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REVIEW OF GREEN BELT POLICY IN SCOTLAND
APPENDIX 2
ANALYSIS OF OBJECTIONS TO RURAL WEST EDINBURGH LOCAL PLAN
Introduction
A2.1 The Finalised Rural West Edinburgh Local Plan was approved by the City of Edinburgh Council on 26 June 2003, replacing the 1999 Finalised Plan.
A2.2 The information provided by the City of Edinburgh Council shows that 116 parties submitted 489 representations and formal objections to the plan (henceforth referred to generally as objections). 6 Of these, 135 objections (submitted by 62 objectors) were related in some way to the Green Belt.
A2.3 Objectors submitting the highest numbers of Green Belt-related objections included Friends of the Edinburgh Green Belt and Currie Community Council (10 and 9 Green Belt-related objections respectively), who were concerned about erosion of the Green Belt, and the Earl of Roseberry (9), mostly objecting to Green Belt designations (9 Green Belt-related objections). A second cluster in terms of the number of Green Belt-related objections, with 4 to 5 such objections each, included two landowners (Danzan Trust and Mr A Allison and family), a housebuilder (Cala Homes (East) Ltd), and amenity group (Residents Against Greenbelt Encroachment) and an individual. Landowners and housebuilder were generally objecting to Green Belt designations, and the amenity and housebuilder for such designations.
General Issues
A2.4 Fourteen objections from eleven objectors were related to general and strategic issues regarding Green Belts.
A2.5 Three objectors (all of whom appear to be developers: Homes for Scotland, Taylor Woodrow Developments Ltd & Miller Homes and ATIS REAL Weatheralls Ltd) recommended that the Green Belt be reviewed, to see if it continues to meet its purpose and to identify sites where development can be steered. Additionally, a parallel review of AGLV designations was also suggested. These general recommendations tended to be put forward in order to support the case for specific development proposals, and were against the statement that there is no need to release Green Belt land before 2020. There was a suggestion that Green Belt policy should be applied flexibly, allowing development when there is a strong economic case. A case was also made by a landowner that sites that have had previous uses should be identified as 'brownfield', even if within the Green Belt, and that redevelopment should be allowed on these (this suggestion was made specifically in relation to a former piggery).
A2.6 Opposed to these general pro-development suggestions were the views of objectors such as Friends of the Edinburgh Green Belt and Currie Community Council, which expressed their concern that the Green Belt and the countryside could be used as land banks for future development, thus not supporting sustainable development. Currie Community Council stated that although there is a need to achieve more balanced communities, this should not be achieved by encroaching on the Green Belt.
A2.7 Two objectors raised issues concerning the relative status of Green Belts and countryside. Daltons & Kinleith Industrial Estates Ltd objected that they were both being given the same status in the local plan, and that therefore development control measures in the countryside were 'draconian'. Another objector also argued against same status, but on the grounds that this reduced the status of the Green Belt.
A2.8 Finally, Balerno Community Council raised the issue of according with English policy in relation to restriction of housing in Green Belts.
Green Belt Designations
A2.9 The largest number of objections referred to Green Belt designations. Twenty-nine objectors lodged 53 objections that can be included in this category, nearly all opposing Green Belt designations. Only two (Friends of the Edinburgh Green Belt and Dr Lynda Clark QC MP) supported Green Belt designations, and one landowner sought some relaxation of Policies E5 and E6 referring to development in the Green Belt and in the countryside, to support the 'economic maintenance of a rural estate'.
A2.10 Twenty-two of the objections (lodged by 14 objectors) called for some Green Belt designations to be allocated for housing. Objectors included mostly housebuilders - e.g. George Wimpey East Scotland Ltd, Cala Homes (East) Ltd, Stewart Milne Holdings, Applecross Properties Ltd, MacTaggart & Mickel - as well as some landowners. The sites range from small ones to sites that are cited as being capable of providing around 500 houses, but are mostly fairly substantial. The sites proposed for housing are mainly clustered around existing settlements such as Currie and Balerno, Ratho, Newbridge, South Queensferry and the western end of Edinburgh itself, by Maybury Road. There is also a large site proposed by the railway line between Edinburgh and South Queensferry, in the Green Belt, and another on Kirknewton airfield, which is one of the largest proposals and is not within the Green Belt, but is in a countryside policy area.
A2.11 Eighteen of the objections (lodged by 12 objectors) were arguments against Green Belt designations and/or boundaries. A cluster of these (6 objections) were linked to other objections which put forward sites for housing (see above). These were from house-builders (Applecross Properties Ltd., MacTaggart & Mickel and Cala Homes (East)) and landowners (e.g. Lord Roseberry). Other objections to Green Belt designations were used to support parallel objections proposing development in general (2 objections presented by 1 landowner), economic development (1 objection) and non-conforming use (1 objection). Two objections were from estates, arguing that options had to be left open for rural estate management.
A2.12 Green Belt designations on two sites (south of South Queensferry and north of Currie) were objected to on the grounds that they could support mixed use development. Both objections were lodged by housebuilders (AWG Residential and Miller Ventures).
A2.13 Only two objections explicitly proposed economic development on specific sites designated as Green Belt. These were located by the airport (lodged by FSH Airport (Edinburgh) Services Ltd) and at Royal Elizabeth Yard (lodged by FR Evans (Leeds) Ltd).
A2.14 One objection called for a review of the Green Belt boundary to take into account a potential road link, in relation to a specific development (Scottish Agricultural Science Agency at Gogarbank Farm).
Access And Countryside Recreation
A2.15 Seventeen objections, lodged by sixteen objectors referred to access and countryside issues. About half of these (8) came from residents who were opposed to a housing allocation in Ratho Station, outwith the Green Belt, which entailed relocating playing fields and changing facilities to land that was previously Green Belt. Two objections (from British Waterways and The Brewster Brothers) objected to restrictions on the provision of appropriate development associated with the canals. Another two objections (from Turnhouse Golf Club Ltd and Danzan Trust) referred to the restrictions on development of golf courses and driving ranges, which are uses that the local plan supports in the Green Belt. The objectors argued for opportunity to be allowed for other forms of development that they consider support golfing, including residential.
A2.16 Amenity and community groups lodged 4 comments which were generally supportive of access and countryside recreation policies. Currie Community Council and Friends of the Edinburgh Green Belt strongly supported policies related to waterways and the latter sought clarification on a specific right of way. Balerno Community Council questioned the suitability of 'war games' as a countryside activity.
Housing Allocations
A2.17 Sixteen objections were lodged by nine objectors in relation to housing allocations. All but one were against specific housing allocations in or next to Green Belt or overall policies which were perceived as not protecting the Green Belt sufficiently against housing development.
A2.18 Objections to specific sites included housing allocations in Kirkliston and Ratho Station. Though some of the representations and objections to allocations in Kirkliston and Ratho Station came from Kirkliston and Ratho Community Councils respectively, as well as from residents, surprisingly Cala Homes (East) Ltd objected to all three housing allocations in Ratho Station, and both Stewart Milne Holdings and Cala Homes (East) Ltd objected to the large house allocation north of Kirkliston (for around 650 houses acc. to Finalised Plan). The consultation period is therefore used by housebuilders not only by defending their proposals but also by attacking rival proposals. One objection to a site allocated for housing in Ratho Station called for this to be enlarged.
A2.19 Friends of the Edinburgh Green Belt and Currie Community Council defended the principle that greenfield sites should not be used for housing, and expressed concern over how 'restraint' is going to be exercised in the Green Belt in relation to housing. In addition, Currie Community Council was concerned with coalescence with Juniper Green through the development of housing on a site between the two settlements, though this site is not in the Green Belt and there are existing buildings on it.
Countryside Policy
A2.20 Eleven objections were lodged by nine objectors regarding countryside policies. Two objections, lodged by Friends of the Edinburgh Greenbelt and Currie Community Council, defended that areas of the countryside not covered by Green Belt policy should have an 'environmental importance equivalent to the Green Belt'.
A2.21 All other objections were in support of developments on sites that had been designated as countryside. Four objectors (Glenmorrison Group, Defence Estates (Scotland), Cliftonhall School and a private individual) supported the allocation of housing sites on land designated as countryside. Two of these were fairly large sites (one estimated for 200 houses) and on the border with West Lothian; these both argued that their development for residential use would meet the objectives set out in West Lothian's plans.
A2.22 Two objectors (Alex Brewster & Sons and Tarmac Northern Ltd) supported the designation of countryside land for economic development by the M8 at Newbridge.
Expansion Of Green Belt
A2.23 Ten objections were lodged by three objectors supporting further Green Belt designations beyond those contemplated in the local plan. Five of the objections were lodged by two individuals, and the other five by Residents Against Greenbelt Encroachment. All objections either sought extensions of the Green Belt or objected to deletions from the Green Belt. Background reasoning for inclusion in the Green Belt was not generally provided.
Summary
A2.24 The objections to the RWELP show a considerable amount of pressure on the Green Belt, mostly from housebuilders, as well as landowners. This pressure is concentrated on the edges of existing settlements such as Currie and Balerno, Ratho, Newbridge, South Queensferry and Drumbrae (Edinburgh). There is also pressure for housing on sites that are in land designated as countryside, particularly on the border with West Lothian. Together with this pressure there are signs that competition between housebuilders is played through in the consultation exercise, with developers arguing against sites that might compete with their own.
A2.25 There is also some evidence of pressure for economic development, both on Green Belt land, particularly around the airport, and on land designated as countryside, by Newbridge. Although fewer sites were put forward for development in objections to this plan than had been the case for the previous local plan, Edinburgh City Council planners felt that this was due to the fact that the current Structure plan does not contemplate these developments and is too recent for objectors to argue against as outdated. However, they indicated that this type of pressure tends not to disappear in the long term. Other pro-development concerns are those of recreation providers in the Green Belt, linked to golf, canals, etc., who consider local plan policies to be too restrictive. Rural estates have displayed similar concerns.
A2.26 Amenity groups, community councils and individual residents display strong opposition to any development that they perceive as 'eroding' the Green Belt. Their objections range from general policy principles to specific sites - in the latter case either objecting to specific development allocations or calling for extensions to the green belt.
A2.27 In terms of general issues, amenity groups and community councils are concerned about the use of the Green Belt and the countryside as a land bank, whilst several developers question whether the Green Belt is serving its purpose, and call for a strategic review of its functions and the identification of sites where development can be steered.
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