Assessment of Planning Application 26/0040/IC Against National Planning Framework 4 (NPF4)
 

1. Purpose of this page...

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This page summarises key planning considerations arising from National Planning Framework 4 (NPF4) and how they may apply to the proposed development at the West of Quarry Drive site.

 

The intention is not to challenge the principle of development already established through Planning Permission in Principle granted by Scottish Ministers in January 2023, but rather to highlight that current applications must still be assessed against the statutory development plan, which now includes National Planning Framework 4 (NPF4).

 

This means Inverclyde Council must assess the proposal against the relevant policies of National Planning Framework 4 when determining application 26/0040/IC.

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2. Status of National Planning Framework 4

NPF4 became part of the statutory development plan on 13 February 2023 - just 18 days after Planning Permission in Principle was granted by Scottish Ministers.

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Under the Town and Country Planning (Scotland) Act 1997, planning decisions must be made:

“in accordance with the development plan unless material considerations indicate otherwise.”

NPF4 now sits alongside the Local Development Plan (LDP) as part of that development plan.

Where there is any incompatibility between an older LDP policy and NPF4, the later policy prevails.

 

Many current Local Development Plans (including Inverclyde Council's) pre-date NPF4 and therefore planning authorities must ensure that proposals are fully tested against NPF4 policies.

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3. Key NPF4 Policies Relevant to the Site

Several policies appear particularly relevant when considering the characteristics of the site and its current use.

These include:

• Policy 3 – Biodiversity

• Policy 20 – Blue and Green Infrastructure

• Policy 21 – Play, Recreation and Sport

• Policy 22 – Flood Risk and Drainage

• Policy 14 – Design, Quality and Place

• Policy 16 – Quality Homes

Each of these is considered below.

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4. Policy 3 – Biodiversity

NPF4 represents a significant shift in Scottish planning policy by requiring positive enhancement of biodiversity rather than simply avoiding harm.

The policy states:

“Development proposals must contribute to the enhancement of biodiversity, including where relevant restoring degraded habitats and building and strengthening nature networks.”

The policy also states:

“Development proposals that will result in significant biodiversity loss will not be supported.”

Implications for the Meadows Site

From available information the site appears to contain:

• semi-natural meadow grassland

• established trees

• areas of wet or poorly drained ground

• habitat potentially used by wildlife.

Where development replaces existing semi-natural habitat with built form, planners must assess whether biodiversity enhancement is genuinely delivered.

This typically requires:

• ecological surveys

• biodiversity enhancement plans

• measures to strengthen local nature networks.

If biodiversity is simply reduced or fragmented, the proposal may conflict with Policy 3.

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5. Nature Networks

Policy 3 also requires development to contribute to:

“building and strengthening nature networks and the connections between them.”

Nature networks are ecological corridors that allow wildlife to move between habitats.

These may include:

• grassland areas

• woodland edges

• drainage corridors

• hedgerows

• wetlands

• connected green spaces.

Even where land is not formally designated, it may still form part of a local nature network.

If development fragments such a network through housing, roads, fencing or landscaping, planners must assess whether the proposal weakens ecological connectivity.

The correct planning test is therefore not simply whether the site contains ecological interest in isolation, but whether it forms part of a wider connected ecological system.

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6. Policy 20 – Blue and Green Infrastructure

NPF4 places strong emphasis on protecting and enhancing green infrastructure.

The policy states that development proposals should:

• protect and enhance blue and green infrastructure

• integrate nature and water management into development.

Blue and green infrastructure can include:

• natural drainage routes

• ponds and wetlands

• woodland belts

• green corridors

• informal greenspace used by communities.

Relevance to the Site

This Meadow land appears to function as part of a wider green corridor and contains retained trees and natural drainage features.

Development proposals must demonstrate that these features are protected and integrated rather than simply removed or reduced.

Loss of green infrastructure can conflict with Policy 20.

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7. Policy 21 – Play, Recreation and Sport

NPF4 recognises the importance of accessible outdoor space for community wellbeing.

The policy states that development proposals which result in the loss of recreational space will not be supported unless:

• the space is replaced by equivalent or better provision, or

• it can be demonstrated that the space is no longer required.

Importantly, the policy includes informal recreation, not just formal sports facilities.

Examples include:

• walking routes

• dog walking areas

• informal open space used by residents.

Evidence of Informal Recreation

The Meadow site appears to contain well-established informal paths (“desire paths”) created by residents walking across the land.

These paths can provide evidence that the land is used as a community greenspace.

If development results in the loss of such recreational space without a replacement provision, this could raise concerns under Policy 21.

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8. Policy 22 – Flood Risk and Drainage

NPF4 strengthens requirements relating to flood risk and surface water management.

The policy states that development proposals should:

• not increase flood risk elsewhere

• incorporate sustainable drainage systems (SuDS).

Where development occurs on land that contains natural drainage features or saturated soils, planners must be satisfied that:

• surface water runoff will not increase

• neighbouring land and properties will not experience increased flooding.

If drainage proposals are insufficient or unclear, this may raise issues under Policy 22.

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9. Policy 14 – Design, Quality and Place

NPF4 requires development to contribute positively to the quality of places.

Development proposals should support the six qualities of successful places:

• healthy

• pleasant

• connected

• distinctive

• sustainable

• adaptable.

Planning authorities should consider whether layouts dominated by:

• large areas of hardstanding

• garages in front gardens

• tightly packed housing layouts

create a high-quality residential environment consistent with these principles.

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10. Policy 16 – Quality Homes

This policy addresses the delivery of good-quality housing environments and an appropriate tenure mix.

One of the key principles is that affordable housing should be well integrated within developments.

Where affordable housing is clustered or segregated, this can undermine the objective of creating balanced communities.

Planning authorities should therefore assess the distribution of affordable housing within the site layout.

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11. Key Issues for Consideration

Based on the policies outlined above, several questions arise that the planning authority should address when assessing the proposal:

1. Does the development demonstrably enhance biodiversity, as required by NPF4 Policy 3?

2. Does the site form part of a local nature network, and would the proposal weaken that network?

3. Are existing green infrastructure features protected and enhanced?

4. Would the development result in the loss of informal recreational greenspace used by residents?

5. Have drainage and flood risk issues been fully addressed?

6. Does the layout provide high quality placemaking consistent with NPF4 principles?

7. Is the affordable housing integrated appropriately within the development?

 

12. Conclusion

While the principle of development on the site has previously been established, current proposals must still be assessed against the current statutory development plan, which includes National Planning Framework 4.

NPF4 introduces stronger policies relating to:

• biodiversity enhancement

• nature networks

• protection of green infrastructure

• recreational space

• sustainable drainage

• high-quality placemaking.

 

It is therefore important that the planning authority carefully tests the current proposal against these policies to ensure that the development aligns with the national planning framework now in force.

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