As regular readers of our blog and Spotlights will know, March 2022 saw the end of almost 5 months of consultation on the draft fourth National Planning Framework (NPF4) which, once adopted, will become part of the Development Plan against which all planning applications will need to be assessed (with this expected to happen later this year). The Scottish Government is now analysing submissions made in response to the consultation but, while we are waiting for the outcome of that, what do we know about the general reaction to the draft? Has this broadly been welcomed, or will some of the responses come as somewhat of a punch in the mouth (albeit not literally in this case, unlike the fate that Mike Tyson may have faced) for those who drafted it?

From our point of view, we previously highlighted some of the challenges that the draft plan faces in our blog Draft NPF4 – a plan for all seasons?, particularly in terms of balancing its commitment to the delivery of net-zero, nature-positive places with sometimes potentially competing, but equally important, aspirations with regards to economic and social sustainability. As a result, while we welcomed the draft’s aim of transforming the way we use our land and buildings so that every planning decision contributes to making Scotland a sustainable place, our response to the consultation raised concerns about the extent to which NPF4 might actually deliver this. And it seems that we are not the only ones who think this way with, as highlighted in our April Spotlights, a number of high-profile stakeholders having raised questions about the implementation of NPF as currently drafted.

To give one example from our own response to the consultation, although the draft seeks to proactively enable the re-use of vacant and derelict land and buildings, our recent experience of working on a number of projects of this nature is that this will only be possible if planning authorities understand, and are required to take into account, the particular challenges that such proposals present when assessing them (this being something not currently acknowledged or required in the draft). In particular, we would have liked to see more support for positive changes to be made to historic buildings to ensure that these can be appropriately adapted to changing needs, recognising that this may require compromises to be made in some cases. There is, however, nothing in the draft that heralds any significant change in this respect, thus possibly limiting the potential contribution that historic buildings might continue to make to the places in which they are located.

In addition, in seeking to ensure that the journey to net-zero is a fair one, we would have liked the draft to have given more consideration to the interplay between land-use planning and the Scottish Government’s land reform and community empowerment agendas, recognising the respective scopes of each, and where and how they can combine to deliver more positive outcomes in terms of ensuring local people are more able to shape their places for more environmentally sustainable ways of living. And again, we understand that we are not alone in this view with, for example, the Development Trust Association Scotland (which supports development trusts across Scotland to deliver community-led regeneration) also having highlighted the need for NPF4 to complement existing community empowerment legislation in ways that it currently doesn’t, and taking the specific needs of different communities into account.

One matter of particular concern in respect of recognising the different needs of communities across Scotland is the way in which the draft champions the universal creation of 20-minute neighbourhoods (neighbourhoods within which people should be able to meet most of their daily needs without having to walk for more than 20 minutes) as a means of making places more resilient and sustainable. As an urban development model, there is of course a lot to commend the 20-minute neighbourhood concept in terms of, for example, reducing travel and hence carbon emissions, increasing active travel and improving health and wellbeing, increasing equality of access to services, and supporting local economic activity. Where concerns arise though is the absence of any guarantees about the quality of services which are accessible within 20 minutes, and that the concept doesn’t necessarily translate well to many existing communities, particularly in rural areas. Indeed, some consider that applying this to such communities risks exacerbating the centralisation of rural services and reinforcing barriers to addressing poverty and inequality in those areas, contrary to the express aspirations of NPF4 in these respects. This is a point which we believe merits more detailed consideration, so look out for a future blog with further thoughts on 20-minute neighbourhoods coming soon!

At the same time however, and in accordance with our own view, it seems to be widely accepted that there are a lot of positive elements to the draft NPF4, particularly in terms of the ambitious vision and aspirations of the Plan, and the commitment in that to addressing key challenges such as climate change, and inclusive growth, with concerns relating primarily to the detail of what is proposed and how this might be implemented rather than to the principle of this.

So, while some of the responses to the consultation may not make for easy reading for the Scottish Government, it seems unlikely that there will be any knock-out blows, but this of course remains to be seen when the results of the ongoing analysis are published.

Meantime, to find out how we can help with any aspect of the planning process, please visit our website or email us at Or, if you would like to see our other blogs or sign up for email updates, please click here.

Thanks for reading!

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