The revised draft of the Fourth National Planning Framework (NPF4), which was first laid before the Scottish Parliament in November 2022, has now been formally adopted following a period of consideration and approved by vote in January. Promising a "fairer, greener Scotland we want to see for the benefit of future generations", this now replaces the National Planning Framework 3, the four Scottish Strategic Development Plans (SDPs, covering the four largest city regions in Scotland), and incorporating the Scottish Planning Policy framework.
This new framework represents a more streamlined, overarching strategy approach that addresses spatial and thematic planning policies in one place. NPF4 has increased status and will be assessed alongside the applicable Local Authority Development Plan in the assessment of planning applications, meaning that its policies have a stronger role in day-to-day planning decision-making.
Setting out Scotland's spatial vision for 2050, NPF4 aims to encourage the planning system to stimulate investment and economic growth by providing certainty for investors whilst also providing increased flexibility in policy terms to allow the planning system to respond more effectively to market opportunities as they emerge. The City of Edinburgh Council has already sought an updated policy position against the content of NPF4 from all agents with applications already submitted but not yet determined.
The NPF4's approval comes at a time of widespread economic and political uncertainty in Scotland and the United Kingdom, from rent freezes and subsequent U-turns, the implementation of short-term let control areas, to local authority resourcing deficiencies and a worrying decline in urban planner recruitment. Considering this unstable backdrop, NPF4 may face a challenging start at the outset of its lifespan. We will likely see a 'snagging period' for developers and Local Planning Authorities alike, where new proposals will have to negotiate both the requirements of the approved NPF4, current and emerging Local Development Plans (LDPs), and the current political, environmental and economic climate.
Regarding the contents of the document itself, there are certain policies that may cause friction with adopted and emerging LDPs moving forward. An example of this includes the emerging NPF4 stance on the use of brownfield sites. NPF4 requires that the biodiversity value of brownfield land which has naturalised be considered in determining if the reuse of a site is sustainable. It might be argued that this represents a surprising additional policy obstacle to overcome, given the general focus on prioritising brownfield over greenfield.
NPF4 also seeks to impose a minimum 25% affordable housing requirement Scotland-wide, with the potential for a higher contribution if justified by evidence of need. This will likely affect development viability in areas with no or lower current affordable housing requirements, such as Glasgow, Dundee and Fife.
The National Spatial Strategy, as set out within NPF4, recognises the impacts of the pandemic on the social and cultural make-up of Scotland's towns and cities under Productive Places. It notes that development proposals that improve the vitality and viability of city, town and local centres, including by extending the mix of types of development, should be supported. This positive policy shift explicitly supports a much wider range of appropriate town centre uses beyond retail.
Overall, the adopted NPF4 represents a considerable top-down change to planning and development in Scotland, setting out how Scotland aims to reach its net-zero carbon target by 2045. Covering the entire country, NPF4 will impact all levels, areas and sectors of the planning system in Scotland. How the property market reacts to NPF4 is yet to be fully understood.