CIEEM response to the review of implementation of NPF4

Here you will find our response to Local Government, Housing and Planning Committee call for views on the implementation of NPF4 and the progress made over the past year (closed 7th March 2025).

This response was developed by our Scotland Policy Group.

Policy 3

Implementation Concerns

  • Lack of clear guidance on metrics and interim measures for biodiversity enhancements

  • Inconsistent approaches among Local Planning Authorities (LPAs)

  • Ambiguity for developers about what constitutes “significant” enhancements

Capacity Issues

  • Lack of capacity in LPAs undermines NPF4 implementation

  • Insufficient enforcement staff and ecological expertise in many LPAs

Recommendations

  • Provide interim guidance before metric release

  • Address irreplaceable habitats and designated sites in biodiversity planning guidance

  • Clarify compensation requirements for priority peatland

  • Establish effective mechanisms for long-term monitoring, evaluation, and enforcement

  • Develop a standardized approach for offsetting

  • Coordinate a National Nature Network

  • Workforce planning to build skills and capacity through adequate funding

  • Ensure minimum ecological knowledge for planners and elected officials

  • Properly resource the development of a Scottish biodiversity metric

  • Develop mechanisms for long-term commitment to biodiversity enhancements

  • Conduct a skills gap analysis and provide necessary training

  • Consider future needs for training the next generation of professionals