Scotland draft National Planning Framework 4 (NPF4): What does it mean for Natural Capital, Biodiversity and the Environmental sector?

The National Planning Framework 4 (NPF4) details Scotland’s long-term plans and aspirations until 2045 and is open for feedback[1] until 31 March 2022. 

Once adopted NPF4 will become part of Scotland’s statutory development plan and will directly influence planning decisions. Therefore, its content and wording with regard to biodiversity and natural capital have significant implications for how these topics will need to be considered and addressed within the planning system going forward.

NFP4's Emphasis on Biodiversity and Natural Capital

NFP4 was laid before the Scottish Parliament on 10 November 2021 and throughout the draft there is a particular emphasis on securing positive outcomes for natural capital and biodiversity. The opening paragraph of Part 1 sets the tone:

“We must embrace and deliver radical change so we can tackle and adapt to climate change, restore biodiversity loss, improve health and wellbeing, build a wellbeing economy and create great places.”

Targets for biodiversity will be set out in a new Scottish Biodiversity Strategy for 2030[2], which will standalone completely replacing all previous strategies and plans[3],[4]. The aim is for this to be published within 12 months of COP15[5] (biodiversity), which will conclude on 8th May 2022.

Biodiversity Enhancement for All Developments

In a distinct departure from current practice, NFP4 sets out a requirement for biodiversity enhancement for all developments (with the exception of fish/ shellfish farms and householder applications). Key policy relating to biodiversity is set out under Policy 3 Nature Crisis. This states that:

“Development proposals for national, major and of EIA[6] development or development for which an Appropriate Assessment is required should only be supported where it can be demonstrated that the proposal will conserve and enhance biodiversity, including nature networks within and adjacent to the site, so that they are in a demonstrably better state than without intervention, including through future management.”

Policy 3 goes on to clarify that biodiversity enhancement should be significant, go beyond any proposed mitigation, be secured within a reasonable timescale and include management arrangements for their long-term retention and monitoring. More detailed requirements include consideration of local distinctiveness, irreplaceable habitats, best use of nature-based solutions, and habitat connectivity.

Policies

This is a clear departure from the current reality where Environmental Impact Assessment (EIA) projects, whilst encouraged to provide biodiversity benefit, are only required to have ‘no significant ecological impacts.’ NFP4 will require a shift in mindsets and joined up collaborative thinking, to maximise the benefits of biodiversity enhancements for nature and people. The aim of securing positive effects for biodiversity is also evident in policies on Blue and Green Infrastructure (Policy 12); Natural Places (Policy 32); and Trees, Woodland and Forestry (Policy 34).

Measuring Biodiversity

NFP4 doesn’t stipulate how biodiversity should be measured, however we anticipate that this will be clarified in the new biodiversity strategy and will include the use of a metric-based approach similar to the DEFRA metric[7] that is already being used in England, albeit modified to be more appropriate to the Scottish context[8]. It may also be adapted to consider the value of other ecosystems service in addition to biodiversity.

The Impacts of Climate Change on Scotland

NFP4 also notes that the locked-in impacts of climate change in Scotland include increased flooding, water scarcity, environmental change, coastal erosion, impacts on forestry and agriculture, extreme weather events, and risks to health, food security and safety. It goes on to acknowledge that natural capital underpins the Scottish economy and reiterates the need to invest in nature-based solutions to mitigate climate change and address biodiversity loss and thereby safeguard the economy, and health and wellbeing.

Achievement of NPF4 requirements will necessitate significant education and development in the environmental sector. This will include training new and existing practitioners, farmers, landowners and other stakeholders in policy requirements and techniques; and better databases of new and existing habitats and natural capital projects to facilitate a joined-up approach, where adjacent projects support and do not undermine one another.

SLR are engaged with a range of clients across Scotland to deliver biodiversity and natural capital projects at a range of scales; from looking at biodiversity and other potential ecosystem services gains in farmland in relation to food supply chains, to large-scale habitat restoration and enhancement projects and compensation and off-setting for large developments.

Our interdisciplinary team facilitate a 360o approach, so that habitat and ecosystem restoration plans are practical, deliverable, locally distinct ecologically and in terms of landscape and cultural heritage. In particular we seek to avoid single service (e.g. carbon) tunnel vision and consider all the ecosystem service benefits that a site can offer, from nutrient neutrality and disaster resilience to cultural heritage, recreation and food provisioning. We offer a full life-cycle service from conception and design to post-implementation monitoring. We are always pleased to talk to organisations about how natural capital and biodiversity link with their business interests and ESG targets. If you would like to discuss potential projects or collaborations with us, please get in touch.

At SLR we are looking forward to continuing to work with our clients, collaborators, and other professionals in the environmental sector to deliver the positive aspirations of NFP4, for nature and people.

References:

[1] https://www.gov.scot/isbn/9781802012446

[2] https://www.gov.scot/publications/scottish-biodiversity-strategy-post-2020-statement-intent/pages/6/

[3] https://www.gov.scot/publications/scotlands-biodiversity---its-in-your-hands/

[4] https://www.gov.scot/publications/2020-challenge-scotlands-biodiversity-strategy-conservation-enhancement-biodiversity-scotland/

[5] https://unric.org/en/cop15-cop26-why-two-cops-2/

[6] Environmental Impact Assessment (EIA)

[7] http://publications.naturalengland.org.uk/publication/6049804846366720

[8] https://naturalcapitalscotland.com/article/guest-blog--biodiversity-net-gain/