The CIOB's response to the Scottish Government's Draft National Planning Framework 4

The CIOB has responded to the Scottish Government's National Planning Framework 4 (NPF4) consultation, which closed on 31st March. NPF4 will set out the Government's priorities and policies for the planning system through to 2045, becoming part of the statutory development plan. We were pleased to see a focus on place-based planning policy, and our response made recommendations regarding sustainability, land-use policy, quality, and equality, diversity and inclusion.   

Sustainability   

We were pleased to see the Government's focus on sustainability within the built environment to support net-zero targets and ensure that development contributes to the health and well-being of people and places. Our response welcomed the Government's recognition of the Global Climate Emergency and supported the strategy's ambition to facilitate the achievement of the UN Sustainable Development Goals. As we outlined in our response, meeting ambitious net-zero targets will require coordinated, long-term action, and various mechanisms will be needed to bring about the culture shift required to drive a greener built environment. As such, we made several policy recommendations we feel are necessary to achieve these targets:  

We called for the Government to adopt a numerical definition of Nearly Zero Energy Buildings (NZEBs) within national standards to help facilitate a regulatory environment that supports the construction industry to deliver them.   

In support of the Government's focus on the circular economy, we highlighted Policy S17, as published in the London Plan. We urged the Government to consider a similar policy to set requirements for the reuse and recycling of construction demolition waste.   

We highlighted the CIOB's support of a whole-life approach to the assessment of greenhouse gas emissions across the built environment. To that end, we called on the Government to prioritise policy that considers performance monitoring over the life span of buildings, considering greater use of post-occupancy evaluation of buildings and infrastructure. We further recommended that these assessments consider the performance of buildings across a wide range of measures, considering the wider benefits and costs generated by their construction and occupation.   

Place-based Approach   

We were glad to see the Government adopt a place-based approach to planning policy. Place provides a point at which creators of the built environment – planners, construction professionals, architects, designers, infrastructure providers, and sustainability professionals – can work together to deliver a sustainable environment. We supported the spatial principles outlined within the NPF4 strategy, which looks to deliver regionally focused development decisions responsive to local needs and challenges. Aligned to the Government's view, we believe no single policy or development can, on its own, create sustainable, liveable places. As such, we support planning policies that preserve the freedom to innovate and respond to regionally diverse needs and challenges.  

We welcome the Government’s focus on the well-being economy and recognition of the importance of a just transition to net-zero.  In our response, we highlighted our recent work on Equality, Diversity and Inclusion within the construction industry, including our recently published Diversity and Inclusion Charter. We support the Government's recognition of the importance of a just transition, ensuring that the climate change response must provide a better future for everyone.   

We further supported the Government's collaborative approach to planning policy, highlighting the Value Toolkit we developed with our partners, which advocates for public consultation throughout the journey of public and private projects.    

While we welcomed the emphasis on compact growth, we outlined that international evidence suggests that a policy to ensure compact growth through the planning system must consider the impact of land-use restrictions on land values. We called on the Government to ensure that land-use planning policy that limits urban expansion ensures that the resultant increase in land values associated with residential planning permission is democratised and that perverse incentives in terms of the final build product are avoided. Further, we outlined several international land-use policy examples that the Government could consider to mitigate any adverse impacts of compact growth policy on land values and development incentives.   

Quality   

The CIOB is committed to championing the importance of quality within the built environment and was pleased to see the strategy's commitment to high-quality design throughout the construction process. We further supported the strategy's inclusion of the six qualities of successful places.  
Our response advocated for a holistic approach to quality within the built environment that focuses not only on the build product but also on the build process. We urged the Government to take account of ethical development throughout all stages of construction, ensuring fair treatment and an inclusive environment for all individuals who engage with a project, from initial inception to lifetime occupancy. To this end, we further highlighted the work we've undertaken to champion Equality, Diversity and Inclusion, mental health and the eradication of modern slavery.    

We outlined one of the major barriers to good design and quality for builders of all sizes – land costs. In order to achieve the high-quality environment that the strategy prioritises, we urged the Government to take a proactive approach to the land market to deliver better quality and design for consumers.     

Housing   

The CIOB supported the Government's vision to provide "more and better homes" for Scotland and was happy to see a focus placed on delivering affordable, energy-efficient homes across the country. We outlined the vital role Scotland's existing housing stock will play in achieving net-zero targets. As such, we urged the Government to adopt a National Retrofit Strategy as a critical infrastructure priority to provide the certainty businesses need to create stable, green jobs and the confidence that consumers need to invest in whole-house retrofit projects.   

Overall, the CIOB was pleased with the priorities outlined within the Draft National Planning Framework 4. We will continue to engage with Government to provide information on the practical steps needed to support the industry's efforts to transition to green technologies, embrace sustainability and quality across the build process, and achieve the goals set out within the strategy.