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REVIEW OF GREEN BELT POLICY IN SCOTLAND
GLASGOW AND CLYDE VALLEY
5.72 The recently approved Structure Plan for Glasgow and Clyde Valley (May 2002) has prompted a review of Green Belt policy and structure within many of the constituent local authority Local Plans, including those for Glasgow, East Dunbartonshire and North Lanarkshire - the focus for this case study.
Historical Perspective
5.73 A Green Belt policy has been applied around Glasgow for many years, predating objectives set out in Circular 24/1985. The Green Belt as a concept was first forwarded in the 1946 Abercrombie Plan for Glasgow and the Clyde Valley. However, the policy only had advisory status in parts of the area until it was formally designated in the Strathclyde Structure Plan 1979. However, from the outset there was an awareness that the Green Belt was more than just a land use designation. The broad geographical extent and scope of the Belt is described in the work of Frey quoted in Chapter 2.
5.74 Transport was high on the agenda in the 1981 and 1990 revisions of the Structure Plan in determining which settlements would not be promoted for development. As such, it could be argued that the current Structure Plan's emphasis on growth corridors was built into strategic thinking back then. Green Belt policy was reaffirmed in the Plan's Strategic objectives following local government reorganisation in 1996 and periodic perceived shortages of land. Strathclyde Regional Council consulted on the process of site selection in preparing the 1990 Plan, following the identification of a shortfall, but were inundated with proposed options. The 1990 Plan also responded to the need to be more specific on the location of housing releases. However, in preparing the current Structure Plan, it was not necessary to be as specific since the requirements could be delivered within Local Plans. One year after approval, all Local Authorities have identified their Green Belt release proposals in their finalised or adopted Local Plan or (in the case of North Lanarkshire) within supplementary planning guidance. The Structure Plan Committee currently monitors applications in the Green Belt.
5.75 In general, periodic planned releases have been the main mechanism of change and development affecting the Green Belt. To illustrate the significant scale of some of these changes, it appears that in 1993, 4231 hectares of the Glasgow local authority area (current boundaries) were designated Green Belt; whilst by 2003 this had fallen to 3310 hectares, a reduction of approximately 22%.
Current Strategy
5.76 Designating a long term Green Belt is critical to supporting the current Structure Plan's overall goal of promoting "balanced and sustainable development". Indeed, the plan states that "the Metropolitan Development Strategy requires the continued designation and safeguarding of the Glasgow and Clyde Valley (G&CV) Green Belt within which there is a presumption against the spread of built up areas and the encroachment of development into the countryside". As such, the Green Belt is integral to the achievement of the Plan's strategic objectives and is integrated into the three key themes. Strategic Development Locations (SDLs) identify areas where major change will occur and are complemented by a Green Belt which will safeguard the Countryside Around Towns (CAT) and villages and help ensure that investment is not diverted from the SDLs.
5.77 Regeneration was also a key theme within previous Structure Plans. The current Structure Plan acknowledges that in spite of substantial brownfield opportunities, there continues to be pressure for urban expansion into the Green Belt and for the development of urban green spaces. As such, the Structure Plan seeks to focus new development at appropriate locations within existing urban and rural settlements, thereby reducing pressure for urban expansion, integrating communities and maximising the use of existing services and infrastructure. Maintaining the Green Belt is therefore tied into the settlement strategy in terms of the scale, distribution and quality of development required. It is commonly held that the Structure Plan's Green Belt policy has assisted in directing development to within the existing urban fabric. However, it is also suggested by some that, in less buoyant areas, a different strategic approach may be required with accretions to the urban area, be these of core or free-standing settlements. That said, achieving these objectives requires a consistent approach to the Green Belt.
5.78 The current Structure Plan also refers to "reinforcing the landscape character and setting of towns and villages by designating and safeguarding a long term Green Belt". A 'Corridor of Growth', linking major centres of employment and services to all communities and in particular to areas of needs, may provide a focus for greenfield expansion and its management and promotion in preference to other areas. In the Structure Plan, Strategic Policy 2 states that Authorities will "assess the potential of the following areas…to contribute to the requirement for development land post 2006" - one of the two areas identified as being Gartloch/Gartcosh. However, planners in Glasgow and East Dunbartonshire were keen to point out that ribbon development around corridors was to be avoided. The Green Belt is also linked to the proposed Green Network. The need to safeguard and enhance resources, linked to a new "Green Network" along the corridor would appear to address possible concerns regarding ribbon development.
5.79 In terms of housing supply, the current Structure Plan states that Local Plans should make specific provision for 5,650 houses (3,300 additional to effective supply pre-2006 and 2350 post 2006) - "if necessary by greenfield release". This figure is some what less than in previous Structure Plans (e.g. 9,500 in 1981; 9,000 in 1990 including Ayrshire). The majority of these releases are in East Renfrewshire, South Lanarkshire and West Dunbartonshire. The Structure Plan does not anticipate any significant change in the balance of greenfield/brownfield development. The majority of these releases are in Glasgow. Of this, the Glasgow City Plan is expected to provide 1950 (1600 by 2006 and 350 post 2006). (we comment below on the scale of release sites now being considered by Glasgow). Housing releases are also planned for North Lanarkshire (1050). In contrast, East Dunbartonshire is not expected to provide any release, partly because of existing unimplemented allocations. In identifying sites, Local Plans are also expected to have regard to "the need to ensure the long term stability of any new Green Belt boundary and environmental considerations".
Current Local Plans
5.80 The Glasgow City Plan's (2003) development strategy is "to build on Glasgow's strengths and continue to develop sustainable environments that attract residents, investors and businesses." As such, the strategy encourages the development of new neighbourhoods, communities and facilities while "protecting and enhancing the City's natural and built environment, community focal points and residential districts". Achieving this requires a balance between "adopting policies encouraging exciting new quality developments in areas where change would be beneficial and those that take a hard line on development that might have an adverse impact on infrastructure, residential amenity, environmental quality or social inclusion". As part of this, the Council is "looking for a new suburban vision on…important greenfield development sites" as identified on the proposals Map. Nine such releases are planned and are located on the urban edge, in some cases near the City's peripheral housing estates. However, land releases have been planned as opposed to incrementally developed in order to deliver housing choice. The Council seeks to locate new "executive housing" in areas where the housing market can sustain it. As a result, four of the nine releases are on the Southern edge and two in the North near Summerston and Broomhouse. These sites have not been developed yet. However, two sites originally allocated for upper market housing in Drumchapel were subsequently developed as middle range housing, which delivered benefits in terms of enhanced housing choice. Each of the sites is tied into the wider regeneration of the areas. However, it was also acknowledged that some areas might take time to grow into upper market housing areas.
5.81 East Dunbartonshire Finalised Draft Local Plan (2002) also reflects key strategic priorities in its guiding principles of sustainable development, the sequential approach, the integration of land use and transportation and social inclusion.
5.82 Any consideration of current green belt policy within North Lanarkshire has to be located within the context of 11 adopted Local Plans of varying age and 4 emerging Local Plans. As such, the current picture is unclear and raises issues of consistency with Local Plans of similar age showing differences in the expression of Green Belt policy. The intention is to prepare a Council-wide Local Plan once existing emerging plans have been completed and a draft Local Plan is to be published towards the end of 2004. This presents the Council with an opportunity to take an overview of the Green Belt within a single document.
5.83 North Lanarkshire's Draft Strategic Development Framework is also of relevance as it aims to support health and safety, community well-being and social inclusion as well as economic prosperity. The commitment to the Green Belt is stated in the policy context and the Strategy section confirms that "the Green Belt should be protected and efforts made to enhance the amenity of rural areas". The Framework also places significant emphasis on the "Green Network". North Lanarkshire has allocated land releases for economic development with Ravenscraig as a major planned release (most of which is not within the Green Belt). However, the North Lanarkshire case study interviews would seem to indicate that in certain circumstances Green Belt policy may be secondary to other more pressing economic development priorities. The same conclusion can be inferred from the analysis of decisions reported later.
Functions
5.84 The Structure Plan refers to the Green Belt as seeking to achieve a number of "interrelated objectives". These include:
- Control the growth of built up areas and support the process of urban regeneration;
- Prevent neighbouring towns from merging and control sporadic and isolated development;
- Preserving the special character of towns including their landscape setting;
- Protect agricultural land from inappropriate development and create the necessary stability for its productive use for appropriate countryside uses such as forestry;
- Protect and where appropriate enhance landscape character and biodiversity;
- Provide for the enjoyment and recreational use of the countryside and
- Support the development of the Green Network.
5.85 As such, a number of these objectives go beyond those cited within the Circular and expand on those set out in the 1946 Abercrombie Plan. However, they broadly encompass virtually all of the functions identified elsewhere in this report. The functions of the Green Belt as set out in Local Plans, generally reflect Structure Plan priorities and those set out in the Circular. However, interviews with planning officers suggest that different local authorities place particular emphasis on some objectives above others and the Green Belt often performs different or multiple roles in response to local circumstances. For example, it was suggested that coalescence was more important to people in specific locations, was closely linked to identity and had a particular resonance with people in these places (e.g. East Dunbartonshire). Similarly, using Green Belt policy to promote urban regeneration may be less effective in areas of low demand, even though it is probably more needed in such places. Thus it may still be effective in pursuing a desired settlement strategy, and may be linked to a more focussed brownfield strategy. The G&CV Green Belt is therefore viewed as a tool of spatial planning that can be employed in different places for different reasons at different points in time. Indeed, some respondents suggested that current functions could be regarded as supplementary to this main objective. Viewing the Green Belt as a spatial planning tool also reflects current European debates on polycentricity, social inclusion and sustainable settlement structure.
5.86 The recycling of brownfield land and the implementation of a strong Green Belt policy are viewed to have underpinned the wider regeneration process. The current Structure Plan continues to place particular emphasis on regeneration and seeks to maintain momentum. However, views were mixed as to whether the urban regeneration argument had been won and whether this represented an argument for a relaxation of Green Belt policy. That is not the official view, and supporting urban regeneration is still viewed to be an important function of the Green Belt, with 70% of new development being built on brownfield land (broadly defined).
5.87 The need to restructure the housing stock within urban renewal areas is also discussed within the Structure Plan. In discussing Inverclyde, the Plan states that such areas "should have regard to the potential to integrate higher quality housing" and "an element of Green Belt adjustment might be appropriate". However, the Plan also refers to requirements that have to be met for acceptable urban expansion (e.g. improved public transport access and the need to create a Green Belt edge which is "clear, high quality and defensible in the long term").
5.88 Planning officers in Glasgow pointed to the city's very tight and 'artificial' boundary in comparison with other local authorities. While Glasgow City Council might shape the Structure Plan, the fact remains that the Council's planning activities are carried out within the context of the Structure Plan. The post-1996 change in administrative boundaries and Structure Plan arrangements to some extent placed authorities in a "bidding position", suggesting some competition between local authorities. While it was acknowledged that all local authorities are signed up to the Structure Plan, it was also recognised that local authorities have a degree of choice that they did not have in the past, enabling authorities to some extent to pursue "different agendas" for the Green Belt.
5.89 For example, it was suggested by planning officers in Glasgow that East Dunbartonshire provides for the upper and middle markets relatively successfully and is mainly interested in preventing coalescence and preserving landscape setting. Interestingly, planning officers in East Dunbartonshire felt that the Green Belt's key strategic role was in promoting urban regeneration within Glasgow, as the health of the conurbation was important to the future development of the area. That said, preventing urban sprawl and coalescence was recognised to be an important local issue for residents and local politicians, who were particularly sensitive to links with Glasgow. Indeed, 97% of residents and businesses recently surveyed as part of consultation on the Local Plan either agreed or strongly agreed with the Council continuing to strongly resist urban expansion into the Green Belt. Coalescence was also an issue for a number of small settlements in East Dunbartonshire and the need to retain "distinct and compact settlements" linked to the identity of individual communities. Despite pursuing relatively strong Green Belt policies, East Dunbartonshire has experienced some incremental 'creeping development' between some settlements. It was felt that those functions highlighted in the Circular remain important and should not be diminished. However, the Structure Plan's emphasis on urban regeneration could be incorporated into revised guidance.
5.90 Respondents from all the Glasgow & Clyde Valley case study meetings expressed in different ways the view that North Lanarkshire was a relatively pro-development authority which adopted a realatively relaxed stance towards Green Belt . The analysis of planning decisions reported later does not contradict this perception. That said, it was also acknowledged that each authority has equally plausible reasons for departing from established Green Belt policy where they had done so. However, some concern was voiced regarding the possibly short-lived nature of benefits and the potential scale of such incremental development activity. The need for consistency in applying Green Belt policy was re-emphasised by some officers.
5.91 Given current administrative boundaries, there was a sense within Glasgow City that it had little option other than to allocate land within the Green Belt. It was felt that solutions to Glasgow's problems had to be identified within its own administrative boundary. However, this need not necessarily be the case within a regional Structure Plan based on Housing Market Areas which go beyond individual authority boundaries. Nevertheless, in an attempt to stem population decline, Glasgow has embarked on an extensive programme to attract and retain households. Glasgow's Housing Choice Survey identified a need to improve the choice of family housing. The definition of what that would comprise followed later in the City Plan, which pointed to a lack of housing at the upper end of the market including detached housing with reasonable plot ratios. As such, the Green Belt was viewed as an area that could accommodate such development. In doing so, the Council was sensitive to potential conflicts with its brownfield development strategy and that the two approaches did not overlap. However, it was also conceded that different administrative boundaries might have resulted in releases elsewhere than those currently planned.
5.92 East Dunbartonshire shares Glasgow's concerns regarding housing choice but activities are focused on promoting a better mix of housing including smaller family and affordable accommodation. However, it was also argued that issues related to choice justified a strategically planned approach. There was some concern at Glasgow's housing releases, at a professional and political level, both relating to both the scale and manner of potential release on the urban fringe. At a strategic level, it was argued that current demand may not last forever and there was a risk of undermining strategic priorities related to urban regeneration. This was felt to be a particular issue in the GCV area where authorities are separate but operate within the same market area. In discussion of these issues we observe some tension between on the one hand wanting more flexible and tailored mechanisms at local level while on the other seeking a more effective measure of strategic alignment.
5.93 Transport and infrastructure were identified as significant issues over which planning officers felt they had least control due to fragmentation lack of resources. In the past the previous Regional Authority at least had a degree of control over investment in water and sewerage and transport infrastructure. In contrast, current decisions on the location of new development are often constrained by available infrastructure. Infrastructural issues often transcend administrative boundaries, although local solutions are being developed, for example, with regard to water infrastructure. However, some officers were reluctant to accept developer arguments of spare capacity as a valid justification for development in the Green Belt, which could result in piecemeal development. Infrastructure constraints were thus an important example of the circumstances which could change and thereby alter the local interpretation of general Green Belt policy.
5.94 The Structure Plan addresses the fact that some recent greenfield industrial and business development is poorly linked to areas of unemployment. It notes that some nationally safeguarded Inward Investment Locations are currently designated as Green Belt. However, should such sites cease to be required, they would retain their Green Belt designation. In an area currently experiencing population decline, the function of the Green Belt is perceived to be a means of encouraging urban regeneration within North Lanarkshire. Major strategically planned releases for business and industry in North Lanarkshire involving Green Belt included Eurocentral, Junction 6 Newhouse, and Strathclyde Business Park. North Lanarkshire like other areas has also experienced some housing pressure and associated releases of Green Belt land ( see also analysis and mapping of decisions in Appendix 3).
5.95 The Structure Plan also promotes local employment opportunities (for business and industrial development up to 5-10 has) in constrained suburban locations "having regard to impact of Green Belt Structure and character" in an effort to reduce car- based commuting. Promoting indigenous economic development continues to be a priority within East Dunbartonshire and planning officers pointed to some small scale successes. However, it was also acknowledged that such gains (e.g. pavilions included as part of mixed use developments) came with the risk of substantial housing, which could impact on existing transport networks. But it was recognised that housing was the only sector of the market that was relatively buoyant at present and developers were willing to fund business development from housing.
5.96 There was a view that national policy was more lenient towards certain types of development e.g. economic development and telecommunications. It was felt that such an attitude reflected a lack of confidence in where such development fits into the long-term framework, with decisions taken on a shorter term, reactive basis. Although it was recognised that attitudes are beginning to change, it was felt that the current strategic framework was in a better position to respond to requirements to designate sites of national importance well in advance, thereby providing consistency in approach. In some situations, it was conceded that difficult decisions have to be made when there is a genuine choice between accommodating inward investment or losing it elsewhere, but in general these situations are rare.
5.97 The Structure Plan also makes provision for Strategic Environmental Resources, the majority of which are located within the Green Belt's outer boundary. In addition to the Green Belt, the Green Network and priorities, the Strategy requires a "Strategic Environmental Framework". This Framework for the sustainable development of natural resources is to be a priority for the first revision of the Structure Plan. Planning officers attached considerable importance to high value environmental settings and these objectives were to be achieved through the settlement strategy. The Structure Plan also highlights small-scale opportunities around towns "close to poorly managed areas of Green Belt, which if enhanced could create much valued and needed recreation and amenity space". Such "poorly managed areas" are also natural or semi natural and may have a high ecological value and as such are important in their own right.
Urban Form
5.98 The Green Belt Framework is illustrated within the Structure Plan in Key Diagram Insert A and covers a large area (100,000 ha). The Diagram represents the "broad framework of Green Belt resources" and is expected to guide future releases from the Green Belt, should they become necessary. The Diagram makes a distinction between the inner Green Belt (including sensitive wedges), Green Belt structural corridors (separating major parts of the conurbation) and the outer boundary.
5.99 The areas designated Green Belt within the Glasgow City Local Plan are the countryside surrounding Glasgow's built environment as well as Pollok Estate and Park. Glasgow's Green Belt is composed of six distinct areas (on the periphery) - Castlemilk, Parkhouse/Crookston, Drumchapel, Summerston, Millerston, Easterhouse/Broomhouse. These areas also form part of the City's Green Network. As such, those areas of Green Belt that fall within Glasgow City Council's administrative boundary are not contiguous. Glasgow has already coalesced with a number of urban areas round the edge raising issues as to whether this is a valid function. Pollok Park is described by planners as the most successful bit of the Green Belt in terms of usage and is surrounded by development. Plans to create a new country park in the South are intended to replicate this and officers are currently considering utilising the model elsewhere in the city thereby providing recreational use and landscape setting.
5.100 All open land (other than the Campsie Hills) out with the urban settlement structure form East Dunbartonshire's Green Belt.
Nature of Regime
5.101 In accordance with SDD Circular 24/85, an assessment of Green Belt boundaries was carried out within the Structure Plan. In terms of the inner boundary, it was felt that there was a continued need to give priority to urban regeneration and no strategic adjustments were required to the general extent of the current Green Belt, " except where necessary to meet other Structure Plan requirements". This would seem to offer local authorities some discretion in how they interpret such requirements.
5.102 The Structure Plan also refers to "locations where the release of urban edge green field land linked to the restoration of an equivalent area of brownfield land for Green Belt purposes" can contribute to the realisation of the Metropolitan Development Strategy. However, any such opportunities should be well located in relation to the transport network and are to be identified through the Local Plan process.
5.103 In terms of the Outer Green Belt, "some detailed adjustment…might be appropriate" (e.g. moorland in view of the protection offered through Regional Park Designation). Elsewhere, "the general extent of the Green Belt relates to the purposes of the Green Belt, in particular, the area within which there is a need to control development pressure for the spread of the built up area and the encroachment of development into the countryside".
5.104 Local Plans are expected to review the Green Belt boundary within the framework of the Structure Plan. The Glasgow City Local Plan has taken the identification of long term growth areas forward through designated Comprehensive Planning Studies, which provide an indication of the Green Belt's capacity for further development. The total capacity of sites subject to these studies is very much larger than the additional housing allocation made in the recent Structure Plan. Within these studies, seven main capacity issues are addressed including landscape appraisal and impact on surrounding areas/communities (and mitigation measures) as well as transport, utilities, community capacity, land form and impact on community infrastructure (e.g. schools). The Studies assess medium term potential; should there be a requirement for future housing land releases in line with the Structure Plan, the studies will provide an indication of environmental capacity, highlighting constraints to development. The Studies also address market issues including consideration of what the market would sustain in specific areas. The Studies therefore include an assessment of whether sites can be developed, as opposed to previous criteria based assessments, and are considered to be more responsive to market requirements. Each of the Studies is expected to be drafted by the middle of 2004.
5.105 In discussing future land requirements, there is a tension between assessment in terms of supply and demand and local authorities' view of settlement structure. There has been limited debate over which areas Glasgow may wish to expand into. Such a debate at city-wide level would make explicit the City's intentions in terms of growth, thereby enabling the city to focus on preferred areas. Planning such extensions is preferable in terms of levering in associated infrastructure and ensuring the provision of appropriate facilities required to support "understandable communities". East Dunbartonshire was also keen to achieve significant community benefits associated with land releases (e.g. infrastructure, 40% affordable housing).
5.106 At the moment, the Planning Studies are viewed as technical reports and the Council has yet to decide how these will be fed through the statutory consultation process. Once a decision has been made as to those options that are to be taken up, the Council is aware that it may be open to challenge and that the Studies need to be robust enough to withstand this. At present, landowners are closely involved in the Studies and awareness has been enhanced through the Local Inquiry process. Informing the wider community may require a different mechanism, possibly through the Area Committee system.
5.107 Local reaction to the potential land releases in Glasgow was mixed, with only one of the ten sites being subsequently withdrawn. The majority of objections, in the area that received the most (i.e. Robroyston), were related to lack of community facilities rather than loss of Green Belt land. In other areas, objections were related to loss of Green Belt land but these were relatively few in number.
5.108 The Structure Plan identifies thresholds for the scale of development that are likely to represent a significant departure from the Structure Plan. In particular, the Plan is sensitive to the "cumulative impact of, and therefore need for control of small scale housing developments in the Green Belt or wider countryside". Where urban expansion is justified, the Plan refers to the need to control scale and form. The Joint Committee has responsibility for continued review of the need for further development and any future strategic urban expansion required would be brought forward through an alteration to the Structure Plan. The selection of such areas is to be based on the guiding principles of sustainable development and criteria used in policy SPP1. In particular, any future urban expansion will require to be linked to existing or potential core public transport network, travel demand management and the promotion of non-road freight options. Important decisions are to be integrated, where possible, with regeneration initiatives and have regard to impact on the Green Belt.
5.109 Consideration is also given to development of low density, low impact housing within the Green Belt and the wider countryside. The Plan concludes that "the potential opportunities of these forms of development are extensive and ad hoc in their distribution throughout the Structure Plan area. The cumulative effects of such development in the Green Belt are covered under the general presumption against isolated and sporadic development in the Green Belt and wider countryside generally."
5.110 Local Plans also cite a range of criteria that developers are required to meet when developing green field sites. In particular, sites have to be serviceable in terms of infrastructure, transport and access. The Glasgow City Local Plan is to apply a maximum density standard on mainstream family housing on greenfield sites. On upper market greenfield sites, layout design, minimum plot and garden sizes and other standards will be used to "create high quality housing environments capable of competing with suburban locations outside the city boundary." The development of large or locally significant sites or those of key importance to the City, such as greenfield sites, are to be undertaken within the context and framework of a master plan or planning brief for the site. Where mainstream middle market housing is to be developed on Greenfield sites, a maximum density of 25 dwellings per hectare is to be applied. All greenfield development is also expected to meet layout and design guidance and greenspace, landscape and environmental criteria. These were thought to be important in ensuring quality development.
5.111 Glasgow City Council recognises "that situations could arise where development within greenbelt may be acceptable". There is a presumption against mineral (including peat) extraction, open cast coal mining, tipping and infilling unless it can be shown that the substantive area of the proposals involves restoration of derelict land while not adversely impacting on residential areas, important wildlife sites, protected species or other environmental resources, landscape character and local distinctiveness, visual amenity or affecting the enjoyment and recreational use of the countryside. The Plan also sets out categories of development that are exceptions including limited new development directly associated with telecommunications. While a number of planning applications are granted in the Green Belt, these are considered by officers to be for relatively minor matters (monitoring data provided for a limited period seemed to confirm this so far as the City was concerned). While it was recognised that there was "always a penalty" to farming around urban areas in terms of litter, vandalism and repairs, issues related to development within the countryside were not considered to be relevant in Glasgow's case.
5.112 Overlapping designations- In Glasgow and Clyde Valley, Green Belt policy was not intended as the primary policy to protect particular sites such as SSSIs as this was seen to be the function of other designations and policies Although a commonly held perception, this was not considered to be justification for having a Green belt. It was also suggested that the Green Belt carried more weight with ministers because it carries weight with the public.
5.113 There were mixed views amongst planning officers as to the relative status of Green Belt policy to existing environmental designations (e.g. SSSIs). On the one hand, overlapping designations were perceived to add credibility in policy terms and had greater strength as a result. Some officers felt that adopting a tiered approach was too similar to the "old white land concept" and would encourage development pressure. It was argued that, as all designations were derived from national guidance and good practice developed elsewhere, proposed top tier designations were already development 'no go areas' that "sit under" Green Belt designation. It was suggested that Green Belt land is protected by landscape purposes and as such everything that falls below this may be considered contributory factors. However, questions remained as to whether the Green Belt could currently be considered the top tier of protection. While some officers felt that designating top tier land would send out a different signal and reinforced existing designations, others felt that it was important to retain a functional element and that this was one of the strengths of Green Belt policy. Accordingly, all Green Belt was considered to be multi-functional in terms of its wildlife, recreation, flood management and access functions and the more of these functions a site delivers, the better. It was also pointed out that some environmental features (e.g. pond) currently designated may have come about due to e.g. drainage problems and that there was scope for more effective management through associated development. However, it was generally agreed that there are a "series of planning fundamentals" or basic planning tenets that should not be lost sight off (e.g. gateways, visually intrusive development on hills) and that, as a tool, the current concept of Green Belt was useful.
5.114 Officers pointed out that SSSIs were not designed to control development but to control damaging activities that may be carried out within such areas. They also suggested that SSSIs were more sporadic in nature and can be located within urban areas. It was felt that such designations served a particular purpose but do not duplicate Green Belt roles and responsibilities. Policies designed to control development in the countryside were seen to lack "panache" from politicians' and developers' perspectives. It was felt that 'changing the name' would risk diluting the concept. Adopting a two tiered option was viewed with caution and some planners had reservations, arguing that this departs from the concept of the Green Belt as a "belt to control the expansion of towns" and would prove to be very unpopular with local politicians and communities. Some planning officers were wary of "any such half-way house" as there was "a danger that the thing runs away with itself". It would also promote perceptions that if land was not is the top tier, it was not protected - "Developers eyes would light up with glee!" Previous structure plans reviews had assessed this approach and rejected for a range of reasons.
5.115 Future Development zoning - It was argued that once an area had been assessed it leads to speculation and public concern that the Green Belt is being downgraded, resulting in local resistance. However, it was also suggested that such scenarios are the result of a communication issue. Allocating land for long term requirements was considered by some respondents to be impractical in an area like Glasgow and Clyde Valley in terms of the scale and distribution. Although some areas were identified for long term development, these were kept as Green Belt because it was considered important to minimise speculation. It was felt that the current system enabled any such releases to be fully debated within the formal public process and allowed people to have their say. Strategic planners were more inclined to adopt a responsive and flexible approach to reviewing future land releases for housing, as opposed to identifying a specific strategic land reserve, and described this as a 'plan, monitor and manage' approach.
5.116 Boundaries- As mentioned above, the release in the South of the city is linked to the provision of a country park, which is expected to protect the edges more effectively than designating a defined edge. The fact that the park also provides protection in terms of coalecence is a "happy coincidence". Investment in the park is also expected to enhance access. Glasgow City council is prepared to enter into agreements with landowners and surrounding communities to improve access and promote investment in natural resources based upon information provided within the Planning Studies. It was argued that having an up-to-date and robust Local Plan was more important in ensuring that boundaries were defensible. As releases were planned, defending boundaries was less of an issue when it came to appeals. The Comprehensive Planning Studies provided a basis upon which to assess applications and were accorded status (by the Reporter) as they were referred to within the City Local Plan. Indeed, it was felt that having a structured 'plan-led' process and the Planning Studies helped ensure that the boundaries were not subsequently adjusted through the Inquiry process. As the Planning Studies are more localised and relevant to neighbourhoods, they act as a useful tool enabling the Local Planning Authority to adapt to a changing situation. Although the Green Belt boundaries are expected to change in the long term as a result of land releases, it was anticipated that elements of the Green Belt would be more defensible as a result of this process.
5.117 East Dunbartonshire reviewed its Green Belt boundaries while preparing the current plan. As the Council was not required to plan for any major releases, this review sought to identify a long-term, defensible and sustainable boundary. While some sites have been identified within the urban area, these were the result of a need to rationalise the Green Belt to create a defensible boundary in some areas. A proposed Master Plan for a sensitive area between Bearsden and Milngavie will ensure that a wedge will prevent the two settlements from coalescing. Otherwise, boundaries in East Dunbartonshire are strongly defined.
5.118 Most interviewees felt that a sequential approach to site selection for future development offered a degree of protection, provided a means of identifying the "real choices you have and in making the best choice given the circumstances". The sequential approach also ensured flexibility to changing circumstances.
5.119 Some argued that the concept of the Green belt was "not needed intellectually" in the context of a robust and up-to-date development strategy. It was argued that the Green Belt around Glasgow reflected the interdependent settlement structure that exists and requirements for some consistency of control within the region.
5.120 In terms of life span, it was argued that the Green Belt only had the life of the development strategy. This places considerable emphasis upon ensuring that plans are kept up to date. For example, the Structure Plan has a plan horizon of 10 years (not long in the context of the proposed Strategic City Region Plan system). However, this may need to be reviewed in light of local circumstances (e.g. urban regeneration) and take up in areas experiencing rapid growth (e.g. every 2 years). This also helped to counter unnecessary hope value and speculation.
Land Management
5.121 Management of the Green Belt has always been an issue within Glasgow and Clyde Valley due to scale and the need for regeneration of the peripheral estates on the urban edge. The area has a long history of environmental initiatives dating back to the 1970s including the Clyde Calders, Kelvin Valley and Cart initiatives. In 1981, the Green Belt was incorporated into wider strategic policies in an attempt to improve clarity while highlighting the need to manage it through specific initiatives. These initiatives subjected areas to more detailed analysis and highlighted the need for a more systematic framework. The value in having a more flexible mechanism led to establishment of the Green Belt Management Company (now the Scottish Green Belt Company). Up until 1996, substantial resources were available as part of an overall environmental programme. However, this disappeared as a result of the "squeeze on resources". Recent initiatives covering the Green Belt include the Central Scotland Trust, initiatives to promote community woodland and the Countryside Around Towns/Greenspace Network, a number of which work alongside local communities and schools.
5.122 The current Structure Plan sets out a 'Green Network', which extends from the heart of Glasgow and other town centres through to the remoter communities. This Network is to be detailed in the Local Plans and implemented through joint action programmes with key public agencies. Although the Plan refers to commitment to some key components, it also concedes that there are gaps, which are to be priorities for promotion and management. The restructuring of the urban fringe is also regarded by Councils to be a key priority.
5.123 Regarding rural development, there is a presumption in favour of development that serves rural needs and the Structure Plan sets a framework for sustainable development of natural resources in terms of tourism, recreation and primary industries. There were concerns, however, that rural diversification has been more about "asset stripping" in some areas and can be difficult to determine. East Dunbartonshire have eleven categories of acceptable development related to agricultural use. Current policies allow for a degree of flexibility in order to permit certain limited agricultural support and diversification activities, outdoor recreation and a limited range of developments which can justify the need for a rural location linked to tourism. The Council has marginally relaxed its policy regarding the redevelopment of farm steadings and small holdings. The potential for tourism has also been recognised. However, the Council is wary of tourism being used as a justification for the development of housing in the countryside. Despite agricultural decline, the LPA continues to receive a number of applications for agricultural workers' accommodation and it can be difficult to determine whether these are genuine. Applicants are required to provide a full business justification and the Council calculates whether labour is needed. However, this was an area in which the Council would value independent and objective advice.
5.124 In Glasgow, each of the Green Belt sites has a dedicated team and each is analysed in terms of landscape quality with advice from the Environmental Section regarding required mitigation measures. This includes a detailed design brief and identification of issues requiring further negotiation with developers on e.g. edge treatment. Glasgow also has access officers and a draft Access Strategy, which is out for consultation at the moment. However it was suggested that such initiatives tend to be opportunistic depending upon landowners' interest in taking advantage of support offered and "what is flavour of the month". New legislation (Land Reform and other) is expected to impact on what can be carried out the countryside, which will also impact on the Green Belt. In the context of Community Planning and partnership initiatives such as the Healthy Cities Network, the City Council is working closely with other partners in meeting health related objectives linked to promoting cycling and walking. Such initiatives have enabled more joined up working but processes and mechanisms continue to evolve. In all this, however, the Green Belt is treated in the same way as greenspace.
5.125 Most Green Belt land in East Dunbartonshire is considered to be of good quality, particularly around the fringe. A landscape character analysis was carried out in preparation of the new East Dunbartonshire Local Plan, thereby strengthening the Green Belt. Obtaining resources for environmental enhancement, however, is proving to be more difficult as funding is channelled through Social Inclusion Partnerships. East Dunbartonshire also have a greenspace team (including a biodiversity and two access officers) and has developed a programme of work to be implemented in partnership with local landowners. Blight was not considered to be the problem it had been in the past as both predecessor authorities took a firm approach. Land that is 'banked' tends to be farmed and is well looked after as developers view such sites as long term assets and are prepared to invest in the land.
5.126 Some areas of Glasgow's Green Belt are considered to be of good quality. However, other areas have no maintenance regimes in place. Blight was an issue in Glasgow, with some owners buying land for development potential and using the subsequent non-management of that land as an argument for doing 'something better' with it (i.e. development). However, officers felt that Glasgow did not suffer too badly. In general, maintenance was tied to ownership and was not necessarily tied to landowners' attempts to realise land value. It was also suggested that title deeds provided protection in the case of Pollok Park, which might have been "eaten into" if these had not been in place.
5.127 In Glasgow, responsibilities for programming, implementation and maintenance of greenspace within large developments are subject to agreements. This enables developers to build on redundant ground on the urban edge in exchange for the development of new open space, if it is in an accessible area (e.g. Auchinlea). The City Plan also provides examples of how to calculate "greenspace obligation" relative to population. However, it should be noted that this applies to all sites, greenfield and brownfield.
5.128 North Lanarkshire has been consulted regarding a number of woodland planting schemes in the Green Belt, most recently at Newarthill, Motherwell and Drumpellier, Coatbridge. In both cases, the owners are using the opportunity of the Woodland Planting Scheme to diversify their holdings. It is not known whether development prospects have been a consideration.
5.129 There was general consensus that countryside around towns and cities should have a higher value than at present and required specific measures to address that. There was also general agreement that the Green Belt had a recreational value linked to debates on preferred settlement strategy.
Other issues
5.130 Planning officers in all authorities felt that the Green Belt has to relate to local contexts and performs a different role in different situations. As such, it was felt that a 'one glove fits all approach' would not prove workable.
5.131 Officers felt that the Circular was in need of review from a users point of view. The current circular was perceived to be a "flimsy document that lacks volume" and as currently phrased is a "vague tool". It was felt that a more strongly worded Executive policy would assist local authorities in resisting incremental development in appeal situations (vis. 'rounding off the urban area').
5.132 Officers in East Dunbartonshire were keen to retain the Green Belt as it prevents urban sprawl and ribbon development. It was argued that the Green Belt was strongly and consistently used in East Dunbartonshire and there was reluctance to see that alter - "if it has worked up to now, it would seem foolish to change it." Retaining the Green Belt was seen to be critical to the Local Plan's aim of achieving sustainable development. Whatever the new arrangements, it was felt that local authorities should have the option of retaining the Green Belt even if some local authorities do not want it.
5.133 Officers felt that the Green Belt was the most publicly known and politically defended concept in planning but was also the least understood. Planning officers suggested that while the term Green Belt has a degree of credibility with the public, changing the name was considered to be irrelevant from a professional perspective as long as there was a planning regime in place. It was felt that the debate should be "less hung up with names as functions".
5.134 Planning officers at Structure and Local Plan level referred to Green Belt's negative aspect in being seen as a method of stopping development. It was felt that the Green Belt was currently viewed as "just a land use designation " and planning should be proactive in encouraging "things to happen so people can enjoy it more " so that the Green Belt is regarded as an environmental resource. It was felt that access was just as important as proactive management in terms of promoting plans' social agenda regarding quality of life.
Analysis of Development within the Green Belt area
5.135 Appendix 3 reports on an analysis of recent planning decisions in part of our Green Belt case study area, namely North Lanarkshire. It should be emphasised that the findings do relate to this one area and recent time period, and are not necessarily representative of experience across the whole GCV area. The analysis of planning applications in the Green Belt within North Lanarkshire would suggest that the 'plan-led' system is working to some extent. However, it does not suggest that Green Belt policy represents an impermeable barrier to development in this area. A significant number and proportion of applications are getting approval despite in some cases being at variance with the previous Plans. This would seem to accord with planning officers' views that local politicians are sometimes less interested in the Green Belt per se than in the perceived need to facilitate development. This is perhaps understandable in that many parts of North Lanarkshire have experienced decline of traditional industries and development is welcomed. However, this approach would seem to be at odds with strategic policies adopted elsewhere. While the Scottish Executive has called in a number of proposals within the Green Belt for consideration, it was felt that the rationale for intervention, or non-intervention was not always clear. There have also been a number of appeals, which have tested the Green Belt policy.
5.136 The analysis of planning applications demonstrates that, when size of site or number of housing units are considered, approval rates are higher in urban edge situations than in the isolated Green Belt areas or indeed in the countryside beyond. This suggests that the planning authority to some extent concurs with the development industry in favouring sites at the urban edge. That said, the majority of demand as measured by applications, land or housing units is on 'greenfields', particularly former agricultural land, although there may be issues of relative quality compared to elsewhere. There does not seem to be much evidence of decisions discriminating in favour of brownfield sites and against greenfield or other 'green' sites, within the Green Belt area. The formal GCV policy in favour of brownfield sites is specific to urban areas, but in other parts of Scotland or UK this would also be a relevant consideration in Green Belt or rural areas.
5.137 The major land uses proposed are housing, business and leisure/sport etc. Housing accounts for approaching half of the land area involved. Next in importance comes the 'other category', including leisure/sport/tourism. The third significant category is business/industry/storage/distribution, perhaps partly reflecting North Lanarkshire's specialism in this kind of activity based on its central location and communications. Minerals and waste are of some importance in the Green Belt, but rather more significant in the countryside areas beyond the Belt. This evidence confirms that planning decisions in the North Lanarkshire Green Belt appear to be more restrictive in the case of housing than in the case of economic development (where refusal is rare indeed). This may be unsurprising in a district with the industrial history experienced by North Lanarkshire.
5.138 Mapping of the major applications ( see Appendix 3) shows some concentration in a broad arc around the north and east of the main settlements of Coatbridge-Airdrie and Bellshill-Motherwell. Many sites are greenfield and these tend to be closer to the urban edge than the brownfield sites (within the Green Belt area). However, the pattern appears less clustered than that found in the comparable mapping for Edinburgh Green Belt.
5.139 The evidence from the applications and decisions data confirms North Lanarkshire's emphasis on economic development, indicating a fair level of development activity in the Green Belt and a willingness to approve development in many instances. The main sector where this seems to be less the case is housing, particularly larger housing applications, which are concentrated more on the urban edge. Here Green Belt control is biting to a degree, although it is far from being an impermeable barrier to development. Also, as was clear from the GCVSPT interviews, there are periodic (every 10 years or so) major housing releases, which effectively redraw the Green Belt boundaries. So there is some support here for the housebuilders' contention that Green Belt is an "anti housing policy", but probably not as strongly as in some other areas.
Comments
5.140 The aims and functions of the G&CV Green Belt reflect the full range of functions identified in this study, both those contained in the original Circular and other functions, older and newer. Arguments for preventing urban coalescence based on urban identity are still strongly voiced in some areas. Regeneration has been important over the recent past, but this is quite often used now as an argument for Green Belt release, which sits somewhat uncomfortably with the large legacy of vacant brownfield land in the region.
5.141 It is clear that, within the comprehensive framework of aims and functions set by the Structure Plan, different local authorities place different emphasis on the different functions and, arguably, interpret their implications differently. There is some contradiction between continuing recognition of the role of the Structure Plan in mediating strategic issues and an increasing willingness to pursue differing local strategies. We perceive, as do local actors, a degree of competition between the local authorities for certain kinds of development, and some consequent unease about differential interpretation and operation of Green Belt policies in the different authorities.
5.142 We have identified elsewhere that Green Belt can be used implicitly as a form of strategic land reserve. It is abundantly clear that this is very much how Green Belt is being used in G&CV, particularly through the cycle of plan reviews leading to major releases but also through the identification of key sites and corridors within the designated areas and through particular opportunistic releases.
5.143 The region as a whole has a complex urban structure, with the central city varying in its dominance of different parts, and this is reflected in the inherited shape of the Green Belt. Transport has been an important criterion in decisions on the location of new development and continues to be reflected in the criteria for new releases. Other forms of infrastructure are playing an increasingly constraining role, with local authorities lacking leverage over the fragmented system of provision.
5.144 Wedges are already a significant feature of this complex structure and parts of the Belt are already conceived very much in these terms. Some Green Belt wedges penetrating the urban structure are perceived as particularly valuable forms of greenspace. The concept of a green network linking the urban cores to the countryside is an important principle informing planning policies and environmental enhancement programmes.
5.145 This case study perhaps provides an important test of the concept of a city-region strategic plan based on consensus between the partner authorities, with housing markets for example officially recognised as cutting across authority boundaries. As indicated above, the current consensus system is subject to some strain arising from the different interpretations and emphases of policy in the different adjoining authorities. The nature and expression of strategic policy allows considerable scope for local discretion. Local Plans set and review specific Green Belt boundaries within the strategic context set by the Structure Plan, including identifying in detail those releases of former Green Belt land proposed in Structure Plans. Significant use is currently being made of 'Planning Studies' of potential release sites as a non-statutory precursor to Local Plan allocation, while in other cases an economically-oriented strategic development framework appears quite important alongside the statutory land use plans themselves.
5.146 In practice, policy appears to us to be applied rather differently in the three case study authorities we have looked at. This applies both to the planned release of significant sites for development and to the operation of development control within the frame set by existing plans. In short, the Green Belt is more of a stable long-term constraint, and control is much tighter, in some authorities than in others. Practitioners express mixed views about this, both welcoming local specificity and flexibility while also expressing some concern or unease about some of the decisions of their neighbours.
5.147 The general view, from both Structure Plan and local levels, is that, while the general policy is enduring, Green Belt as a designation of specific land is not permanent, but rather is a flexible tool whose life does not necessarily extend beyond that of the current Development Plan (c.10 years). However, the views expressed from one of the authorities seem more in consonance with permanence.
5.148 The evidence confirms that housing development is resisted rather more than business development, but the degree of restrictiveness over housing seems much less in practice than found in some other areas such as Edinburgh. Part of the reason for this is the concern of some authorities to provide more housing choice and to attract a more balanced population, as well as the wish to see development in general or to secure side benefits in terms of environmental or other facilities. Isolated individual housing in the rural areas is not looked on with particular favour, however.
5.149 Overlapping with other specific designations is not seen as a particular problem. There is general support for protecting the best greenspaces within the belt. The idea of tiers of Green Belt was considered but with considerable concerns expressed about this weakening control in the lower tier areas. Our suggestion of explicit forward allocations of land for future development needs was felt to be impractical, although the reasons for this were not entirely clear. In effect, the Green Belt contained the strategic land reserves and key sites or corridors for future development. There was support however for a 'sequential approach' to releases, with the application of a full range of good planning criteria to individual proposals.
5.150 There has been a strong tradition of proactive land management and environmental/access initiatives, but these have been hampered by a squeeze on resources since 1996. There is still a need for more positive tools and resources in this regard to complete the green network and improve access. Blight is perceived to be a problem in some areas but not others; we would observe that this may correlate to some extent with the tightness and permanence of the regime.
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