It believes that the strategy, policies and projects that derive from the Framework will have a direct impact on local decision-making and local place-making.
Our main area of interest is the Central Urban transformation section of NPF4 and other areas of specific interest to Edinburgh – both city and city region. In addition, we have taken special interest in Part 3 of Framework, covering the National Planning Policy Handbook. Comments on Part 3 are covered is a separate document.
Overall, the Cockburn Association welcomes the general thrust and overall sentiment of NPF4.
In particular, the strategic ambitions to pioneer low-carbon, resilient urban living; reinvent and future-proof city centres; accelerate urban greening; rediscover urban coasts and waterfronts; reuse land and buildings; invest in net zero housing solutions; grow a wellbeing economy; reimagine development on the urban fringe; and improve urban accessibility are welcome.
Against this support for the generalised strategic thrust of NPF4, we are concerned with the lack of evidential assessment of delivery of NPF3. Without very clear analysis of the success or otherwise of NPF3, it is very difficult to consider the likelihood of success of NPF4. Also, whilst the positive rhetoric and narrative is compelling, polices and strategies are generally too caveated in terms of precision and language to give confidence in delivery.
In general terms, there is a lack of clarity on several key issues such as those noted below.
- Growth model and approach seems incompatible with zero-nett carbon/climate mitigation requirements, community wealth-building and other policy drivers. It is not clear how these potentially conflicting policy drivers are aligned to ensure support rather than conflict.
- No explanation in spatial or geo-political terms of the emphasis on Edinburgh City Region for population growth and enhanced development proposals, especially housebuilding. Edinburgh City is expected to deliver almost double the number of new houses as Glasgow (41,300 v 21,300) which rises to almost 3.5 times across the Edinburgh City Region (c.75,000). The linkages to infrastructure needs, land-use conflict (eg Urban Edge/Green Belt issues) and sustainable travel are not explored and are, in part, contradictory.
- Circular economy needs to focus more on Community Well-being and less of waste management. The core principles of “reduce, reuse and repair” are not strongly articulated across all aspects of the Framework. There is an opportunity to create far better connections between the circular economy, zero waste ambitions and the planning system. Policies should make more of positive carbon capture and management.
- Tourism features as an important sector for NPF4 to address. We would advocate that this policy should shift the emphasis towards ‘responsible tourism which amongst other things, seeks to minimise negative economic, environmental and social impacts; and generate greater economic benefits for local people and enhances the well-being of host communities. In this regard, we find the emphasis on Cruise tourism on the Edinburgh Waterfront national project unsupportable.
NPF4 is very light on the “how” as opposed to the “what”. It is also couched in a language the weakens delivery in terms of policy commitments. For example, strong statements like “‘We must embrace and deliver radical change so we can tackle and adapt to climate change” are undermined by non-directive words such ‘Encourage’ when referring to low- and zero-carbon design.’ The preparation of a National Action Plan with clear allocation of resources to achieve the strategies and policies contained within NPF4 will be required.
Although we appreciate that NPF4 is a national strategy and not meant to cover the ground occupied by Local Development Plans and strategies, it is a material consideration in planning matters and will have considerable influence.
We welcome that statement in the Framework, “as a capital city with a World Heritage Site at its core, it will be crucial that future development takes into account the capacity of the city [of Edinburgh] itself and its surrounding communities and makes the most of its exceptional heritage assets, places and cultural wealth.” In making this workable, it is therefore essential that an analysis of what is meant by “capacity” and how it is measured and defined is developed as part of NPF4. The concept of carrying capacity is embedded in ecosystem analysis but has not been developed as a useful tool for urban management. There is a very positive opportunity to create such a policy tool here which should be grasped, otherwise this statement will be little more than positive rhetoric.
We have already mentioned concerns about the emphasis of the Edinburgh City Region for population growth and housing building. The City of Edinburgh is expected over the next 10 years to accommodate an additional 41,300 new houses with the wider City Region taking 75,800. In comparison, Glasgow City is required under NPF4 to take on 21,300. There are concerns that this could lead to overdevelopment and might well undermine the delivery of related Scottish Planning Policies such as prevention of loss of prime agricultural land or Policy 29 on Urban edges and Green Belt, which will be subject to consider pressure from the private market-led housebuilders who might exploit this quantitative target as a means of justifying loss of prime land or Green Belt.
Strategic Approaches and Projects
In our internal and external discussion, the Cockburn has articulated these seven areas of strategic land-use or resourcing issues that should have greater emphasis in the framework or needs to be included as a major issue.
Maintenance & Repair as National Strategic project – the need to ensure existing places are fit for purpose and resilient completely missed in NPF4. It has been estimated that 72% of the buildings in the historic centre of Edinburgh are in need of significant repair due to a backlog of neglected maintenance work and the cost of basic road maintenance (potholes) is estimated to now cost £71m. Keeping our buildings and neighbourhoods in reasonable condition should be a firm objective of this Framework.
Sea Level rise as impact from Climate Change needs to be considered as a strategic land-use constraint in Spatial Strategy. The recent IPCC Report has suggested that it is now a matter of when, not if, that sea levels will rise. There is no indication of this significant issue featuring as a major land-use challenge. In supporting the development of Edinburgh’s Waterfront as a national development, it is essential for this to be factored into it.
Housing (Quality) – concern with emphasis on Built to Rent; no quality initiatives other than bland statements and reliance on Place Standard. Cost of Living pressures and affordability not addressed. Need to increase internal space standards and internal/external spaces to cope with emerging blended work patterns. Over reliance on commercial housebuilding sector to determine market need and land-use determinations suggests need to review definition of effective land supply.
Housing (Quantity) – major concern is concentration on City of Edinburgh/Edinburgh City Region for housing expansion with too great an emphasis on peripheral, suburban housing types. Weak links to infrastructure first approach. Lack of regional planning framework to ensure coordination. Poor link to 20-minute neighbourhood concept. Need to increase delivery of affordable and social house types in Edinburgh which suggests a different approach to the current market-led model. Current 25% threshold should not be reduced.
Food Security and Food deserts – Will be a significant issue in plan period; prefer an outright ban from using prime agricultural land for development, which implies fundamental review of spatial strategy within Central Urban Transformation area. Need to emphasise localism and links to poverty and food.
Energy Security – greater emphasis of integration of “passive house” standards in all housing developments; innovative renewals rollout including PV, micro-wind, etc. Development of Heat Networks as key national project.
Resources to deliver – there is no denying the fact that financial pressures on local authorities will inhibit delivery. The City of Edinburgh Council is one of the poorest resourced in Scotland, yet it is expected to shoulder significantly higher levels of national developments than others. Good planning requires adequate resources. National resources might be allocated to assist in upskilling planning authorities especially in areas of carbon management and climate preparedness.
View our full submission by clicking the box below.