Reflecting on the National Planning Framework 4

28 Nov 2022

The Fourth National Planning Framework (NPF4): revised draft was published 8 November 2022 and sets out a plan for Scotland to create sustainable, liveable and productive places to improve people’s lives. 

Bruce Wilson, Head of Policy and Advocacy at Scottish Wildlife Trust, represented LINK when giving evidence to the Local Government, Housing and Planning Committee on 22nd November. Bruce highlighted that LINK welcomes the changes made to significantly improve NPF4 and appreciates the work the Committee has done to ensure the planning system plays its part in restoring nature, as well as delivering for people and climate.  

Bruce highlighted that ‘the equal weight given to climate and nature in this revised draft is strongly welcomed.’ This provides clarity for decision-makers and recognises the interrelated nature of these issues. This is not to say that there will not be challenges in the implementation of the policies and much will depend on future guidance and decision-making. 

The revised draft strong step in the right direction to include a definition of nature-based solutions in line with the IUCN definition; ‘Nature-based solutions are actions to protect, sustainably manage, and restore natural and modified ecosystems that address societal challenges effectively and adaptively, simultaneously providing human wellbeing and biodiversity benefits. 

The strong policy wording on forestry and woodland is very welcome and has been strengthened since the last iteration of the Draft NPF4. For example:  

  • Provisions for ancient woodland and ancient and veteran trees have been improved even further, with the use of clearer language describing that developments will not be supported that impact on these habitats.  
  • Individual trees are highlighted in the document now, which is a positive improvement.  
  • Any land with existing woodland, or that has been identified as suitable for woodland creation must be enhanced, restored and should have additional trees integrated into development design. 


We welcome the intent of Policy 3, to protect biodiversity, reverse biodiversity loss, deliver positive effects from development and strengthen nature networks. Although nature networks are mentioned numerous times in this policy, it is not clear whether guidance will follow on this. NatureScot have been commissioned by the Scottish Government to develop and publish a national framework setting a clear vision, principles and approach for local delivery of Nature Networks in Scotland. It is disappointing that this is not mentioned in the Delivery Plan. 

Bruce highlighted that ‘we need to know the impact that we have created in order to have positive effects of biodiversity’ and ‘we can’t manage what we don’t measure and there isn’t enough emphasis on how we measure our biodiversity impact’. We must be very wary of claiming positive effects without strict obligations to first of all work out what biodiversity is being lost. 

The planning system doesn’t hold all the answers to solving the biodiversity crisis, but it has the potential to play a significant role to deliver meaningful change to protect and enhance Scotland’s nature. NPF4 is a crucial opportunity to ensure Scotland’s planning system delivers transformative, meaningful action for people, climate and nature. We will be looking closely at NPF4 to see if it delivers the transformational change promised. 


Juliet Caldwell, LINK’s Advocacy Officer


Image: Calum McLennan

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