Autumn is a season often associated with reflection and renewal and it is therefore apt that there have been various reports recently on how National Planning Framework 4 (NPF4) is performing in terms of delivering more housing to meet the housing emergency.
Local Government, Housing and Planning Committee
Over the summer, the Local Government, Housing and Planning Committee carried out its second annual review of NPF4, having earlier called for views from key stakeholders on issues arising from their engagement with NPF4.
On 9 September, the Convener of the Committee wrote to the Planning Minister setting out the Committee’s conclusions, concerns and recommendations and asking the Minister to provide updates on various matters relevant to housing. These included:
- concern at the pace at which guidance to support the implementation of NPF4 is being prepared and requesting details of work being done to assess the need for further guidance on local living and 20-minute neighbourhoods, flood risk and water management;
- concern about the number of out of date local development plans and the number of Evidence Reports failing the gatecheck procedure and requesting an update on the risk of having increasingly out of date plans;
- requesting an update on the 23 actions included in the Planning and Housing Emergency Delivery Plan as well as the Short Life Working Group on planning;
- concern that the focus has been on procedural aspects rather than the outcomes achieved by NPF4 and requesting an update on how the Scottish Government is progressing its work on developing its approach to monitoring and measuring progress on NPF4’s impact.
The Minister responded on 20 October, advising that there are no plans to issue further guidance on local living and flood risk at present and stating that it is the job of the planning officer and the decision-maker to consider all of the relevant policies in NPF4, recognising that for any application there will be policies for and against the proposal. Whilst consistency is important, the Minister was of the view that this has to be balanced with the need to allow for discretion in the system so that specific local circumstances can be taken into account as part of the assessment of each application on its individual merits.
On local development plans and gatechecks, the Minister advised that a session with local authorities on Evidence Reports has now taken place, and the Scottish Government has recently issued further guidance which builds on lessons learned and sets out the minimum requirements for gatechecks more clearly.
In respect of the housing emergency, the Minister confirmed that all 23 actions in the Planning and Housing Emergency Delivery Plan have been progressed (see below) and those requiring further work have been rolled forward into the Housing Emergency Action Plan.
He highlighted that the Scottish Government will be consulting this autumn on mechanisms to accelerate housing delivery and in the meantime, they are actively monitoring housing applications on non-allocated sites, to build a stronger evidence base on the impact of NPF4 Policy 16 in practice which will provide scope for Ministers to intervene, should the evidence suggest this is required.
Finally on the impact of NPF4, the Minister indicated that the work on monitoring NPF4 will be set out in the latest version of the NPF4 Delivery Programme and suggested that it will take time to see the legacy of the policies in our places and communities, given development timescales.
High Level Group on Planning Performance
Similar concerns about the slippage in the adoption of new LDPs and inconsistencies in the Gatecheck process have also been raised by the High Level Group on Planning Performance which published the minutes of their meeting on 25 September 2025. The Group comprises representatives from Scottish Government, public and private sector and third parties.
The Group suggested that transitional guidance pending the adoption of new LDPs would be useful for developers and more transparency on timescales for the LDP process would be helpful.
The Group also sought an update on actions to implement the Housing Emergency Action Plan and were advised that a Q&A document had been provided to Heads of Planning (HOPS) to support their understanding of the new notification requirement for application for 10 or more houses on unallocated sites.
Letter to HOPS and Q&A on notification of housing applications
In a letter to HOPS, the Chief Planner has advised that the notification requirement is not a call-in direction, nor a notification in advance of issuing a decision. There is no 28 day delay before decisions can be issued on relevant planning applications, but if through the monitoring of applications it becomes apparent that there are applications of interest, Ministers can issue specific call-ins before a decision is made/issued.
Scottish Government will also be monitoring relevant cases at appeal and may issue case specific re-calls.
The Chief Planner confirmed that the direction applies to all current undetermined applications and is expected to be temporary, to support monitoring of how NPF4 Policy 16 is being implemented in practice and is expected to be withdrawn once it has fulfilled its purpose.
Confirmation is also given that “non-allocated land” means land not allocated for housing in the LDP and the direction applies to applications for permission in principle where the number of housing units may not be specified and covers applications for houses, flats and student accommodation.
Clarification is given that the ambition set out in the Housing Emergency Plan to increase all tenure housing completions by 10% a year over the next 3 year period is distinct to targets within the statutory planning systems for the allocation of land and seeks to increase the pace of delivery across all sectors.
Planning and the Housing Emergency Delivery Plan – Actions Update
PARD issued a blog on 28 October providing an update on the 23 actions which were identified in the Planning and the Housing Emergency Delivery Plan in November 2024. Many of these actions have been reported in previous Home Reports, such as the Chief Planner letters on NPF4 being read as a whole; the housing notification direction; the blog on proportionality of planning assessments; and guidance on Masterplan Consent Areas.
In terms of upcoming actions, as referenced by the Planning Minister, the blog highlights that PARD will be consulting this autumn on “Accelerating Build Out”, exploring potential fiscal and legislative measures to increase the volume of housing delivery, including specific measures that could support SMEs.
Scottish Government has provided funding to assist HOPS with developing standard wording templates for common planning conditions and section 75 agreements so we may see progress on these actions.
Conclusion
Many people in the housebuilding sector no doubt share the Local Government, Housing and Planning Committee’s concerns that the Scottish Government’s focus has been on procedural aspects rather than the outcomes achieved by NPF4 and the actual delivery of more homes more quickly.
Despite the actions outlined in the various updates, since the housing emergency was announced in May 2024 the number of new build completions of all tenures has continued to fall (down 6% on last year) with private sector completions at their lowest since the year to the end of June 2018 and completions in the social sector at the lowest since the year to the end of 2017.
If these updates provide the autumnal reflections on how NPF4 is performing in respect delivering more homes, renewed urgency on turning the actions into roofs over head is surely called for before we enter another winter of housing discontent.
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