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REVIEW OF GREEN BELT POLICY IN SCOTLAND

CHAPTER FOUR THE VIEWS OF STAKEHOLDERS

INTRODUCTION

4.1 This chapter reports the views of national stakeholders. These were canvassed by a mix of one-to-one interviews, focus groups and email correspondence. Views were also gathered at the workshops during the seminar held at the Scottish Executive on January 23 ^rd 2004. A number of stakeholders were also represented on the project advisory group. Table 4.1 lists organisations actively canvassed through interviews, focus groups and emails. The chapter is structured according to our fourfold themes of Green Belt functions, urban form, the nature of the Green Belt regime, and land management in the Green Belt. It emphasises stakeholders' diagnoses of what is good and bad about the present regime, but also reports suggested approaches.

Table 4.1 Stakeholders actively canvassed

GREEN BELT FUNCTIONS

4.2 A recurring theme was that the Green Belt designation should be used not as an end in itself, but as one means of strategic settlement planning with a long term horizon - at least the 20 years promoted by SPP3 and maybe longer. This theme was voiced by developers, consultants and regulators alike. Concomitantly, a recurring criticism was that planning authorities do not do this (see s4.4 below). Structure planners argued that Green Belt is not required to manage settlement strategy where there is only one planning authority. It is a tool to ensure consistency across interdependent areas under multiple authorities: so why do you need a Green Belt round St Andrews? Other examples were cited of successful management in the absence of Green Belt (East Fife villages, Dundee).

4.3 A second recurring theme was that all Green Belts differ in their character and development contexts, that the same purposes do not therefore apply in all cases, and thus that a nationally-set 'one size fits all' policy is therefore inappropriate. This does not necessarily sit well with criticisms set out below of lack of precision in national guidance, and lack of consistency in local application: it will require finessed guidance simultaneously to satisfy the desires for flexibility, precision and consistency.

4.4 Specific critiques of purposes included:

• House builders saw the purposes set out in SDD24/85 as too generalised and thus open to variable interpretation by planning authorities.
• Reporters reported no problems at appeals with the identity/anti-coalescence and the landscape setting purposes, whereas the recreation and institutional uses purposes do create problems (the former due to lack of positive powers and resources, the latter due to ambiguity). Several consultants also considered that the original anti-coalescence and landscape setting functions as still valid.
• Reporters considered the circular to be inconsistent in purposes, pointing out that the presumption in para 4(iv) of the annex, against minor development like extensions to existing buildings, is irrelevant to any of the three purposes listed.
• The Edinburgh Green Belt Network (EGBN) argued that the goal of preventing coalescence of settlements remained important and should not be downgraded in response to the issue of sustainable transport and the associated argument for orienting development to transport corridors. Other stakeholders, particularly planners in local and central government, regard the transport corridors issue as important, however. More agreement may be found around the concept of development nodes linked to transport. EGBN were particularly concerned with visual and psychological coalescence, which depends on topography, and this might be covered by the aim of maintaining the landscape setting of towns.
• SNH saw no point in adding, as in English guidance, a specific purpose of protecting the setting of historic towns, on the grounds that the general landscape setting purpose covers that. In SNH's view, Green Belt could serve all three possible functions of natural heritage designations - an accolade, a signal to policy makers of the place's importance, and a land management tool - though at present its role is limited to the second of these.
• The function of protecting agricultural land (an original purpose in the Abercrombie days but not listed in SDD24/85 as a Green Belt purpose) was considered obsolete by house builders, but structure planners cautioned that our current view of the value of farm land is a product of the Common Agricultural Policy, and that a longer term view of its worth should look beyond that.
• House builders also argued that we already no longer need the post-SDD24/85 function of assisting regeneration. Because the urban brownfield market is now well developed, the planning regime no longer needs to force developers on to urban brownfields (see below). Indeed, since the subsidy available for brownfield remediation was reduced, the danger is that pressure is redirected on to urban greenspace. Structure planners recognised the seductiveness of the argument that we can relax Green Belt policy because the regeneration argument has been won, but were wary of this being too short term a view. The Victoria Quay workshop was united about the desirability of urban brownfield redevelopment but slightly less clear about how actively this needed to be encouraged and whether Green Belt was the right instrument.

GREEN BELT AND URBAN FORM

4.5 Critiques of the impact of Green Belt on urban form centred on tight girdles creating leapfrogging. Undesirable effects identified from this included damage to outlying communities and surrounding landscape around Aberdeen, and having to invest retrospectively in city-region transport across Green Belts. The alternative model approach of green tongues or wedges of open land separating developed spokes along transport corridors (as in the Copenhagen 'finger plan') was variously mentioned approvingly as a planned alternative; Aberdeen is now actively committed to this alternative approach. EGBN were less concerned about leapfrogging, but felt that it should be planned.

4.6 House builders expressed concern at the threat of town cramming arising from a restrictive Green Belt policy, and that we should now plan for expansion rather than regeneration, among other reasons to cater for a housing shortfall of 5000 units. They argued that the vision of urban living in flats and tenements is elitist and out of touch with popular demand. What people want is family homes in green suburbs, and the planning regime should recognise this and plan positively to satisfy the demand. The challenge is to design a suburbia fit for the 21 ^st century. House builders further supported this argument in favour of incremental growth at the city edge by arguing that the quality of the environment could be secured by forward planned structural landscaping, for which unfortunately the planning authorities currently lack the design expertise. The desirability of masterplanning was mentioned in this context.

4.7 The desirability of a continuous Green Belt was discussed with SNH in relation to severing biological populations. SNH pointed out that the import varies greatly with the species. Losing the physical continuity of the Green Belt will of itself not necessarily affect the populations of many more common species such as badgers, but care is needed to design greenspaces which allow migration of populations within, in and out of urban areas. Similarly, there are also land management /operational farming arguments for an extensive as well as continuous tract of Green Belt.

THE NATURE OF THE GREEN BELT REGIME

4.8 A recurring theme was that Green Belts are used negatively as a tool of restraint, not positively as part of a toolkit for strategic forward planning. Reporters referred to a culture of 'control and containment'.

4.9 Another recurring theme was that Green Belt is still the best defence of open land around towns, because other local landscape designations (such as Area of Great Landscape Value) are less rigorously enforced in practice. Such peri-urban land is seldom of the level of national worth justifying a national statutory designation which would reliably protect it. Early results from an ongoing survey by SNH, incidentally, indicate that local biodiversity (e.g. Local Nature Reserve) and recreational designations (e.g. Regional Park) are fairly reliably enforced, but it is less clear that the wider designations (such as AGLV) are. Thus there is still a widely-held pragmatic view that it is too risky to abolish Green Belts. On the other side, it was pointed out that disaster has not followed the abolition of Dundee's belt, because it was replaced by positive policies.

4.10 This view is difficult to reconcile with another recurring under the heading of the nature of the Green Belt regime: planning authorities' weak and inconsistent application of Green Belt policy. For example, on the topic of releases, Reporters pointed to small applications being refused while large ones are permitted, and this was echoed by house builders complaining that housing is refused yet commercial developments are permitted. House builders criticised Reporters for inconsistent handling of out-of-date Development Plans, though Reporters maintained that appeals seldom succeed on the grounds that the Development Plan is out of date. The Victoria Quay workshop argued for provision of high amenity commercial sites on specific zoning rather than in the Green Belt. But structure planners pointed out that major inward investments could not always be anticipated and thus planned for, leading to economic pressure for ad hoc releases undermining Green Belt credibility. Their only solution is to have a criterion-based policy allowing for exceptions.

4.11 Most Scottish planning authorities do not use white land to provide for urban expansion at the inner edge of the Green Belt. However, in growth areas this is bound to lead either to leapfrogging or to considerable releases from the belt for run-of-the-mill development. This in turn engenders the cynical perception of the belt as strategic land reserve. The Victoria Quay workshop thought that land should be safeguarded for special uses such as airports. In the case of housing, for which there are wider options, a preferable procedure is to allocate land for 'phase two' development. Similarly, on the closely related topic of washover or insets, the prevailing view was that washovers of settlements are illogical.

4.12 Permanence, or more properly long-term stability, of Green Belts is expected by the public and hence by politicians. Research into the history of the Edinburgh Green Belt indicates that 4000 acres have been lost from the original belt set out in Abercrombie's 1949 plan, while a further 8000 acres are suffering significant visual detriment from pylons, roads etc. Areas of belt have been pinched off from the rest. Concern was expressed at the phenomenon of a downward spiral, wherein a release undermines the belt functions of adjacent land, which in turn is thus more readily released, and so on.

4.13 There is a general sense that predictability is the best defence against speculation and its undesirable effects on land management via development hope value (see below). That predictability does not necessarily require long-term stability; it requires a clear and up-to-date forward plan and rigorous enforcement of it. But, notwithstanding such arguments for rigorous enforcement, more than one stakeholder was of the view that releases are acceptable so long as they do not compromise the overall functions of the Green Belt. SNH saw large commercial releases as more of a threat than housing releases to the integrity of the Green Belt, because they are more likely to entrain further unplanned releases. Its internal policy guidance note on Green Belts (01/02) argues that erosion of belts is more of a threat to the natural heritage than is damage to outlying areas from leapfrogging, and that abandoning Green Belts would overall increase harm caused to the natural heritage by development.

4.14 The public's perception of Green Belt as intended to be permanent is closely tied to its perception of it as an instrument to preserve landscape amenity, rather than as a tool to manage settlement growth. This in turn raises the question of overlap of Green Belt functions with those of other designations. Stakeholders offered few views on whether this causes problems in practice. The Victoria Quay workshop did not see overlap as a problem, and SNH is now less concerned about it than it was. From the natural heritage standpoint, abandoning Green Belts would not be seen as damaging so long as local landscape designations were strengthened. So long as Green Belts remain in place, model policies for Development Plans might help to ensure consistent defence of natural heritage interests on Green Belt land. The Victoria Quay workshop however thought it difficult to design model policies to cope with the generally acknowledged variety of local circumstances.

4.15 Consideration of the overlap of perceived functions between Green Belt and conservation designations leads on to the idea of classifying or tiering Green Belt land, with strongest protection of those parts which best serve amenity functions. This was most explicitly advocated by the Edinburgh and Lothians Green Belt Network, which floated the idea of identifying at least four classes:

• areas of high conservation value which should be sacrosanct
• areas which should be retained to prevent coalescence of development
• areas of low conservation value which could advantageously be released with associated landscape improvements
• land which could be added to the Green Belt

4.16 Part of the object this approach is to increase certainty and thus the defensibility of the top tier, but one Victoria Quay workshop pointed to the danger of the exact opposite, that tiering might fuel speculation in lower tiers and so weaken Green Belt policy overall. Another workshop floated a sequential approach of identifying the areas of most conservation value, protecting them with appropriate designation, and using the Green Belt designation to review the parts left over in the light of preferred urban form.

4.17 On this subject of stability, boundary review practice drew some strong criticism. House builders saw a 'void at the centre', created by lack of clear national guidance and lack of national enforcement, as responsible for poor practice by planning authorities in reviewing boundaries. That practice lacks transparency and lacks intellectual rigour, being driven too often by short term local political expediency: it was even suggested that sometimes planners start by identifying land releases with which they would be happy in the intended Local Plan, and work back from there to draft the boundary review strategy in the Structure Plan. The Victoria Quay workshop wanted national guidance on review criteria and process, but wanted boundary decisions left to planning authorities.

4.18 On the question of national status of the Green Belt designation, the Victoria Quay workshop confirmed the view from stakeholder interviews and the advisory group that Green Belts are designated for local/regional purposes and should therefore not hold national status.

LAND MANAGEMENT IN THE GREEN BELT

4.19 There is a potentially complex relationship between Green Belt status and land management. A core question is the effect of development hope value. While Green Belt is in principle expected to depress land value because it reduces the chances of planning permission, in practice it may raise it because of the exclusivity and high amenity associated with any permission that is given; it will depend on the reading of likelihood of release and other locational factors. Hope value has been accused of encouraging the neglect of farmland, but SNH and Reporters doubted whether it is a chief cause, pointing rather to the problems of farming in the fringe, irrespective of Green Belt status. Farmers' representatives pointed out that any general effects will in any case be masked by local context, such as whether the land is occupied by the owner or rented, whether it is part of an enterprise with holdings elsewhere, and whether a developer holds an option on it.

4.20 More than one stakeholder group emphasised the need for positive land management actions to back up the planning policy, and SNH thought that the guidance needs to make this point more strongly than does SDD 24/85. A caveat about the otherwise attractive finger plan urban form was that the green tongues would barely be viable in farming, so who would intervene to manage them positively? Structure planners felt that the image of Green Belt as a negative tool stands in the way of positive management of the urban fringe.

4.21 For example, while most parties subscribe to the idea of a greenspace network uniting town with country, Reporters pointed out that the Green Belt designation does nothing of itself to help "provide countryside for recreational purposes" (SDD 24/85) operationally by opening land to public access. Although the new core path network duty laid on local authorities should help in this regard, house builders pointed to a lack of public resources for such actions and asked who is creating public parks these days. In a similar vein, structure planners pointed to the positive management of the urban fringe under the pre-1996 regions, and that there is a case for examining whether the mechanisms for organising and resourcing this since the demise of the regions are as effective. Opportunities for landscape enhancement cited by various stakeholders included

• the agri-environment schemes, which are not currently tuned to the circumstances of peri-urban land
• urban forestry
• the potential for development agencies to invest more in improving the appearance of 'gateways' in the Green Belt as tools for marketing cities
• bringing brownfield sites in the Green Belt back into beneficial use, another challenge for development agencies

4.22 A commonly touted means of securing landscape improvements in the Green Belt is the release of land currently in poor condition in return for landscape improvements. In this connection the Victoria Quay workshop pointed to scope for country houses in parkland, as well as the West Lothian lowland crofting initiative, seen as successful in generating structural landscaping. House builders expressed some frustration at the reluctance of planning authorities to enter into such deals. Such an approach must nevertheless be conducted within the framework of a strategic landscape plan, if incremental ad hoc deals are not to put at risk the overall integrity of the belt. The lack of such strategic landscape planning tools was acknowledged (e.g. in Germany strategic landscape plans provide a means of guiding deals on environmental compensation of green field development). SNH admitted that it is not yet ready to propose what such tools might be. While this issue goes beyond the consideration of Green Belts, it is timely that SNH is currently consulting on Scotland's Future Landscapes. One of the representations made on this by the planning profession is the need for a stronger focus on the landscapes around the towns - and thus including Green Belts - which are those which most people experience most of the time, and which are also those where most change is happening as land is developed.

4.23 The specific issue of releasing poor quality Green Belt land as a means of enhancing it sits within the wider issue of the extracting planning gain from developers through planning conditions and agreements, and how this is to be related to Green Belt status. Feedback from a workshop at the Victoria Quay seminar made it clear that developers already feel that they are required to supply a disproportionate share of community facilities which should properly be provided by the responsible public authorities, and will thus resist further demands. Restructuring of Green Belt, such as is now occurring in Aberdeen of the South East Wedge of Edinburgh, provides an opportunity to negotiate sizeable contributions to enhancements, not just on the development sites but in the adjacent 'green network'. A particular issue is the spatial relationship of the beneficiary community to the development site: developers will understandably question the provision of benefit to the wider community on the grounds that Green Belt is for the city as a whole, not only for those in the immediate vicinity. Model policies, mentioned above, might provide one route to more certainty on this matter, even if not to satisfaction.

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