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REVIEW OF GREEN BELT POLICY IN SCOTLAND

CHAPTER SIX - INTERNATIONAL PERSPECTIVES

WHY LOOK ABROAD?

6.1 Part of our research looked at experience outwith Scotland and the rest of the UK. Our reasoning was that the spread of urban areas is a challenge that all land use planning systems have to address, and that international concerns to move towards more sustainable forms of development have led to renewed interest in urban form and land management at the urban fringe. Green Belt policy is one approach to some of these issues, but are there others? Do countries with similarities to Scotland, such as the Scandinavian states where there are few large cities and an extensive land area relative to population, use a Green Belt? We also looked further afield to find examples of other approaches and to probe how they fared in practice.

6.2 The methods we used to do this part of the research were a combination of literature review, e-mail questionnaires and follow-up telephone interviews. We cannot claim that our findings are exhaustive, or that we have looked at every relevant country or example of how other countries plan and manage their urban growth; that would be a substantial research exercise. However, we have been able to access the experience of practitioners and academics with substantial knowledge and insights, and therefore we believe that our findings are of value to this study. At the same time we would caution against casual transfer of experience internationally. Cultures, legislation, and institutions all differ, and abstracting policy from its context can be risky. We have therefore sought to make measured comments on possible transfers from abroad. Rather than summarise findings country by country, the chapter analyses the international experience in relation to the key themes of the research project overall - function; nature of the regime; land management and then urban form.

THE FUNCTION OF GREEN BELTS

6.3 Green Belts in the British sense were very much the exception, not the rule, in the countries that we studied, though Kuhn (2003) says there are Green Belts around Vienna, Barcelona, Budapest and Berlin. How far are the purposes of Scotland's Green Belts reflected in the planning systems of other countries? A fairly typical answer was given by a member of Switzerland's Federal Office for Spatial Development: 'One aim of the national spatial planning policy is to stop the excessive growth of urban areas. However, there is no special policy - there are no "circular belts", just "barriers", and those aim primarily to keep existing settlements (villages, towns, cities) spatially separated'. Similarly Denmark does not have a Green Belt policy, 'but we have a clear distinction between urban areas and non-urban areas (rural areas). Urban areas/urban zones have to be clearly defined as such in regional and municipal plans. You have to have a specific permission if you want to build a house or anything which is not connected to farming activities in the rural zone.' However, there are other countries, notably Italy, where there is no explicit national policy seeking to constrain the spread of urban areas.

6.4 Despite the fact that the idea of Green Belts has been widely debated amongst planners and architects in Italy since the 1930s, Marco Cremaschi and Anna Laura Palazzo tell us that such ideas have had 'scant influence on practices'. However there are some examples of recent green belts in Italy, as Box 6.1 shows.

Box 6.1: The exceptions that prove the rule in Italy

6.5 All the countries we studied exhibited some concern to protect agricultural land. For example, Rachelle Altermann told us 'Israel's national planning system has an entrenched policy for the protection of agricultural land. The clearance of a special national body must be received for any conversion of agricultural land.' Similarly, 'Since the early 1990s the instrument of a national statutory plan has been used to map out areas of rural landscape where development is limited'.

6.6 The Netherlands has long been regarded as the European country with the most comprehensive and integrated spatial planning system, but again their approach addresses concerns associated with Green Belts, but through different policy mechanisms. There has been a national spatial policy to contain urban growth since the 1960s, but instruments and aims have changed slightly over time. Currently containment is seen as a means towards sustainable development, by protecting countryside while also facilitating access to a variety of houses and jobs, and reducing the need for car-based trips. Containment is also seen as a means of assisting urban regeneration. Similarly in Switzerland the protection of green areas serves a range of other purposes as well as preventing the coalescence of settlements: 'Green barriers have not only the function to separate the settlements (thereby structuring the landscape), but they are equally important for the protection of agricultural land, to provide open spaces for recreational use, to elevate the ecological quality and to protect fauna and flora.'

6.7 In summary the aims of Scotland's Green Belt policy are echoed in the planning systems of several other countries, but they are usually approached by means other than Green Belts.

THE NATURE OF THE REGIME

6.8 In most other countries planning control operates through zoning rather than on the British basis of discretionary development control. This means that, notwithstanding our 'plan-led system', in these other countries the plan is the determining document for decisions on development. Such systems carry a higher degree of certainty than ours, and much of the control function is primarily administrative rather than professional. This also means that plans tend to be more precise about what uses are permitted or not permitted on each piece of land, compared with the policy-led UK system. Hall (2002, 205) describes zoning in the USA as 'a limited and negative system of control over land use… a device for segregating different types of land use… it could not easily protect open countryside against development'. Ironically this weakness means that public acquisition of land is often needed in the USA to protect it from development, and the fact of purchase is likely to mean that positive management regime is then integrated with the system of protection, e.g. with land being used as a state park. Hall cites San Francisco in the 1970s as an example of how a de facto green belt was created in this way. Similarly he notes that Boulder, Colorado, raised local taxation to acquire the land to create a Green Belt that is now twice the area of the city, but which has helped to push up housing costs beyond the means of low income people, as well as extending commuting.

6.9 In the USA zoning is typically a local matter that is not constrained by a more strategic level of planning policy. Thus the capacity to articulate a green belt as a policy is very limited. Furthermore there are strong cultural attachments to private property rights and to low-density living. As we shall see later, these have mediated the way that zoning operates as a planning regime. However, a zoning system is also the norm in continental Europe, though in some countries the system is nested within a hierarchy of policy and plans at different scales, similar to what we have in Scotland. Thus, for example in Finland, there is no actual 'green belt policy' but 'protection of the beauty of the built environment and of cultural values' is written into the Planning Act 2000 (section 5), which also attempts to prevent 'creeping' urbanism between cities or districts and to protect their special values (section 54). To this end the legislation permits 'joint' local plans to be prepared between adjacent local authorities.

Box 6.2: The regime in the Czech Republic

6.10 The Swiss situation is rather typical of a European regime. The national level designs and implements the general spatial planning law, develops guidelines (Swiss Planning Policy Guidelines, 1996) and generally influences spatial development by its sectored polices, or integrated policies like the urban development policy. However, the main instrument to contain the spread of urban areas is zoning, a matter on which the communes - and there are nearly 3000 of them -have very considerable discretion, within guidelines set by the higher tier cantons. The zoning plan of a commune will precisely map where building is allowed or prohibited. The latter zonings include "agriculture zone" or "protection zone". So there are clear urban growth boundaries, and a legal urban / non-urban distinction. Within the area designated for urban growth, the competence for designing and zoning- defining its uses - lies with the commune, although the canton must give its approval. Within the "agriculture zone", strong restrictions apply, defined in the national spatial planning law. Thus the system is both more devolved but also more prescriptive than the one that operates in Scotland.

6.11 It is less easy to generalise about large federal states, such Canada, the USA or Australia, as planning legislation is usually a state/province matter often supplemented by local codes. In such countries land availability and popular aspirations for low-density living meant that many of the aims of green belt policy did not apply. However, from the 1970s onwards environmental concerns led to some initiatives to modify the way that zoning and land sub-division rolled out low-density suburbia. Pacific coast US states began to enact growth control ordinances, often having to overcome litigation to do so. In essence a local council declares an urban growth boundary (which may actually lie beyond the authority's current administrative limits). Once approved this controls the servicing of land for development. Box 6.3 gives an example, showing that the process can be contentious, but also demonstrating the scope for planning regimes to use mediation to resolve urban fringe disputes.

Box 6.3: An urban growth boundary: Ephrata, Washington State, USA

6.12 Planners with direct experience of working growth management systems have some reservations. Bill Grimes, who led the mediation by Studio Cascade, says that the 'one size fits all' approach of Washington's State-wide GMA means that some of its requirements (such as proposed urban densities of 3 houses per acre) were impractical in a small community like Ephrata, where topography makes some sites unsuitable for urban development or rural uses like farming, and yet these were required by state law to meet standardized regulations for these uses. Furthermore, the GMA has been amended annually since it was initiated in 1990, meaning there is a need for constant updating of City compliance and, to some stakeholders a constant need to monitor how changes affect their property holdings and to challenge these if necessary.

6.13 Reviewing Green Belts in Europe, and especially the attempts in the 1990s to establish a green belt of regional parks around Berlin, Kuhn (2003, 23) concluded, 'Pressure of suburban growth, inter-communal concurrence concerning the settling of private households and firms, complete loss of a regional food supply and - last but not least - limits of public planning to rule private ground and private land-uses are general reasons for deficits in implementing greenbelts around European cities.' He described the Green Belt as 'a wishful construct' that was not derivable from ecology or the aesthetics of suburban landscapes.

6.14 In summary, other planning regimes seem to give significant powers to very local levels of government - councils much smaller than any in Scotland - to demarcate in detail the boundary between urban and non-urban uses. Typically these plans are site specific and there are blanket restrictions on 'inappropriate development' that carry legal force. Once made these allocations are binding until the plan is changed. The contentious nature of plans for extending the urban area means there is a case for using independent mediators to seek agreement amongst contesting stakeholders. There are doubts about whether planners really have the powers to make Green Belts permanent.

LAND MANAGEMENT

6.15 Not only do many other countries entrust very local councils with responsibility for managing the area of urban-rural transition at the edge of settlements, but also local taxation in such countries is often structured in such a way that the local council gets a fiscal boost when new development occurs (not that these issues are completely irrelevant in Scotland). Councils, through local income/spending and/or property taxes are less dependent on central government for their revenues than is the case in the UK. In the US in particular there is a system of impact fees through which developers pay towards the indirect costs imposed by development (e.g. roads, schools etc). However, whether such systems by their nature alter attitudes or facilitate or impede attempts to achieve Green Belt policy aims is beyond the scope of this project.

6.16 Successful environmental management and positive use of protected land at the edge of the city inevitably requires resources and some institutional form committed to such outcomes. Not all the examples we looked at managed this. For example, Professor Maier from Prague told us that in his country 'a gap may occur between planning land-use control (e.g. for a recreational area) and available resources to implement it.' We have already referred to the way that public land acquisition created 'Green Belt' style areas of parks around some US cities. Public ownership also seems to be a conspicuous feature of successful land management in Finland as Box 6.4 shows.

Box 6.4: Positive Management of the Urban Fringe: Helsinki

6.17 Sometimes the positive management of the green space protected by land use legislation is tied to the sector rather than to the plan. For example in Switzerland, there is a consensus that in forest areas close to cities/towns, the welfare-function (recreation, clean air, groundwater protection) is more important than the production-function (wood, food, raw material). Similarly in Denmark there has been a national policy for the last ten years that seeks to create new forest areas near towns for recreational purposes.

6.18 In Israel there is partial integration of land use planning and environmental management. Professor Altermann reports that 'Due to the country's small size, declared national parks and nature reserves are often adjacent to urban areas. These are managed well. Since 2002-03 there are new and innovative initiatives for large (in Israeli terms) regional parks within the Tel Aviv conurbation and in other parts of the high-density central district. These are now on the approval track. To implement them, new instruments of financing are currently being developed. In December 2003 such a measure was approved with the guideline that all betterment tax revenues from development approved on the outskirts of the park (yes, this tax does exist in Israel!) should be pooled for the implementation of the park. There are no national resources for such parks so that the local authorities must use creative means, with the aid of national planning bodies, to implement the parks.' The Dutch are also looking at ways to balance costs between what they call ''green' development and 'red' development' within and surrounding urban areas so that the qualities of the 'green' areas can be enhanced.

6.19 One means of facilitating a recycling of development value released by edge of city development to enhancement of remaining green areas on the fringe is known as 'urban land adjustment'. Essentially it involves a planning-style agency facilitating the consolidation of adjacent plots in different ownerships, then organising servicing, sub-division and re-sale with cost-recovery. Adams, Disberry, Hutchison and Munjoma (2001) report on such systems operating on the urban fringe in Australia, Germany, Japan, Korea, Indonesia, Thailand and Nepal. A key factor, varying between countries, is how much landowner support is required for the system to be able to operate.

6.20 In Italy, where restrictions on urban spread have proved difficult to enforce, there is increased environmental awareness and new initiatives are being taken. The new plan for Rome (2003) does not consider the Green Belt as such, however it connects green areas in a rather extensive 'ecological network'. This is a design idea as well as a functional one, that connects the green wedges of national and regional parks (stretching from the outer ring towards the city centre) with other layers of the environmental systems: rural areas, the river, sport and recreational facilities, and open areas. The Dutch have championed the environment for over a generation and in the last decade there has been an active programme of land acquisition by government agencies to implement the idea of a national ecological network. However, land is a scarce commodity in the Netherlands, and van der Valk (2002) argues that this policy has doubled the price of agricultural land and led to land speculation in some central parts of the country.

6.21 The conclusion drawn from this part of the research is that for positive management of the protected land at the urban fringe there needs to be institutional awareness and co-operation. This may be possible if there are few owners and extensive land uses, as was the case with Switzerland's forests or traditions of public access (as is the case in parts of Scandinavia). Forms of betterment and recycling of development value may be able to unlock land and finance for positive management, but in situations of land scarcity inflation of land prices may occur.

URBAN FORM

6.22 There is an extensive debate about urban form and its relationship to sustainable development. This section of the research does not attempt to review that literature, but rather explores two key approaches that are followed in other countries. These are 'smart growth' and 'corridor development'.

Smart Growth

6.23 'Smart growth' became a buzzword in the US in the 1990s, though Hall (2002, 206) maintains that its practical effects have been minimal, a point confirmed by Knapp (2004). It is intimately associated with the 'New urbanism' movement, which advocated higher densities and mixed uses as an antidote to the monotony of America's suburbia. These approaches have critics as well as aficionados. When looking at them from a Scottish perspective it is important to remember just how different the development context has been in the USA (or in other countries with very low-density suburbs where the ideas have also enjoyed a vogue, e.g. South Africa and Australia). For example, research into a 'sprawl index' (Knapp, 2004), expressing the relationship between urban densities and obesity levels, seems a particularly American way to test land use policy.

6.24 Table 6.1 is in effect a manifesto for 'Smart Growth'.

Table 6.1: Smart Growth and Sprawl

Source: Litman (2003)

6.25 As Table 6.1 shows the 'Smart Growth' agenda encompasses a concern to contain the levels of urban spread that are the norm in North America, but also carries other concerns about design and planning that would be seen as commonplace in Scotland. Even further is the contrast with Finland where Douglas Gordon says, 'Higher densities in the large cities are an effective policy to contain dispersal. In as much as the majority of new development is housing, and most of that social housing is funded by the State, then not only are price and quality controls adhered to rigidly, but also funding will depend upon whether an area is growing or is static. It can be said that it is 'atypical' for towns and cities to allow dispersal, particularly as winter lasts for 5 months, and district central heating has to be controlled within a relatively narrow urban framework. Hence, nature also forces recognition for the need to have higher density networks and compact urban cities and towns.'

6.26 The rigours are less in Italy. Cremaschi and Palazzo observe that, 'The Italian debate has produced quite innovative concepts such as those captured by the image of the 'dispersed city' or, on the contrary, of the 'urban countryside'. In different parts of the country, the highly industrialised North East (the low-density conurbation between Padua and Venice, for instance) or some less developed southern regions (as an example, the coastal developments of Sicily and Calabria), the pattern of urbanisation is less one of concentration around a primary city, and rather a quilt of urbanised spots and pocket country areas. In such regions no room is left for Green Belt policy, while a tentative reflection is taking place regarding the multiple balance between open and built up areas.' Anyone who has visited these regions will be able to recall this 'urban countryside' landscape.

6.27 Again the Dutch are interesting because containment there has been such a feature of their planning and social life, but also because there are signs of very significant change. Mommaas (2000) argues that whereas housing used to be 'the most important vector in physical planning, now it's leisure', and those leisure facilities are increasingly to be found on the edge of the city - IKEA, the Claus' Party Centre in Hoofddorp, the Alexandrium shopping mall (with more than half the shopping floorspace in the city centre of Rotterdam), Showbizz City in Aalsmeer, any number of multiplex cinemas. He suggests that a global leisure time economy is already engulfing Europe, where increased pressure on time is making time-distance to leisure facilities a key driver of land development. If the Dutch are being forced to re-think urban containment, then there is a need for a rethink in Scotland too.

Corridor development

6.28 If it is going to be increasingly difficult to maintain the levels of urban containment of previous generations, then we need to look to models of urban form that seem to be able to handle growth in an efficient and sustainable way. Many of the countries in our survey use green wedges and development corridors as the basis of a strategic planning approach to combining urban growth with protection of natural environmental networks. In some cases the strategy may have been driven by basic topography. For example the classic glaciated valleys, lakes and precipitous slopes of Switzerland almost force development to follow corridors along the flat valley floors. However, in flat Denmark the classic Copenhagen 'finger plan' from the 1940s still steers development to the transport corridors between the green wedges. Since 1989 the aim has been to concentrate development around the rail stations in the Copenhagen region. As Box 5 shows, the Swedes do it that way too.

Box 6.5: Strategic Planning and Sustainable Urban Form: Stockholm

6.29 Growth corridors have also proved effective ways of managing growth around the big Australian cities, though there the density has been lower than in Scandinavia and there has been more reliance on car-based commuting. Gordon Edgar, a senior planner in Victoria's Department of Sustainability and Environment, describes the Melbourne situation in Box 6.6.

Box 6.6: Planning Melbourne 2030

6.30 In summary, there is a strong case for a development corridor approach linked to long-term planning of the land supply for housing development in particular. However, this needs to be integrated at a strategic level with the planning of public transport, density and green wedges.

CONCLUSIONS

6.31 While many countries seek to protect undeveloped land from urban spread a formal Green Belt is the exception rather than the rule, and where it has been applied there have been criticisms similar to those voiced about Green Belts in the UK. The typical regime is a zoning system that is more localised in its operation and more spatially prescriptive than UK discretionary development control.

6.32 The most effective integration of environmental aims and recreational use of edge of city open space appears to be in systems where there is either public land ownership or interventions to recycle development value, or where other sectors, notably forestry, recognise that their resource adjacent to urban areas should be managed on a multi-functional basis.

6.33 Economic, social and cultural changes are putting increasing development pressure on accessible sites adjacent to urban areas. Conflicts over conversion of edge of city land mean that planners may need to use mediation to get consensus.

6.34 Development corridors offer robust long-term strategies and a flexible means of managing urban growth, while still being able to deliver aims of brownfield regeneration, public-transport links to development and environmental protection through green wedges.

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