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REVIEW OF GREEN BELT POLICY IN SCOTLAND
CHAPTER EIGHT CONCLUSIONS AND RECOMMENDATIONS
CONCLUSIONS
General Context
8.1 Green Belt policy in Scotland is overdue for review, since much has changed in the two decades since the last official policy guidance. Key challenges include economic and spatial restructuring, growth pressures, the emphases on environmental sustainability and social justice, and maintaining urban as well as rural vitality. The functions of Green Belts have manifestly changed, as have generally-accepted notions of desirable urban form.
8.2 Green Belts have been modified in some areas, removed in one important case, but newly created and extended in others. They clearly represent a concept that is perceived as important by the public and found valuable by planners in their efforts to shape and manage urban growth. Yet there are clearly differences of understanding of their role by different groups and in different areas. These differences and uncertainties are compounded by considerable variation in how Green Belts are implemented in practice.
8.3 Green Belts are not an end in themselves, but should be seen as a tool of strategic long-term settlement planning. Planning authorities are not always using them in this way.
8.4 Green Belts are being introduced or maintained particularly in areas experiencing growth pressures and perceiving a need for proactive 'growth management'. The Green Belt was removed in Scotland's lowest demand city-region, while in some other cases we find that Green Belt restraint appears to be applied less rigorously where growth is lower and economic development more of a priority. There is widening recognition that differing contexts may require differing emphases in policy, that this may mean that Green Belts are more relevant in some contexts than others, and that their physical shape and control regimes may also vary.
8.5 The international perspectives confirm that a range of economic, social and cultural changes are putting increasing development pressure on accessible sites adjacent to urban areas. In this way, a policy regime which sufficed 20 years ago may be strained under today's pressures. The debate between 'sprawl' and 'smart urban growth' is pretty universal, although the terminology may vary.
Functions of Green Belts
8.6 The three functions of Green Belts defined in Circular 24/85 - prevention of coalescence, provision of land for recreation, landscape setting for towns - remain important in the rationale for most existing Green Belts, although these are not unproblematic. The first reflects notions of urban identity but may conflict with emerging ideas on sustainable urban form and with meeting development needs, while the second cannot be met in full by the essentially negative instrument of Green Belt.
8.7 Newer functions have come to play a stronger part, particularly supporting urban regeneration and the sustainable compact city. The regeneration aim has been achieved in many cases and whether this needs so much emphasis in the future is questioned in some quarters. Protecting the best landscapes and green environments close to towns is a de facto role of increasing importance, which should probably be recognised more explicitly. In some instances Green Belts also play a de facto role as a strategic land reserve, a function that in our view sits uncomfortably with the general concept. The potential role of Green Belts within the emerging emphasis on proactive spatial planning is widely recognised as important.
8.8 The international review reported in Chapter 6 shows an almost surprising degree of similarity of the concerns motivating equivalent or related policies in other countries: most of the same objectives are mentioned. However, it is unusual for the policy solution to equate to 'Green Belt' as we would understand it; this is a quintessentially, though not exclusively, British device.
Urban Form
8.9 Green Belts have encouraged urban regeneration, including brownfield development and higher density development within existing built-up areas. However, there are concerns about the dangers of 'town cramming', both in terms of loss of valuable urban greenspace and in terms of not meeting the needs and demands of some households, particularly families, for moderate density 'suburban' types of housing.
8.10 'Leapfrogging' development is a particular problem associated with Green Belts, as is recognised in many Plans; although the response to this varies, in some cases this is motivating a reshaping of Green Belts. Partly for this reason there is growing diversity in the shape of Belts, some taking more the form of sectors or buffers while others are developing into more complex networks. While there are some arguments for maintaining a continuous ring of green land, and for this being of more than minimal depth, these are not necessarily overwhelming arguments and neither would they necessarily apply in all cases. Just as the emphasis on different purposes may vary with context, so may the spatial form.
8.11 The international perspectives suggest that 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 and environmental protection through green wedges. Some Scottish local authorities are now adopting this model in a proactive fashion.
Planning and Control Regime
8.12 Green Belts are a strategic issue addressed in Structure Plans, but there is considerable variation in the way they are handled in Local Plans. It is at this level that boundaries are set and revised, but the transparency and criteria used in this process vary and give rise to some concern. There is a tension between the perceived 'long term' nature of Green Belts and the considerable flexibility exhibited in terms of releases in some areas. It is clear that Green Belts interact with the way in which land is or is not allocated for future major development requirements, and this is handled differently in different areas.
8.13 The control regime in Green Belts is generally tighter than in other rural or urban areas, and this creates some problems around 'allowable uses' in relation to rural economic diversification and recreational uses. There are concerns about the inconsistency of these regimes, between areas, between housing and economic developments, and between smaller and large-scale developments.
8.14 Green Belts may appear at times to duplicate other overlapping protective designations, but this may be perfectly logical and appropriate. Some players perceive Green Belt as a stronger defence of open land around towns than some other designations, notwithstanding its uneven implementation record.
8.15 Green Belts are widely seen as a long term, even 'permanent', form of protection from development, but the reality in Scotland is that there has been much re-designation and development of former Green Belt land, through both planned and responsive releases. Public opinion tends to expect permanence, and arguments about avoiding speculation and 'hope value' and about wildlife protection also point in this direction. This has to be balanced by planners against urban, economic and societal change, not all of which is predictable.
8.16 Formal Green Belts are rare in other countries, but many places achieve some of the same purposes by a combination of formal delineation of urban, rural-agricultural, forest or parkland areas backed by a more mechanistic zoning approach to planning.
8.17 Conversion of land from (semi-)rural to urban use can often create conflict, as is seen in other countries and not just the UK. Part of the role of planning is to try to find an acceptable consensus, and mediation techniques are increasingly seen as having a role here.
Land Management
8.18 The need to enhance recreational access and environmental conditions in Green Belts is widely recognised, but there is often a gap between aspirations and available resources. Planning gain can play some part in bridging this gap but in some cases this can compromise other core objectives of the regime, unless set within a clear framework in terms of landscape and urban structure.
8.19 In some other countries the significant scale and location of public land ownership plays a strong role, not just in facilitating the implementation of urban form plans but also in helping to resource environmental and recreational enhancements to green areas. Corridor/wedge development/protection plans offer more opportunities for the recycling of larger-scale development gains for these and other public purposes.
RECOMMENDATIONS
Functions
Traditional functions
8.20 Government should provide a re-statement of the functions of Green Belts. This should include two of the three objectives identified in 1985 - provide land for recreation, but excluding or restricting reference to institutional uses; and maintain the landscape setting for towns/cities.
8.21 The first objective, prevention of coalescence of settlements, should be qualified, to emphasise that this is only where appropriate to local circumstances and only after having regard to an assessment of the optimal urban form for growth in the region.
8.22 We see no case for reinstating a reference to agricultural land requirements.
More recent functions
8.23 Protection of the 'best' greenspaces, in landscape and ecological terms, which are close to urban areas, should be a priority that is reflected in the functions of Green Belts.
8.24 The use of a Green Belt to encourage urban regeneration should be included as a potential function, in the context of local strategies, but with the suggestion that this is most appropriate in lower-demand regions.
8.25 Green Belts should not be used as a strategic land reserve; strategic allocation of land for future development needs should be long term and adequate.
Urban Form
8.26 Moving towards a more sustainable form of urban development should be a prime concern of strategic land use planning. However, the Executive should not prescribe an encircling Green Belt as an 'off the shelf' means of achieving this. Rather, the Executive should encourage authorities to use sound methodologies for sustainability appraisal, involving a rigorous analysis of options within the planning process. Green Belts or other protective designations emerging from this type of robust analysis led by the planning authorities should be supported by the Executive and by Reporters.
8.27 The Executive should seek to raise awareness, at all levels and amongst all stakeholders in the Scottish planning system, of international experience of the use of development corridors and nodes and green wedges, and the benefits of greenspace networks as spatial planning concepts. Such concepts could be reflected at the national level in the National Planning Framework, or through Planning Advice Notes.
Planning and Control Regime
8.28 The basic concept of a protective designation for greenspace adjacent to towns/cities should remain a part of the planning system in Scotland. However, serious consideration should be given to the institution of two tiers of 'Green Belt', as a way of recognising much of the diversity of function identified in this study.
8.29 Under this approach, the first tier would comprise green areas adjacent to towns and cities which are deemed of national or regional significance. We suggest these might be called 'Green Heritage Areas'. The criteria for identification should be the quality of the landscape / cultural landscape, its significance to greenspace and ecological networks, its exceptional recreational significance, or its contribution to the visual quality of key gateways to or the landscape settings of towns/cities. These would carry particular weight where the value of such qualities to the city / region are deemed to be of national economic significance. This 'national' tier should be seen as effectively permanent (or very long term), and only subject to change after transparent and rigorous review involving very full consultation.
8.30 Consideration was given to how to implement this 'national' element of Green Belt in Chapter 7 (para 7.29). There are various options, which might involved national guidance and/or a Statutory Instrument. The essential idea is that , although local authorities could initiate and influence the setting up of such tier 1 areas, central government would be involved in approving and registering them and, subsequently, in any decision in relation to changes in such areas or development (beyond normal permitted development) within them. Such developments would be subject to formal notification and call-in arrangements.
8.31 The second tier, which might be called 'Urban Fringe Greenspace', would be of local or regional significance. This tier would comprise other land currently in non-urban use within the urban region, or which the planning authority aims to restore to non-urban uses. Such Greenspaces would be identified in development plans as 'no go areas' for significant development within the life of those development plans. Urban Fringe Greenspaces would be land which, taken in conjunction with the Green Heritage Areas, existing built up areas and planned zones for development, would function as strategic buffers or gaps within the emerging urban structure, helping to channel development to other preferred directions. There should not be a prior presumption that the new Urban Fringe Greenspaces will necessarily coincide with existing Green Belt boundaries.
8.32 The responsibility for identifying and justifying second tier areas (Urban Fringe Greenspaces) would rest with the relevant local planning authority(/ies). The basis for their designation should be primarily their contribution to the spatial planning strategy and sustainable urban form of the urban area, but this may be supported by reference also to landscape quality, recreational access, place identity, ecological significance and networks. Their planning status and control regime should be seen as being broadly equivalent to that of the current Green Belts in Scotland. Once approved as part of a development plan the these Greenspaces should be supported at appeals in the normal way within the 'plan-led system' while the development plan remains in force.
8.33 There should be experiments in using independent mediators to assist the process of reaching agreement amongst a range of stakeholders about the areas to be designated as Green Heritage Areas or Urban Fringe Greenspace (or whatever title is used).
8.34 Whether in the context of a single or multi-tier Green Belt, "washing over" should be discontinued in favour of consistent use of insets.
8.35 Similarly, development plans should identify or safeguard sites or zones for future development sufficient to accommodate anticipated requirements for new urban uses and infrastructure, with a margin for uncertainty. Green Belts (or whatever they are called) should not be used as a strategic land reserve.
8.36.Subject to the outcome of other research and general approaches to 'model policies', there may be scope for such model policies on development control in Green Belt or equivalent designated areas to be produced by the Executive in consultation with stakeholders. This would clarify and tighten the identification of inappropriate uses in a) the Green Heritage Areas and b) the Urban Fringe Greenspaces. One aim is to increase certainty; therefore, there should be a strong general presumption against exceptions.
Land Management
8.37 Designation of Green Belt or equivalent areas should carry with it a duty to prepare a Greenspace Network Plan, covering and integrating all these protected areas, and their links to other open space corridors. The plans should focus on realising the aims underpinning the designation of these areas, and would encompass, inter alia, the core network of footpaths and access ways for the area, and a range of positive management measures to secure and enhance the quality of the network. The process of preparing and adopting these plans should engage a wide range of stakeholders, and expert, neutral facilitators should be used to build as wide a consensus and sense of ownership as possible.
8.38 There should be attempts to form voluntary bodies or trusts linking a number of stakeholders behind the preparation and implementation of a Greenspace Network Plan, in the context of policies covering planning, environment and social justice. Such bodies should have charitable status and be able to acquire and hold land and property.
8.39 There should be presumption, reinforced through Local Plans and planning briefs, that all new major developments adjacent to Green Belt or equivalent areas would be expected to make a significant contribution towards the enhancement of the environment and access network and facilities of these areas. These contributions should be placed in an earmarked fund for spending on these purposes, and expended within a defined period (e.g. 3 years), through the agency of the body referred to in 8.36 above or directly by the Local Authority.
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