Scotland 2045 – Fourth National Planning Policy Framework “Nature Crisis”: What does it mean for ecologists and developers?

From incorporating biodiversity enhancement to strengthening Nature Networks, the new national planning policy might change how we look at biodiversity in development entirely.

On this page:
What does the policy say?
What does this mean for developers?
What does this mean for ecologists?

The Scottish Government has recently published their Draft Fourth National Planning Policy Framework. In this, there are strong requirements to include biodiversity assessment and enhancement within all development proposals. These, compared with the vagueness of the Third National Planning Policy Framework, set out a clear precedent for developers to consider how their proposals not just affect biodiversity, but can enhance and incorporate the natural world.

So what does the policy say?

NPPF 4 Part 3, Policy 3 is what we’ll look at in this blog. It is aptly named “Nature Crisis”. Within this, there are five lettered components which, summarised, say:

  • (a) Development Plans should Facilitate Biodiversity Enhancement, nature recovery, and nature restoration across the development plan area. This component places a requirement for Local development plans to consider how they can incorporate nature networks within these plans, how they can strengthen existing nature networks within their area, create new habitats for priority species, or improve and restore degraded habitats.
  • (b) Development Proposals should contribute to the enhancement of biodiversity. This places a requirement on developers, architects, and ecologists to include measures within development proposals which promote or incorporate biodiversity such as enhancement of habitats, or inclusion of biodiversity-friendly design.
  • (c) Potential adverse impacts of development proposals on biodiversity should be minimised. This strengthens the requirement to ensure that any effects of a proposed development are adequately mitigated and compensated. It includes wording which promotes the reversal of biodiversity loss, and maximises the potential for ecological restoration.
  • (d) Proposals of National, major, or EIA / Appropriate Assessment scale will only be considered where there is demonstrable conservation if- and enhancement of- biodiversity. This is perhaps the most significant component as it now places the requirement for major development not only to identify and assess the impacts of their proposals, but to fully incorporate, from the offset, measures which will improve the state of biodiversity, natural assets and natural networks within and around the development site.
  • (e) Proposals of local development should only be supported is they incorporate measures to enhance biodiversity in proportion to the nature and scale of the development (excluding fish farming or individual householder developments). This final point strengthens the requirement for local planning policy to ensure that any proposals received include some measure to incorporate biodiversity enhancement of the site and local area within a reasonable scale for the effects of the proposed development. Importantly – this does not impose biodiversity enhancement on individual householders looking for extensions or, presumably, conversions.

What does the new draft national planning policy mean for developers?

Well, developers at every scale will now need to consider, or even alter, their plans and proposals with reference to incorporating biodiversity enhancement and inclusion from the very earliest stages of their proposals.

It will likely mean that input from ecological consultants and biodiversity officers from the earliest stage of the planning process will become even more vital. This collaborative working should help developers identify the effects and mitigation requirements of development proposals, but also identify the opportunities to protect, enhance, and create biodiversity-friendly spaces and design within their proposals.

This new planning policy might see requirements imposed on developers at local scales to incorporate naturalised environments within landscaping, or to set aside areas of development footprints to create or strengthen natural corridors within the wider landscape. What is certain, is that the new planning policy will change how we design our developed landscape, and will empower developers to incorporate real nature-based design and solutions in their proposals.

What does the new draft national planning policy mean for ecologists?

Generally, a lot of us, as ecologists, look at the ways we can encourage our clients to make design choices that benefit species and biodiversity. This has always helped our clients with planning proposals and can offset some of the damage that is inevitably done during the development of each project.

We now need to consider, from the earliest stages of a development, that we are identifying the real-world, scaled opportunities for our clients to meet their obligations under the new planning policy.

This is likely to extend beyond the protected and notable species which we are so used to surveying for, assessing the impacts on, and mitigating. Biodiversity does not after all start and end at legally protected species. This new planning policy framework would appear to set out a strong precedent for us, as ecologists, to look at the entire ecosystem in our assessments and really work for our clients to drive positive, ecosystem-level consideration within their proposals and designs.

Does this new planning policy change the way you think about your role as an ecologist?

Often, we ecologists are the problem solvers who identify ecological constraints and the legislative and mitigative framework to help our clients can overcome these constraints. This new planning policy framework suggests that our role may change, to not only identifying and overcoming constraints, but to identifying opportunities and helping our clients from the earliest stages of their proposals to realise every project’s potential for biodiversity enhancement and incorporation.

The incorporation of biodiversity within design is something that we at EP Ecology are passionate about. We can proudly say that every report we have prepared for our direct clients to-date includes some recommended measures which go above and beyond simple mitigation and compensation.