The Local Government, Housing and Planning Committee, which was established by the Scottish Government in June 2021, is tasked with assessing the working of the country’s planning system (“the Committee”) and reporting its findings to the Scottish Ministers. One of its responsibilities is to review the functioning of the National Planning Framework in accordance with the provisions of section 3A of the Town and Country Planning (Scotland) Act 1997.
On 9 September 2025, following consultation with key stakeholders, including Homes for Scotland, Built Environment Forum Scotland, and the Royal Town Planning Institute in Scotland, the Committee submitted its Second Annual Review of the National Planning Framework 4 (“NPF4”) to the Minister for Public Finance, Mr Ivan McKee (“the Minister”). In it the Committee explained the issues which stakeholders were experiencing with the day to day working of the latest iteration of the national framework and made recommendations regarding how that experience might be improved. Points of principal concern related to the resourcing of planning departments, the issues surrounding the application by local authority planning departments (“LPAs”) of the new suite of national planning policies set out in Part 2 of NPF4, and the delivery of new NPF4 compliant local development plans (“LDPs”).
Resourcing of Planning Departments
The Committee highlighted the development industry’s long-standing concerns about the resourcing of planning departments across all LPA districts. While the third iteration of the NPF4 Delivery Programme introduced initiatives such as the appointment of a National Planning Improvement Champion and the promotion of attractive student bursaries, the evidence presented to the Committee led it to conclude that LPAs across Scotland continue to be under resourced.
Stakeholders reported a shortage of planners across Scotland; a factor that that was exacerbated by the early retirement of experienced senior managers and prolonged vacancy times. LPAs continued to face capacity challenges that significantly impacted on their ability to properly assess the additional raft of technical evidence that developers are expected to provide in relation to those NPF4’s policies that dealt with such matters as climate change, biodiversity enhancement and flood risk assessment. This lack of capacity had forced many LPAs to pass this evidence over to private sector consultancies for review, leading to delay and additional costs for applicants.
The Committee questioned the effectiveness of some of the initiatives that had been introduced by the Scottish Government to address the issue, such as the increase in planning application fees. Whilst acknowledging that it was perhaps too early to properly assess the impact of the increase on resource levels, the Committee also observed that the recent linking of planning fee increases to inflation merely maintained the ‘status quo’ resulting in Scotland falling behind England and Wales in terms of fee income generated. The need for planning fees to be hypothecated was also highlighted.
In his response to the Review, which was published on 20 October 2025, Mr McKee emphasised the Scottish Government’s ongoing recruitment efforts and highlighted the introduction of the National Planning Hub which is intended to provide LPAs with access to specialist expertise and practical support. In relation to the issue of application fee income, he noted that notwithstanding the fact that England and Wales had higher maximum fees, the actuality was that the fees charged by LPAs in Scotland for many development projects were often higher than the fees that their counterparts charged in England and Wales for developments of a similar scale. The Minister confirmed that the hypothecation of planning application fees to finance LPA resource requirements would be discussed with Heads of Planning Scotland (“HOPS”).
Implementation of NPF4
The Committee reported continued calls from developers for further guidance to be provided to LPAs as regards the application in the decision-making process of what were often perceived to be confusing or contradictory NPF4 policies. A common complaint noted by the Committee was that some LPAs adopted a rigid approach in terms of their application of certain policies which resulted in the rejection of development proposals that in all other respects were regarded as being fully policy compliant. Particular concern was raised about the ability of developers to bring forward small scale rural housing proposals, which, by dint of their rural location, would always be unable to meet the 20-minute neighbourhood principle set out in NPF4 Policy. NPF4 Policy 22 on Flood Risk and Water Management was also perceived to present a bulwark against the development of brownfield sites located in areas of identified flood risk that did not have the benefit of formal flood defences.
Stakeholders had also flagged inconsistencies in biodiversity requirements. The Committee drew the Minister’s attention to the fact that the national guidance on the subject presaged in the first annual review of NPF4 had still to be published. The result was that the issue was being given significant and overriding weight by some LPAs in the determination of planning applications and little weight by others. The lack of consistency was a cause for concern. The Committee expressed its concern too at the slow pace at which this much needed national guidance was being prepared.
In responding to these points, the Minister reiterated the advice given by the Chief Planner of Scotland to HOPS that NPF4 policies should be read as a whole, acknowledging that contradictions are normal in planning decisions. He also noted that the issues that key stakeholders had raised regarding NPF4 Policy 22 had been addressed in another recent letter from the Chief Planner and that no further guidance on flood risk is planned, that guidance on the application of NPF4 Policy 3 Biodiversity was in the process of being finalised, and that the Scottish Government’s Planning and Architecture Division would engage further with stakeholders regarding the practical application of the policy going forward.
Local Development Plans
The Committee noted that 20 out of Scotland’s 32 LPAs have outdated LDPs, with updates unlikely before 2028 – 2030. Stakeholders advised that this created uncertainty and with that uncertainty the deterrence of investment. Challenges included the gate check process, which had stalled the preparation of many LDPs. The Committee called for clearer guidance and organised sessions to support authorities.
The Minister, whilst acknowledging these concerns, explained that guidance on minimum gate check requirements had been issued and that training sessions with LPA development planners was ongoing. He also highlighted the fact that LPAs must now provide an update on the expected timescale for the delivery of their LDPs to the Scottish Government every six months.
Other themes raised included the complexity of local place plans, the housing emergency, the accessibility of NPF4 documents, and the lack of data on NPF4’s impact on the economy.
Concluding comments
The Second Annual Review indicates that while progress has been made in implementing NPF4, significant challenges remain. Resourcing constraints, delays in guidance, and the slow pace of updated LDPs risk undermining the framework’s ambitions. The Committee’s recommendations and the Minister’s response reflect a shared recognition that clarity, capacity, and consistency are critical to delivering on NPF4’s objectives. Continued collaboration amongst the Scottish Government, LPAs, and stakeholders will be essential to ensure that NPF4 achieves its declared policy outcomes.
If you would like to discuss NPF4 further, please get in touch with our Gillespie Macandrew Planning team.
*Originally published in the Scottish Planning and Environmental Law (SPEL) Journal in December 2025.
