Sustrans Scotland is broadly supportive of the Draft Fourth National Planning Framework (Draft NPF4). Read our full response to the consultation below.
Sustrans Scotland is broadly supportive of the Draft Fourth National Planning Framework (Draft NPF4).
NPF4 aims to set out the Scottish Government's priorities and policies for the planning system up to 2045.
NPF4 differs from previous NPFs in two ways: it incorporates Scottish Planning Policy and the NPF into a single document and will form a part of the statutory development plan.
Welcoming the long-term vision
Sustrans Scotland welcomes the long-term vision to create better places focused on creating the conditions for lifelong health and wellbeing for all.
We support a place-based approach and welcome an emphasis on collaboration and cross-sectoral work across planning, transport, housing, regeneration and environmental policies.
The Framework recognises the importance of modal shift and requires active travel to be a consideration in every development, reducing the type of development that will increase car journeys and requiring the principles of 20-minute neighbourhoods to guide all local development.
However, we think that some areas could be improved:
Active travel routes to be safeguarded
We would recommend a policy be included that protects existing active travel routes from the consequences of other development.
The National Cycle Network (the Network) is regularly impacted by a range of planning applications that can affect route alignment or accessibility.
Sustrans engages positively with developers and planning departments, but active travel infrastructure such as the Network is not protected in the same way as roads or rail.
We would ask for a policy that can safeguard active travel routes – including those classified as the proposed National Walking, Cycling and Wheeling Network.
This would protect them from removal and encourage developers to mitigate any negative impact by at least maintaining current level of utility of a route or improving on it.
We note similar policies are being used to protect open space and play areas and would recommend the same level of protection.
Importance of accessibility
We recommend that any development proposal should be fully accessible to qualify as part of a national network.
Adding promotion of amenities to support active travel
We would recommend the policy promote amenities that support active travel infrastructure, including charging stations, repair facilities and other supports.
It could be anticipated that increases in cycling will require more extensive parking and storage, for example in city centres, and this could usefully be supported by the policy.