Scottish organisations call for a pause on NPF4

Scotland's planning minister, Tom Arthur, has been urged to "press the pause button" on the development of National Planning Framework 4 (NPF4), amid concerns about what the framework and the Scottish Government intends to achieve.

In a letter to the minister the following organisations say that the means by which the core ambitions of NPF4 might be delivered need to be identified:

• Housing and Place Delivery Forum;
• Policy Scotland;
• University of Glasgow;
• Homes for Scotland;
• Chartered Institute of Housing;
• Robertson Residential Group Ltd;
• Skye Housing Association;
• Alliance of Local Authority Chief Housing Officers;
• RICS Scotland;
• Scottish Federation of Housing Associations.

Led by the University of Glasgow, the UK Collaborative Centre for Housing Evidence established a Housing and Place Delivery Forum in Scotland, which brought together a range of policy officials, professional practitioners and academics to meet and publish evidence-based papers and opinion pieces on housing and place matters.

The forum has written this letter in response to the draft NPF4, which was published in November 2021 for consultation. At the time, the Scottish Government said it was seeking to deliver good-quality homes that were close to local facilities and services, and would future-proof local liveability.

The organisations' responses highlight the lack of detail in the framework and lack of a clear delivery plan backed by financial commitments or an effective monitoring process. The forum also believes NPF4 must do more, among a number of other things to:

• consider the key determinants of the planning process, especially the country's changing population and demographics, and likely patterns of economic change;
• guarantee stronger strategy links with Housing to 2040, A Scotland for the Future, Scotland's National Strategy for Economic Transformation, and the Heat in Buildings Strategy;
• develop and articulate a more considered, professional basis for describing the policy and planning geography for the country to replace the existing ad hoc regionalisation at the core of NPF4's discussion of economic prospects;
• address the diverse needs of urban and rural Scotland, and the inter-relationships of regions, towns, cities and communities;
• articulate a clear way of regulating and monitoring design outcomes, particularly with the significant changes associated with "20-minute neighbourhoods";
• address the issue of local planning authorities' resources and capacity to deliver, and the contradictory policies that exacerbate rather than improve procedures and processes; and
• determine how, and where, strategic investment and infrastructure will be prioritised and funded.

The forum believes pausing the progression of NPF would allow the Scottish Government more time to consider these issues. Once paused the first step should be to engage further with all key stakeholders "to radically rethink the spatial and organisational framework for delivering NPF4".

Homes for Scotland (HFS) published its consultation response, which closed on 31 March and believed that the current draft "will likely reduce the number of homes delivered, thereby exacerbating the housing crisis".

HFS also notes that there is a failure to address the ongoing resourcing challenges within local authorities despite the fact the framework will add to planning officers' workloads.

Liz Hamilton, head of planning at HFS, commented: "Whilst we do welcome the focus upon the ‘deliverability’ of sites and broadly agree with the intent and purpose of several of the policies, we are extremely concerned that, as it currently stands, NPF4 will lead to significantly fewer homes being built".

"Indeed, it appears that Scotland’s housing crisis has been forgotten but this is equally as important as the climate emergency and nature crisis. A better balance must be struck to respond to all".

For more information on this subject, see:

• Scotland 2045 - Our Draft Fourth National Planning Framework;
• NPF4 Letter to Tom Arthur.