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General comments by respondents
16. As already noted, publication of a new Scottish Planning Policy on green belts is warmly welcomed. Respondents overwhelmingly express support for the document, albeit with some big reservations in many cases. Only a handful of responses are wholly negative about the SPP.
17. There is general agreement across the responses that green belt policy needs to be restated and that the Executive is right to do this as part of the new Scottish Planning Policy series rather than a revision of the existing circular. Several responses affirm that Circular 24/1985 is outdated, needs revision, and that a new SPP is the best way forward. The Royal Town Planning Institute in Scotland sums up these sentiments: "We welcome a long overdue update of this twenty year old policy and its transformation from the format of a circular to that of the SPP series".
18. A small number of respondents welcome the new SPP almost unconditionally, remarking on how it would make a useful contribution to planning policy, or encourage appropriate expansion of towns and cities. One respondent says only that: "The content of draft document is very good and needs little alteration if any. Most responses, however, express their support for the draft SPP in more limited ways: "We broadly support the proposals", "The draft SPP21 is to be generally welcomed", "We agree with the general thrust of the revised policy", "In the main we are supportive of the draft SPP, but there are a number of issues" are typical responses. Similarly, the standard form responses supported key elements of the draft SPP whilst marking up disagreements and suggestions about particular elements of the policy.
19. Green belts themselves clearly continue to enjoy more consistent support. The responses suggest that green belts are an aspect of planning most clearly recognised by organisations and members of the public, even though much debate surrounds them. There is evidence here of a general consensus that green belts are a valuable and important planning tool, though some members of the public put them much higher than that. Stewart Milne Holdings in supporting the content of the draft, especially its recognition of the long term function of green belt designation, says the housebuilding industry would greatly benefit from strong guidance provided it is based on justifiable landscape and planning grounds, and which categorically defines where development can and cannot take place in the longer term.
20. Many respondents are pleased to see new emphasis on green belts and support the draft SPP's aims to strengthen and enhance their role. A number of respondents question whether green belts are appropriate or relevant to their area, but only a tiny minority actually question the fundamental principle of green belts or express an entirely negative view about them.
21. The new concise style of SPPs is welcomed, but opinions differ on the adequacy of the document. Some consider it to be well written with clearly expressed policies. Others find it lacking in creative or innovative policy changes. Others find a lack of precision on important points of detail. Since many see green belts as conferring clarity and certainty, it is natural for several responses to highlight the need for policies to be clear, comprehensive, unequivocal and unambiguous. This is noted by many as important operationally, since green belt policies are going to be heavily relied on for guidance in the examination of development plans and the determination of planning applications. More explicit guidance, they suggest, would be helpful to planning authorities, developers and communities alike. In this respect one respondent sees the draft as too much of a discussion paper, and is looking for greater firmness in the published version.
22. Many respondents seek clarification on specific points in the draft, or express a deeper dissatisfaction with particular phrases or aspects of the policies as worded. These are highlighted later in this report. Some respondents also feel the SPP would benefit from an accompanying planning advice note or circular. Despite these remarks it is worth emphasising again that almost all of the responses are positive in tone. Most of the comments and criticisms are presented in a helpful and constructive way. Details of drafting suggestions accompany many of the responses, including the submission from the Scottish Green Belt Alliance.
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