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NPF4: Like NPF3, this plan will fail to deliver without clear capital investment programme

Published 04 April 2022 by Transform Scotland

Transform Scotland has today published its response to the Scottish Government consultation on National Planning Framework 4. Our conclusions are that:

  1. There are many positive developments in the proposed framework. We welcome the importance being attached to place-based approaches, especially by embedding the 20-minute ‘liveable’ neighbourhood approach and that sustainable transport through rapid transit networks, public transport and active travel are seen as nationally important developments. Having said that, the high-level policy statements could be supported by a greater clarity of definition and more helpful thematic integration.
  2. Delivery could be enhanced by greater collaboration in support of national developments and via a regional governance framework. The framework would be strengthened by an accompanying capital investment programme. Local decision-making would be improved through clear guidance on prioritisation and clarity of policy imperatives. The introduction of NPF4 should be supported by a resourcing and development plan for planners and planning related professionals that incorporates the key requirement of carbon literacy training.
  3. Finally, there is a need for a greater level of intersection with other significant strategic policy statements, including those made by the UK Government, such as the Community Renewal Fund, Levelling Up Strategy and Shared Prosperity Fund along with the City Region and Growth Deals, as these may well provide the channels of funding that are required to make a reality of the bold strategic vision provided within the draft NPF4 framework.

Transform director Colin Howden commented:

“The previous National Planning Framework, NPF3, aimed to deliver a greener, more integrated and more equal transport network, but in the intervening eight years since the publication of NPF3 there has been no significant change in in key Scottish transport indicators. Most damningly, there has been no reductions in climate emissions from transport.

“We need the new Planning Framework to be accompanied by a clear capital investment programme. The success of NPF4 will very much lie in the implementation of the plan and key to this will be the delivery of the national developments. To that end, we are concerned that none of the national developments appear in the 2021-22 Programme for Government, and the Infrastructure Investment Plan Scotland 2021-22 to 2025-26 only provides clear investment plans for Circular Economy Material Management Facilities, Digital Fibre Networks and the Dundee Waterfront. We are firmly of the view that there is a need for the Framework to be supported by a capital investment programme so as to ensure that its ambitions can be realised on the ground. 

“A key weakness in NPF4 relates to how the ambitions will be delivered and the timeline. NPF4 is clear that the climate emergency is the priority and that we have to make a rapid and just transition, but we do not have any sense of the timescales for delivery or of which interventions and projects will deliver the greatest reduction in emissions over time. We need to get a sense of that first. That is a big missing part of the agenda not just in NPF4 but also in other parts of the Scottish Government’s policies, such as Strategic Transport Projects Review 2 (STPR2) and the Traffic Reduction Plan.

“We’re pleased to see the inclusion of High Speed Rail within the suite of national developments as we have been disappointed at the seeming halt by Transport Scotland of the business case work to develop these proposals. This must form an essential and integrated part of a national spatial strategy that connects strategic places and supports sustainable, inclusive economic growth while reducing carbon emissions.  

“But investment is also required to provide more sustainable links between our cities and towns. As such, we have proposed that a further national development be included to bring about a major upgrade to the inter-city rail service between Scotland’s cities north of the Central Belt. Significant reductions in journey times could be achieved by the provision of dual track at selected locations and the reinstatement of a direct link between Inverkeithing and Perth by way of Kinross. This forms our ‘National Inter-City Rail Network’ proposal. 

“We also need to see enhanced rail freight capacity throughout Scotland in order reduce the volume of HGVs on roads and, as consequences, reduce greenhouse gas emissions and congestion on busier roads. So this is the focus of the ‘National Low-Carbon Freight Network’ national development proposal.”