On 29 January 2026, RTPI Scotland submitted a response to the Scottish Government's consultation on its draft Climate Change Plan. Read the response below.

About the RTPI

At the Royal Town Planning Institute (the RTPI), we champion the value of planning in building thriving places and communities. With over 27,000 members worldwide, we support planners at every stage of their career: raising professional standards, shaping planning policy, and proudly awarding chartered status, the highest professional accreditation in UK planning.

For over a century we have empowered planners to deliver positive impact: creating healthy, inclusive, economically and environmentally sustainable places. As the voice of the profession, we advocate, support, and lead with purpose, professionalism, and passion.

A resourced planning system to achieve net zero

We welcome the opportunity to comment on this draft Climate Change Plan (CCP), which sets out the Scottish Government’s approach to delivering net zero by 2045. 

This draft CCP covers a lot of ground, reflecting the all-encompassing nature of the challenge to reach net zero. The CCP captures not only national level policy around energy supply, waste management, freight transport etc., but also the consumption and lifestyle choices taken by communities and individuals across Scotland, including travel and shopping choices, business operations etc. This demonstrates that achieving net zero requires the collective efforts of all sectors, industries, organisations and communities, across all scales, with the CCP bringing together our current and planned collective efforts across this vast and complex landscape.

RTPI Scotland broadly supports the draft CCP and the approach being taken in relation to efforts to reduce emissions and achieve net zero in each sector of the economy. Planning has a vital role to play in this regard which is recognised in Scotland’s Fourth National Planning Framework (NPF4) – the overarching policy of which (at Policy 1) is to tackle the climate and nature crises. The RTPI and the TCPA have recently published the fifth iteration of the Planning for the Climate Crisis: A guide for local authorities, which also recognises that planning is uniquely placed to deliver solutions to the climate crisis across the whole of the UK.

Notwithstanding the above, we are concerned that a very narrow view appears to have been taken with respect to the role of the planning system and town planners in achieving net zero across each identified sector in the draft CCP. For example, we note that the only section of the CCP which actively acknowledges the important role of town planners to deliver net zero is within the energy supply section of the plan. This section describes planning as a “critical enabler of the delivery of the increase in energy infrastructure that is needed, in a sustainable way”.

Whilst we are pleased to see clear acknowledgement of the important role of planning in relation to this sector of the economy, we would argue that planning should also be recognised as a critical enabler to support all the sectors covered in this draft CCP. In the following section of this response, we provide some examples of planning’s critical role in relation to other of the sectors covered in the draft plan. We strongly recommend that the final CCP adopt a more consistent approach to acknowledging the role of planning as an enabler to achieve the CCP’s outcomes across all sectors of the economy.

This is particularly important having regard to the resourcing pressures local planning authorities are currently facing. Recent research undertaken by the RTPI into the State of the Profession (published in November 2025) found that:

• 66% of public sector planners in Scotland say their teams lack the capacity to meet demand.
• 60% of Scotland-based survey respondents report being overstretched frequently or all the time in their roles.
• 14% of planners in Scotland intend on leaving the profession entirely in the coming years, with no clear plan to replace them. 
• Total expenditure on planning has decreased by 33% since 2010, despite a 38% increase in the income generated by planning during this same period.

We acknowledge the positive initiatives of the Scottish Government over recent years to provide much needed support to the planning sector through such initiatives as:

• The National Planning Hub, which is currently focused on the delivery of hydrogen, onshore wind, and housing proposals.
• The future planners programme, which saw 17 student planners hired by the Scottish Government to work part time to gain valuable planning experience across a variety of government departments. 
• The National Planning Skills Commitment Plan – launched last year to attract new talent to the profession, including the funding of bursaries for students studying a post-graduate RTPI accredited planning degree.

RTPI Scotland welcomed the above initiatives, and we are eager to see them continue and to expand their reach. All the above initiatives are mentioned in the draft CCP, but only in connection with the energy supply section of the plan. We are concerned that the implication of this will be that the value of the planning system, and of planners, is only recognised in relation to this one (albeit important) sector of the economy – i.e. the energy supply sector. 

It is vital that the final CCP clearly recognises that the benefits of supporting planning and the pipeline of planners go beyond ensuring the future of Scotland’s energy supply. 

In the above regard, RTPI Scotland published our Planifesto in November 2025, setting out our key priorities for the next Scottish parliament following the May 2026 elections. These include a priority to take a whole system approach to funding the planning service through:

• A long-term budget commitment to fund and support future planners.
• A national digital planning champion to coordinate a funded programme to support the embedding of digital efficiencies into the planning system and service.
• Investment in forward plan-making by ensuring that all local planning authorities have the resources and support they need to deliver their local development plans (LDPs) in a timely manner.

Planners have a significant role to play across all areas identified in the CCP to support the delivery of Scotland’s net zero targets. This role can only be realised if the planning system and planners are adequately supported through a long-term investment strategy spearheaded at the national level.

The role of planning to achieve net zero

As mentioned above, the only section of the CCP which actively acknowledges the important role of town planners to deliver net zero is within the energy supply section of the plan. Although references are made within other sections of the plan to key planning-related terms (including “20-minute neighbourhoods”) and documents (including NPF4 and LDPs), these references are sporadic, inconsistent and fail to adequately capture the important role of land use and spatial planning to achieve net zero across all sectors of the economy. 

It is important to highlight that there is a high degree of alignment between NPF4 and the objectives of the draft CCP to reduce greenhouse gas emissions across all identified sectors of the economy. NPF4 includes a total of 33 national planning policies, all of which align (at least in part) with a just transition to net zero and tackling the climate emergency. More specifically, page 8 of NPF4 includes a “reducing greenhouse gas emissions” crosscutting outcome with direct links to 25 of its national planning policies. It also includes a list of 18 national developments – all of which contribute to the delivery of a number of the objectives set out in the draft CCP across the identified sectors of the economy. Despite this alignment, NPF4 is only referenced a total of nine times across the whole of the draft CCP, with no reference made whatsoever to the crosscutting outcome of reducing greenhouse gas emissions, or to the national developments. This is an example of what we would consider to be a critical gap within the draft CCP.

Some examples of where these concerns could be addressed in the draft CCP are in relation to:

• The buildings (residential and public) and business and industrial process sections of the draft CCP.

Planning is referenced in passing in these sections in relation to the role of NPF4 to “encourage, promote and facilitate” Negative Emissions Technologies. There is also one reference to the work of local authorities to prioritise the development heat network projects in their LDPs to support the delivery of local heat and energy efficiency strategies (LHEES).

The “calls to others” in this section of the draft CCP includes a call for local authorities to “build on LHEES to coordinate and sponsor development of place-based projects, seeking out opportunities to aggregate projects into programmes”, as well as to explore opportunities to develop heat networks and collaborate with other local authorities to join up heat plans. Planning is not specifically mentioned in this call, but the reality is that planning plays a central role in the delivery of LHEES – specifically ensuring that the energy goals set out in LHEES are translated into actionable development outcomes on the ground. The RTPI’s recent research on Spatial Approaches to Local Energy Planning (published in May 2025) recognises that energy planning processes (such as LHEES) “are emerging as useful tools to support the transition to a decarbonised energy system at the local level. They provide a strategic framework for identifying opportunities for renewable energy generation, heat and transport decarbonisation.” However, the research also finds that a key barrier to such energy plans realising their full potential is a lack of integration with town planning.

• The Waste section of the draft CCP.

This section acknowledges NFP4’s policy that supports the minimisation of lifecycle greenhouse gas emissions, and the recently published planning guidance to support the application of NPF4 Policy 2 (climate mitigation and adaptation). However, planning is otherwise largely overlooked in this section.

In our response to the Scottish Government’s consultation on the draft circular economy and waste route map to 2030, we highlighted the significant contribution that the planning system can play to the aims of a circular economy through promoting the adaptive reuse of buildings and the recycling of construction waste through the coordination of waste and recycling infrastructure through national and local development plans. For example, regional hubs for reclaimed or reusable construction materials/assets will need to be carefully planned – located not too far from sources or end users and accessible to suitable transport infrastructure. Consequently, we argued in our response that it will be critical for local authority planners to be adequately supported and resourced in carrying out their duties in a way that promotes and further supports the transition to circular construction practices and targets and enhanced food waste recycling. This critical role of planning to achieve the outcomes of the draft CCP in relation to waste are noticeably absent.

• The transport section of the draft CCP.

There is recognition within this section of the spatial implications of a just transition to net zero transport, with some references to place-based delivery, 20-minute neighbourhoods, local living, and well-maintained active travel and EV charging infrastructure. However, there is very little recognition of the role of spatial planning to deliver these outcomes. 20-minute neighbourhoods are a key policy of NPF4 as are sustainable transport (Policy 13), well-designed and connected places (policy 14) and infrastructure first (Policy 18), to name just a few.

Local planning authorities across Scotland are currently in the process of preparing their new-style LDPs to support the delivery of these key NPF4 policy objectives and will, therefore, have a critical role to play in delivering many of the transport outcomes of this CCP. However, spatial planning and NPF4 are not referenced at all in this section of the draft CCP. Neither are LDPs. In fact, LPDs are only referenced once throughout the whole CCP in relation to supporting LHEES.

These types of inconsistencies throughout the draft CCP are concerning. They demonstrate the failure to adequately grasp the critical role that planning plays across the majority of objectives set out in the CCP and runs the risk of creating missed opportunities to utilise planning and planners to their full potential to support the CCP’s delivery.

We understand the challenge of capturing all elements of such a vast and complex topic as climate change within a single plan. The volume of the task naturally runs the risk of it being unable to suitably capture the full extent of crosscutting links to the actions and activities of all professions, organisations, government departments and communities across Scotland. NPF4 provides a good example of the way in which such links can be made in comprehensive way. Table 1 of NPF4, for example, usefully maps out links between NPF4’s spatial principles, national developments and polices with other key and crosscutting polices in Scotland (including the CCP).

Net zero place-making

Embedding circular construction practices is a key objective of the draft CCP under the waste section of the plan. Construction waste currently accounts for up to half of all waste produced in Scotland, with the draft CCP acknowledging the need “to move beyond management of waste materials to maximising the lifespan of carbon and material intensive structures in our built environment”. This very much aligns with NPF4. In particular, Policy 12 (zero waste) of NPF4 includes the prioritisation of “the reduction and reuse of materials in construction” as a policy outcome. 

The wide-spread adoption of circular construction practices to address the issue of embodied carbon is fully supported by the RTPI and we welcome its inclusion in the draft CCP. However, we believe that this objective must also be embedded alongside place-based carbon sequestration practices if we are to reach net zero. This dual approach of balancing the amount of greenhouses gases we emit and the amount we remove from the atmosphere is a central theme of Anderson Bell + Christie’s Balance White Paper, the culmination of a research project supported by Scottish Enterprise and launched in May 2025.

Carbon sequestration and biodiversity enhancement initiatives are principally referenced in the draft CCP in relation to agricultural and farming practices, as well as in the LULUCF section of the plan. These objectives align with NPF4, Policy 5 of which seeks to protect carbon-rich soils and restore peatland which sequester and store carbon. 

Whilst we broadly support these initiatives, we believe the plan is missing an opportunity to recognise the potential contribution of the built environment sector and, specifically, embedding carbon sequestration measures into development proposals. Currently, the CCP views circular construction practices and carbon sequestration as two separate and independent priorities (set out in separate sections of the plan). Recognising the joint and collaborative role of circular construction and carbon sequestration practices as integral to the creation of net zero places (not just net zero buildings) would broaden the current ambitions of the CCP to deliver a place based approach to achieving Scotland’s net zero goals.

RTPI Scotland’s Planifesto calls for the implementation of such a balanced approach to net zero plan-, design- and decision-making, which utilises nature-based carbon sequestration solutions as well as emissions reduction measures. We call for net zero placemaking to be embedded into every planning policy, project, plan and development proposal to support this approach, which must include any future iteration of the CCP.

Delivering a just transition to net zero

Annex 1 of the draft CCP sets out five just transition principles as well as key actions and considerations that underpin the plan. Each sector addressed within Annex 2 also incorporates a section assessing the impacts of the sector specific policies and proposal on achieving a just transition. 

RTPI Scotland agree that decarbonising the economy can only be achieved when there is support and buy-in from everyone who lives and works in Scotland. A just transition to net zero is therefore essential to achieving success. 

In RTPI Scotland’s responses to consultations on Scotland’s just transition plans for energy and transport, we highlighted the strong linkages between achieving a just transition and the spatial principles and policies of NPF4. NPF4 sets out Scotland’s spatial strategy for delivering the ambitious decarbonisation of the Scottish economy, improving climate resilience, fostering biodiversity regeneration and moving towards places for wellbeing across the country. NPF4’s six spatial principles aim to foster this:

• Just transition
• Conserving and recycling assets
• Local living
• Compact urban growth
• Rebalanced development
• Rural revitalisation

Delivering a just transition will rely upon the successful delivery of NPF4’s spatial principles and policies. Despite this, the draft CCP includes very little acknowledgement of NPF4’s role in delivering a just transition across its sectoral objectives. This is despite a number of references to “place-based” approaches throughout the draft CCP, which will require support from the planning sector to implement. 

Local place plans (LPPs) in particular have an important role to play to ensure Scotland’s communities have the means to set out their priorities for their local area and influence spatial planning. Once registered by the local planning authority, LPPs are required to be taken into account in the preparation of the LDP. Consequently, they have the potential to empower community-led change in a way that supports a just transition. However, this can only be achieved if communities have the capacity and skills to embark on the preparation of an LPP. RTPI Scotland have previously expressed concerns that the resource implications (time, skills, as well as financial) for communities wishing to produce LPPs, and for planning authorities to support their development, can be substantial. Not every community is, therefore, suitably equipped to take up the opportunity of producing an LPP. 

In order that this vital planning mechanism can be utilised by Scotland’s communities to its full potential, we have previously called on the Scottish Government to provide dedicated resources for planning authorities to support LPPs, ideally by creating dedicated planning officer roles or through support provided by a national body which can facilitate local links. Enhancing support to communities in plan-making and placemaking is also a key ask of the RTPI Scotland Planifesto, particularly for Scotland’s rural and island communities which are facing their own unique challenges related to (for example) higher costs of living, supply chain challenges and market failure, resulting in affordable housing shortages and infrastructure delivery challenges. These are acknowledged in the draft CCP, but the role of planning as an enabler to support communities in tackling these challenges is not adequately recognised. 

To conclude

Planning is a critical enabler that has an important role to support the delivery of the CCP objectives across all identified sectors of the economy. This, however, is inadequately recognised within the current draft CCP, with planning directly referenced as a critical enabler only once in the energy supply section. Also, NPF4 is referenced only nine times throughout the entire draft CCP, despite there being a high degree of alignment between the CCP’s objectives and that of NPF4.

We would strongly recommend that an approach be taken to more comprehensively and consistently recognise the broad and crosscutting role of planning to deliver the objectives of the CCP across all identified sectors of the economy (beyond energy supply). This is vital to ensure that the value of planning and planners is recognised beyond the energy sector and that planners are utilised to their full potential and equipped with the resources and skills to support the CCP’s delivery across all economic sectors, which in turn will support the delivery of NPF4.