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Comments on each part of the draft policy
The summary
23. Almost all of the individual and community councils, and around half of the heritage & environment group respondents, support the strong presumption against development in the green belt - mentioned first in the summary section of the draft SPP. The vast majority of these responses also refer to the need to avoid urban sprawl which also appears in this section. One respondent notes that " urban sprawl is mentioned in the summary but not elsewhere in the document". All the standard-form responses support both the strong presumption against new development in the green belt and the need to avoid urban sprawl.
24. The responses make little direct criticism of the summary and support was offered to several other statements in the section. But a number of responses do request that the summary makes reference to the countryside, and one draws attention to mixed signals about growth in the first sentence.
The introduction- paragraph 1
25. Though small in number, some responses suggest there should be clearer cross referencing to other policy papers, with one individual arguing that it should not be assumed that everybody has an instant grasp of all Scottish Planning Policies and National Planning Policy Guidelines. Several respondents refer to SPP3 (Planning for Housing). NPPG11 (Sport, Physical Recreation & Open Space) and NPPG14 (Natural Heritage) are also mentioned, and others make individual references to PAN 65 (Planning & Open Space), PAN72 (Housing in the Countryside) and PAN 73 (Rural Diversification).
Managing the growth of towns and cities
Managing the growth of towns and cities: spread of comments from respondents
The changing context- paragraphs 2-4
26. Many of the comments submitted have some relevance to this section of the draft SPP and about 20 of them made comments that can be related to it directly. More than half of these come from environment and heritage groups or planning and related professionals, with the rest coming from across the other respondent categories.
27. The comments on the changing context generally focus on two points - the Scottish Ministers' priority to regenerate communities and re-use vacant urban land, and the recognition of different circumstances across Scotland. There is little disagreement that population and household patterns are changing or that that high quality environments and accessible locations are increasingly important.
28. Several of the responses support prioritising regeneration and the re-use of vacant urban land but, as one response notes, this is something that everyone can agree on. However, a number of the responses say the relation between green belts and urban regeneration is so fundamental that it deserves to be elaborated as a context to the SPP. A significant number of responses point out that urban regeneration is particularly pertinent in the west of Scotland.
29. There is some criticism that the draft SPP fails to properly recognise the different circumstances across the country, with one response seeing an SPP bias towards the east of Scotland. There are some suggestions that the differences between pressurised expansion areas (such as Edinburgh and Aberdeen) and less pressurised areas with availability of brownfield land (mostly in the west) could have been spelled out more clearly.
30. A number of respondents also think it would be useful to elaborate on why changes are being made to the existing green belt policy. Some think there could be greater discussion of policy changes since the 1985 circular (with a few even going back to the inception of green belts at the end of the second world war). In particular, a number of respondents want to see more context and explanation of why preventing coalescence is being dropped as a key green belt objective. Others seek a more rural dimension for green belt policy. These two points are expanded on in observations below on the key objectives.
31. There are also calls to more clearly spell out the links between green belt and the wider-policy context, particularly relating to issues like sustainable development, climate change, reducing the need to travel, integrated transport and green space.
SPP objectives- paragraphs 5-6
32. The responses to the consultation confirm there are many different opinions on what the objectives of green belts should be. 90% of the responses to the consultation (including all the standard-form responses) comment on the key objectives of green belts. In terms of numbers, more responses relate to this section than any other part of the document. Planning authorities, developers and planning professionals tend to be more welcoming to the objectives as stated, but support, criticism and points of discussion come from all quarters, as do proposals for extra objectives.
The vision
33. The vision expressed in paragraph 5 of the draft SPP has proved a good deal less controversial than the objectives that follow it. Many of the responses express their support for the vision. The aim to 'strengthen and enhance the role of green belts and encourage stability to increase their effectiveness' is widely supported and there is also general agreement that green belts can deliver 'major benefits to Scotland in improving quality of life for local people'. Only a couple of responses disagree with these points.
34. Nevertheless, a number of the responses highlight what they see as shortcomings in the opening paragraph. Some think that it should be clearer about the possible expansion of housing into existing green belt areas, whilst others want specific mention of the presumption against new development in the green belt. In a similar vein, some seek further references on the need to prevent urban sprawl and protect the countryside. These points are elaborated on in the observations below.
The objectives
35. Although there is plenty of support for the key objectives outlined in paragraph 6 only a handful of respondents (mainly from the planning profession and local authorities) seem content to let them remain in their current state. There is a common view that the list of objectives is too limited as it stands. Several of the respondents see the strengths of green belts in serving many objectives and want a more comprehensive list to be included. One respondent argues that the omission of objectives might be interpreted as a rejection of them. Some respondents also seek greater precision on the three objectives included in the draft.
Objective 1: To direct planned growth to the most appropriate locations and support regeneration
36. A number of the responses stress the link between the redevelopment of brownfield sites and the achievement of regeneration goals, and so recommend that the objective be reworded to refer specifically to either brownfield sites or development of vacant land. This view is conveyed in alternative wording from Currie Community Council " to encourage regeneration and development on brownfield sites within built up areas".
37. Three of the responses argue that it is misleading for the objective to imply that green belts could positively direct development. They take the view that the benefits actually come about in a more indirect way as development is diverted away from the green belt. One respondent argues that this objective should be placed further down the list below 2 and 3.
Objective 2: To protect and enhance character, landscape setting and identity of towns and cities
38. This objective is very widely supported and only a few comments are directed specifically at its wording. Nevertheless, this objective is closely linked to issues of coalescence and protection of the countryside, on which there are numerous comments. Among the limited number of suggestions for wording it was proposed that references to countryside protection and separate identity should be added. One respondent suggests that this objective sets out the primary purpose of green belt and it should therefore be at the top of the list.
Objective 3: To protect and give access to open space within and around cities, as part of the wider structure of green space
39. It is clear that many people regard the green belt as a valuable asset in terms of access to open space. Responses describe green belts as " green lungs"; one sees green space as beyond price: a legacy for future generations that is "irreplaceable".
40. Though relatively few comments are directed at the wording of the objective, a number of respondents are unclear about the meaning of "wider structure of green space". SportScotland also feels that the phrase "access to open space" does not adequately cover the range of recreational uses acceptable in the green belt, and recommends that the objective specifically refer to recreational experiences. Others suggest that specific reference should be made to amenity and tourism.
41. A number of developers believe that the protection of open space should not be an overriding factor in the allocation of green belt land and argue that other planning mechanisms are better than the green belt in achieving aims for open space and access. A few argue that green belts should not be extended to land within towns.
Urban sprawl, coalescence & identity
42. This, for many, is the draft SPP's inexplicably missing objective. The avoidance of urban sprawl and the need to prevent coalescence are regarded as key green belt objectives by many respondents. There is a common view that the prevention of coalescence is fundamental in protecting the identity of settlements. The absence of any reference to coalescence is therefore one of the most controversial aspects of the draft SPP. Prevention of coalescence has been a central pillar of green belt policy since its inception (a fact remarked on by several of the respondents), and for this reason it is perhaps unsurprising that its absence from the draft SPP has been picked up by so many people.
43. The issues of urban sprawl and coalescence are raised in the standard-form responses. These state that… "Communities are important. Urban sprawl should not be allowed to 'swallow up' settlements. Green Belts should be used to stop that kind of coalescence." Individuals and community councils make up the majority of those who express concern about urban sprawl, coalescence, and in some cases ribbon development, but strong views are expressed across the various respondent groups with the issue raised by developers, planning authorities and environmental bodies alike. " SPP21 lacks provisions for preventing coalescence of settlements", "the prevention of urban sprawl and coalescence remains a legitimate aim of Green Belt designation", "the distinct identities of towns and villages are highly valued" are typical responses. As noted already, one respondent draws attention to the fact that though the need to avoid urban sprawl is mentioned in the summary section, there is no reference to it in the body of the document.
44. A small number of developers and planning professionals support the removal of 'coalescence of settlements' as a reason for green belt designation, highlighting that sustainable patterns of development, for example along transport corridors, can justify coalescence in some cases.
Protection of the countryside
45. The standard-form responses state that… "Green belts are important for countryside reasons, not just for urban reasons. That should be stated in SPP21 and para 6 on objectives should be extended." This view is also expressed in some of the non-standard responses, mostly among the heritage and environment groups that support the stance of the Scottish Green Belts Alliance.
46. Several respondents think that the SPP could do more to view green belts from a rural perspective, and that this would better reflect the relationship of towns and cities to their surrounding areas. A few of the respondents also view the green belt as an important agricultural asset which allows fresh produce to be generated close to areas of demand. Some respondents think that the draft SPP has an urban bias and one suggests it has been "prepared by urban planners viewing the green belt as development land".
47. The main thrust of most of these responses is that protecting the countryside from inappropriate development is a key aim of the green belt and that there should be a statement to this effect in the SPP.
Other objectives
48. As already stated, many respondents want the SPP to contain a more comprehensive list of objectives. Objectives relating to urban sprawl, coalescence and countryside protection are by far the most common ones suggested, but others are highlighted too. The protection of cultural heritage is mentioned by a significant number of respondents, and a similar number also refer to the protection of natural heritage, wildlife and bio-diversity. A smaller number refer to the management of urban fringe areas. Architecture and Design Scotland for example argues for a co-ordinated response to a number of related issues. It wants to see opportunities taken to improve design quality in all edge of settlement developments bordering green belts as well as in associated development in rural areas. The tourism value of the green belt is also mentioned.
Related mechanisms- paragraph 7
49. Several of the responses welcome the recognition that green belts are only one of a range of mechanisms that help shape our towns and cities. There is a general view that green belts need to be complemented by other policies and some local authorities note how green belt aims have been delivered in their area by the use of other policy tools.
50. However, there is a view from some respondents that green belts are a relatively straightforward and effective tool, particularly in protecting an area from inappropriate development, and that some of the alternatives might not always be able to achieve the same results.
51. A number of respondents stress the importance of clear cross referencing to other policy papers (a point already made in relation to the introduction and changing context paragraphs), and some identify related mechanisms to add to those in the draft SPP. Countryside management and rural development policies top this list, but there are also references to the conservation of the historic environment, and on a more strategic level to the National Planning Framework. One view, noting that the engine of pressure on green belts is household formation, asks whether there might be merit in offering tax and council tax incentives to inhabit dwellings more intensively and discourage under-occupancy.
The role and function of green belts
The role & function of green belts: spread of comments from respondents
What is a green belt?- paragraphs 8-11
Definition
52. The draft SPP defines green belt as: "an area of land designated for the purposes of managing the shape of a town or city in the long term" and continues: "It is the outcome of a long-term settlement strategy to achieve the three objectives listed in paragraph 6."
53. Many responses welcome the reference to the long term function of the green belt but there is a common view, particularly amongst planning authorities and planning professionals, but also from developers and environment and heritage groups, that the definition of green belts given in the draft SPP is lacking. The responses include remarks like: "it is a very partial statement", "paragraph 8 fails to adequately define green belts", "The definition is insufficient because it does not define green belt", "The present description of Green Belt appears to be more a statement of purpose rather than a definition." Several of the responses say they find the definition of green belt confusing.
54. A significant number think the definition should be amended. One of the housebuilders suggests that "the purpose of green belt should be to protect land around settlements to define a limit to the urban area", and this sentiment finds echoes across all the respondent groups. Clearly the green belt is still widely regarded as a tool of control and restraint and several suggest that to deny or omit the acceptance of this here is more than a little misleading. The responses include some alternative definitions, most of them emphasising the protective role of the green belt, but the most common suggestion is that some reference to the strong presumption against development should be included. The responses also highlight that restrictive policies are not necessarily negative and can lead to positive outcomes in promoting regeneration and in helping to define and manage urban-rural boundaries.
55. There is almost total agreement that green belts are not the best way to protect natural heritage or safeguard land for major uses, and nearly all of the responses that express a view on this accept that other designations are more suited to these tasks. There is also a consensus that only areas of land that deliver on green belt objectives should be designated as green belt (although, as indicated already, there is plenty of debate as to what these objectives should be).
The form of the green belt
56. Over a third of those answering the question 'what is a green belt?' refer to form and shape. There is broad agreement, especially among planning authorities, that green belts should take a variety of forms and reflect local circumstances. Some advocate one form over another whether green wedges, green fingers, or buffers. South Ayrshire and Edinburgh Councils both highlight the benefits of having distinct and unconnected green belt areas (in the case of Edinburgh the Water of Leith corridor, Holyrood Park and Corstorphine Hill), and East Ayrshire Council goes further, saying green belts should only encircle communities in very exceptional circumstances. On the other hand, one respondent suggests that isolated areas of green belt are not appropriate and that green belts should only apply to land which is directly linked and forms part of the undeveloped countryside.
57. There are different views on whether 'green belt' is the right term if the policy areas can take a variety of forms, especially as the word 'belt' suggests a continuous surrounding band of land. 'Green network' or 'green zones' are alternatives suggested by the Scottish Civic Trust, but other respondents note that there should be a clear distinction between green belts and green field land, and that the term green belt is already well recognised by the public.
58. Two developers welcome the statement that green belt policy 'should be used to direct development to suitable locations, not to prevent development from happening', one noting that the policy should be flexible enough to ensure that appropriate development can take place if there are positive benefits. But some respondents from the other groups think the sentence is ambiguous, potentially undermining the clear presumption against development, and open to exploitation by the development industry. Renfrewshire Council puts forward the alternative " Green belt policy should be used not to prevent development as an end in itself, but to direct development to suitable locations". In the view of one property company, more suitable and sustainable locations could include the urban fringe or along transport corridors, in order to reduce congestion and the need to travel long distances.
Quality of life
59. As noted already, most respondents support the idea that green belts should enhance the quality of life for local people, and few query the four bullet points in paragraph 10. The reference to outdoor recreation is welcomed and the standard responses acknowledge that green belts are important for health and recreation although they stressed that nearby access for people is also important. It is worth noting that some individual respondents draw particular attention to health benefits.
60. SportScotland is concerned to clarify what exactly access is for (does it cover all recreation or extend to education) and suggests that the bullets should also mention access to urban green spaces. Scottish Natural Heritage strongly agrees with the emphasis on effective management, but seeks to clarify the term access to the countryside and question whether it is different from outdoor recreation. SNH also proposes a reference to walking and cycling and like SportScotland refers to the value of green belts for environmental education. Clydebelt requests that green tourism is mentioned specifically.
61. The Association of Scottish Community Councils has a point to make about quality of life. It says that pursuing the regeneration objective of green belt policy has led to many examples of local authorities themselves using green belt and green space land for business or industrial parks, where they provide or allow soulless, drab concrete and steel structures, and then take more land for housing on sustainability grounds to reduce the need for travel. Many such business estates are now more or less empty, says ASCC, and effectively discriminate against the aspiration to enhance the quality of life for local people.
Where should green belts be designated?- paragraph 12
62. " We think that the creation of new green belts should be encouraged" say the standard responses, but over half of the non-standard responses also address this issue with opinions neatly divided according to respondent type. Businesses and developers and planning professionals support the statements in the draft SPP; planning authorities and national agencies are slightly more tentative; and environment and heritage groups, community councils and individuals take issue with several points.
63. There is unanimous agreement amongst businesses and developers that most settlements don't need green belts. They have no enthusiasm for new green belts and several in this category agree that other policies can be used to achieve green belt aims and protect the character and identity of settlements. For example, Homes for Scotland submits: " we have consistently urged planning authorities to use other policies to protect the settings of our towns and cities and in particular it is our view that planning authorities should seek to accommodate growth by seeking to release significant areas of land on the edge of settlements and to use master planning and development briefs to ensure not only high environmental quality but also to promote the place-making agenda". Some argue that all existing green belts should be reviewed in light of the new SPP so that unsuitable ones can be rezoned. The Brethren's Gospel Trusts views are similar to those submitted by businesses.
64. There is also near-unanimity among planning and related professionals that most settlements don't need green belts. This connects with a view that the development pressures that would make green belts necessary are simply not present in many areas, and in most cases other policies can achieve the green belt aims just as successfully. One respondent notes that green belts can sometimes be used to pursue an anti-development agenda rather than to direct development in the wider public interest.
65. Planning authorities offer more cautious support for the SPP. There is recognition that other policy devices can protect the countryside from inappropriate or unplanned development and safeguard landscape setting and character, and both Dundee and Angus Councils (where a green belt was removed) note that green belts will not fit every circumstance. But Aberdeenshire Council suggests more use should be made of green belt policy which is familiar and easily understood by the public, for the protection of open space, particularly within towns. They add that while other policies can do similar things, it is clearer to use green belt policy than a plethora of other local policy initiatives. Scottish Natural Heritage also notes that other policies lack the strength and public recognition of green belts. Clarity is sought on the conditions under which a new green belt might be created. The need for close liaison between authorities is also remarked on.
66. For the most part, community councils, environment and heritage groups and individuals strongly dispute the draft SPP statement that most settlements do not need green belts. The Scottish Civic Trust, supporting the draft in other respects and accepting that the statement may indeed often be true, makes the point that if paragraph 12 promotes the usefulness of green belts in towns and cities with a distinct character and setting, then specific green belt policies (as opposed to vaguer countryside ones) could be used equally to protect the identity of vulnerable smaller settlements. The Association of Scottish Community Councils adds that " building pressure already exists on green areas surrounding even our smallest towns, while large tracts of land and buildings lie empty in their midst".
67. Many responses want the SPP to encourage new green belts or adopt a more neutral stance; a view that accounts for almost half the non standard responses. There is also feeling that each case should be seen on its own merits and that it should be for local people, not for Ministers, to decide where a green belt should be designated. A number of groups cite benefits that green belts would have for their areas. The value of other policies is recognised but with the view taken that they do not necessarily deliver the same results. Many respondents who share this perspective think the statement that 'Ministers do not expect to see many new green belts designated' should be dropped.
Settlement patterns- paragraph 13
68. Responses on this section of the draft document divide loosely by respondent group. Businesses and developers and planning professionals tend to be more supportive of the statements in paragraph 13, while environment and heritage groups, community councils, individuals, and to a lesser extent planning authorities, are more likely to express concern.
69. Businesses and developers welcome the recognition that development can occur along transport corridors and on the urban fringe. Several highlight sustainability benefits of such a settlement pattern, and some see clear benefits too in cooling overheated property markets by increasing the supply of accessible housing land. Planning and related professionals also welcome paragraph 13 and raise the issue of sustainability, supporting greater emphasis on reducing the need to travel in looking at the influence of the green belt on commuting patterns.
Urban fringe, ribbon development and urban sprawl
70. The City of Edinburgh Council sees the range of settlement options presented in the SPP as a radical departure from previous green belt guidance. For many, especially environment and heritage groups, this change of direction is unwelcome. There is a widely-held perception that encouraging development on the urban fringe and along transport corridors will bring back the ribbon development and urban sprawl that many think green belts should be trying to prevent. Some point to a direct contradiction with the commitment to avoid urban sprawl in the summary of the draft SPP, others see this paragraph as a potential get-out clause for development in the green belt. The standard responses object to paragraph 13 in these terms: "town fringe incursion into Green Belts and ribbon developments are aspects of urban sprawl (see summary). I object to para 13 which could encourage them." Previous comments on dangers of coalescence as an objective in paragraph 6 are also relevant here.
71. Some of the respondents argue that paragraph 13 fails to fully explore all the sustainability issues surrounding green belts. Midlothian Council sees this part of the draft SPP as too generalised and seeks more direction on the sustainability issue.
Leapfrogging
72. There is a fairly widely-held view that development that leapfrogs the green belt is undesirable and likely to increase car-borne commuting. Examples are given by respondents. The British Holiday & Home Parks Association Ltd claims the Aberdeen green belt caused development to jump to areas beyond. Strathblane Community Council sees development in Balfron as a generator of commuter traffic to Stirling, and an individual respondent cites the examples of Joppa, Hillhead and Coylton outside Ayr.
73. On the other hand some see this leapfrogging argument as slightly one-sided, arguing that improved public transport links also help to deliver sustainability goals, and in some instances development in outlying settlements may be more sustainable than development on the urban fringe, which could also lead to increased car use.
Other issues
74. The standard responses state that "if Green Belt incursion is really needed, it should include consideration of expanding villages in order to save primary schools, village shops, post offices etc. (If village residents want that) or by other methods set away from the fringes of the towns." A small number of non-standard responses echo these sentiments and advocate more emphasis on techniques that avoid town fringe development and urban sprawl like voluntary village expansion, green halos, and tandem suburbs, described in detail by the Helensburgh Green Belt Group. References are also made to the benefits of developing brownfield land within urban areas. Architecture and Design Scotland highlights the importance of high quality design around the urban fringe.
Development planning
Development planning: spread of comments from respondents
Establishing and reviewing green belts- paragraph 14-15
75. There is general acceptance that green belts should be established and reviewed through the development planning process, but some uncertainty about precisely how this would be done. Business is concerned that green belt designation should only follow after enough land to accommodate future growth has been identified in settlement strategies. Individuals and communities are concerned that their voices should be heard, and one or two are adamant that " once designated, green belts should be inviolate, and not a moveable feast controlled by politicians" since " once destroyed, they are lost for ever".
76. Green belts often involve more than one authority, and one professional adviser makes the comment that the necessary coordination and consistency between them does not always happen. In the submission of Architecture and Design Scotland, green belt policy should act to avoid land becoming blighted, and be seen as a means to secure quality from developers and the responsible maintenance of land over which they hold options.
77. The broad support across the respondent groups that green belts should form part of a long term development strategy and be reviewed through the development plan process was qualified. Several respondents, especially amongst community councils and environment and heritage groups, suggest that because green belts should be a long term designation they should not be subject to change with every review of the development plan. Glasgow University puts it this way: "the constant review of boundaries at each local plan review serves nobody well and undermines the… ability to engage in longer term planning."
Advice for review
78. As one respondent notes, the choice of factors to be taken into account in the review of green belts is key, and several environmental groups voice their support for the use of Strategic Environmental Assessment in this context. There are many suggestions that the review should be rigorous, different views on the key considerations (natural heritage designations or availability of brownfield sites), and a fairly widespread wish for more guidance on this point. Some think a statement in the SPP will be enough while others think clarity and rigour requires separate additional guidance. A number of the responses stress that economic and social, as well as environmental, considerations must form part of any review. Some are eager to know when the review of existing green belts can begin.
79. It is apparent that many see green belt review and the identification of boundaries as perhaps the most difficult processes, and these issues in responses are therefore analysed here in some detail. There is a concern that any review of the green belt could be dominated by developers locking horns with each other, the local authority or local communities. Linked to these concerns is the view that the local communities must be fully involved (involved rather than simply consulted) at all stages of the review process.
80. The St Andrews Green Belt Forum looks for some recognition that the designation and maintenance of green belts is more than just a tool for planners: " The overall impression ... is that the support offered by local communities for their green belts is totally irrelevant: all that counts is whether a planning authority or professional planner find it useful in delivering their objectives." The draft would give more comfort to communities, they add, if it adequately acknowledged the need to take their views into full account in determining any green belt policy changes.
81. Perhaps the above concerns also provide some context to the recommendation in the standard responses that a…"strong presumption against new development in the green belt should apply when development plans are being drawn up."
Ministerial approval
82. There is broad agreement that proposals for new green belts ought to require specific approval from Scottish Ministers, a view that any review that eliminated or significantly reduced a green belt should also need this approval, and some uncertainty whether this would be the case. In the view of the Royal Town Planning Institute in Scotland, the policy should be specific and positive in requiring each of the new strategic development plans for the four city regions to consider the need for green belts, and should further clarify the process by which Ministerial approval will be given for new green belts, or be required for the removal of existing ones.
Boundaries and timeframes- paragraphs 16-19
Long term certainty
83. For the most part, there is a warm welcome for a twenty year perspective. The standard forms of response refer to " at least 20 year protection, not 5 years as at present." Aberdeenshire Council cites the 25 years mentioned in the Review of the Planning System, warns against inflexibility, and suggests making a more explicit connection with development planning timescales. The Scottish Planning Consultants' Forum believes that green belt objectives should be adapted to current circumstances and their time horizons synchronised with development plans, and that the draft should encourage greater flexibility and scope for local discretion. Balerno Community Council has some concerns over 20 years, believing that it may become necessary either to designate new green belt areas to restrain increasing rural attack by developers, or to reconsider green belt to facilitate need, and up to 10 years might be realistic. Strathblane Community Council on the other hand thinks long-term green belts are too important for review in shorter-life development plans: they should be under the control of the Scottish Ministers and reviewed at no less than 30 year intervals.
84. Premier Property Group thinks it correct to establish a 20 year time frame as this will mesh with the Strategic Development Plan and long term housing and business land reviews. Looking at what this approach may require, one business respondent remarks: " for green belts to be credible they should identify areas where, for the long term, urban expansion will not be permitted for sound reasons to protect the setting of towns or to avoid coalescence of settlements… It is possible that a two tier Green Belt policy regime should be operated, the lower tier recognising the inevitability of development on the urban fringe." The two-tier idea is also commended by the Scottish Planning Consultants' Forum, which notes that it was a recommendation in the 'Review of Green Belt Policy in Scotland' by Heriot Watt University.
85. There is a firm view in the development industry that strict time criteria should be used in green belt definition. The housebuilders' organisation Homes for Scotland, along with other responses from this sector, asks for the SPP to include "a sentence which explicitly states that land likely to have development potential within a 20 year time frame should not be zoned as greenbelt land". This group of respondents strongly supports the draft SPP proviso that inner boundaries should not be drawn too tightly.
86. The Scottish Green Belts Alliance wants that same sentence removed as it is likely to be seen as " a green light for urban sprawl". Some community and group respondents see tight boundaries as inescapable in their own areas, or necessary for the revival or regeneration of some towns. Helensburgh Community Council notes that "the more a green belt boundary is pushed out the less accessible it becomes for most people". There are a lot of comments about fairness, meeting a set of standard criteria, and taking great care to get things right in the initial exercise, particularly as many believe that the twenty year timescale will not be subject to any sort of interim review. In the words of one group "the start of each 20 year span will be a sensitive time".
Lines on the ground
87. Commenting on paragraph 17, Premier Property Group agrees that hedges and field enclosures can provide defensible boundaries, but adds that where there are no distinguishable features to demarcate optimal settlement limit, new tree belts can achieve the desired boundary. One community council response disagrees that physical features like roads, railways or rivers should be used if the green belt is to be about preserving character of an area, and that only "tree belts" and "landscape features that form the horizon", such as the ridge of a line of hills, are likely to be suitable. But, in contrast, others suggest that boundaries could include non-visible features such as pipeline or HSE exclusion zones.
Minding the gap
88. The Royal Town Planning Institute points out that the draft SPP needs to explain more clearly what should happen to non-designated land in the event that inner boundaries are not "drawn too tightly", adding that "This suggests some form of white land designation which the Scottish planning system has assiduously avoided in the past."
89. The same point is taken up by the Glasgow & Clyde Valley Structure Plan Joint Committee, which sees this as key to the way green belt can be used to manage urban development. The Committee wonders how long-term development areas, say in the second half of a twenty-year period, can be phased in to meet the demands of a sustained growth scenario. Failure to programme and phase-in long-term development carries major risks, it says. First, the momentum on regeneration and the delivery of brownfield flagship initiatives will be undermined if developers are tempted away to cherry-pick easy sites in the long-term growth areas. Second, infrastructure provision may become short-term and piecemeal as developers refuse to wait for long-term master-planning and all the infrastructure needed to support expanded communities or the creation of new ones. Third, landowners drop their commitment to maintaining the quality of their land once it is identified for development and loses green belt policy cover. Fourth, the drive to improve environmental quality and residential attractiveness is undermined.
90. The Committee also cites the uncertainty of forecasting and setting specific development requirements in the long term. Where previously an authority was able to maintain green belt designation until the need for release was triggered, the draft SPP removes that approach, suggesting nothing as a replacement, whilst still acknowledging the need for control and 'phased' development. There is a need, says the Committee, to specify clearly in SPP 21 and across the SPP series, that the development plan process will structure and manage the development of land released from green belt, and that Ministers will support authorities in achieving this.
91. This need for the SPP to stress that development plans have a key role in phasing land for release from green belt is also pressed by Ayrshire's equivalent Joint Committee. West Dunbartonshire Council takes a similar view, with reservations about safeguarding land in the short to medium term without the cover of green belt policy, it feels the SPP must spell out the principle under which land is safeguarded for structured release.
92. The City of Edinburgh Council also questions the practical implications of this section, pointing out that SPP3 requires structure plans to identify overall housing land requirements for 12 years and provide a "broad indication" of the scale and location of housing beyond year 12, preferably up to year 20. The Council feels it " unclear how the green belt inner boundary, which must be clearly identified on the map and on the ground, can be drawn in such a way as to permit the broad indication to operate. It may be that certain areas of land are kept out of the green belt but safeguarded for longer-term development. Their release would be triggered by housing land monitoring and development plan reviews. Such land will come under intense development pressure and plans will need to be very clear on the timing of any land release so as not to undermine the development strategy." The Council believes that policy should be clearly set out on this key issue to ensure that the position is fully understood by all parties at appeals and inquiries.
93. The Elphinstone Group also seeks clarity, arguing that areas of green belt should be taken out of designation even if they are not required immediately, because this is essential for the development industry to ensure development takes place in time.
Green belt release
94. Inveresk Village Society argues that land should be taken out of green belt for urban growth only where:(a) there are insufficient other locations served by good public transport for housing and other needs to be met, (b) the key objectives of green belt in the specific location are not undermined, and (c) new long term, easily identifiable and defensible green belt boundaries can be created nearby. Their message here is (a) look to the green belt only as a last resort and (b) give solid weight to its specific local functions rather than its role simply as a buffer zone, and (c) green belt release should not start a process of urban creep; instead the loss should be accompanied and offset by stronger protection in the locality. This, the response argues, is better than replacing the green belt somewhere else where the designation might have less meaning, since for greenbelt, location not quantity is paramount.
95. In similar vein, a developer insists that expanding the green belt in one place to make up for release in another should always be fully justified through the development plan process. Others in the business community are more dismissive of the whole idea: " The green belt should not be seen as being of a set area to be topped up if a piece is lost."
Master planning
96. The discussion of master planning in paragraph 19 is noted by one professional response as not unique to green belt releases, possibly even more vital on major brownfield sites and thus, though welcome, is perhaps misplaced and might be better addressed through a Planning Advice Note. Another warns that achieving master plan agreement from all the parties listed could slow down not speed up the system.
Local involvement
97. The reference in paragraph 19 to engaging with local people draws a number of comments. The Helensburgh Green Belt Group points out that the recent White paper contains a major section on the importance of public inclusion, yet the draft SPP inadequately incorporates this factor. This response argues that local communities and voluntary groups should be given active encouragement, and sees the draft statements in 19 and 30 as insufficient. It asks for the word "engaged" to be replaced with "involved", defining involvement as "early, proactive and interactive engagement between two or more parties to develop proposals jointly".
98. The Scottish Planning Consultants' Forum is wary of community involvement being a big factor in the designation of green belts, because it can be used as a powerful weapon for local residents who wish to prevent the peripheral development of settlements even when this is strategically desirable in long term.
Development management
Development management: spread of comments from respondents
99. This part of the draft SPP deals with the issues that arise in considering planning applications. The Royal Institution of Chartered Surveyors in Scotland asks specifically whether the Scottish Executive intends to remove permitted development rights in green belts.
Appropriate uses in green belts- paragraphs 20-22
100. In this section the key issue is clarity, with particular respondents looking for explanation where terms seem unclear. The fear is that without greater clarity, authorities will make inconsistent interpretations. And the danger is voiced that - whatever the uses - green belts are likely to become places of car parks, transmission lines and telecom masts.
Strong presumption against new development
101. This is a point of widespread agreement. Commonly voiced across the respondent groups is the phrase "we support the strong presumption against development". It appears most often in the responses from individuals, community councils and environment & heritage groups, and is found in the standard responses. For many, the presumption against development represents the cornerstone of green belt policy, and there is little criticism of its inclusion in the draft. But the firm reminder is given, mostly by developer and planning professional groups, that green belts should not be used as a blanket policy to resist development.
Local involvement
102. Several respondents mention the need to refer to local involvement at the planning application as well as the development plan stage. There is a feeling among members of the public and community groups that public involvement needs to be given more of a role to avoid poor development management decisions and prevent the piecemeal erosion of the green belt by developers which they see prevailing currently. One heritage group argues that "as a fieldmouse might nibble away at a turnip or beetroot so have developers with an all too acquiescent council."
Suitable for green belts
103. Fife Council agrees that the development plan is the right place to spell out appropriate green belt uses. Preferring this to a criteria-based approach, it thinks a list of developments would allow planning authorities to be clear and direct, and give less room for subjective interpretation and manoeuvre. But Elphinstone Group takes the opposite view, seeing lists as inflexible and incapable of dealing with the kind of innovative developments that may be appropriate in the green belt; and they advocate the use of criteria instead. Both views are mirrored in a few other responses, but there is otherwise little discussion on this point.
104. A number of responses do pick up, however, on the different uses bulleted in paragraph 20. Recreation is the main focus here. SportScotland wants greater clarification on the types of recreational uses that are appropriate in the green belt, and in particular why equestrian uses are considered suitable uses. The Scottish Equestrian Association asks the Executive to give clear unequivocal advice on the positive benefits equestrian uses can bring to green belt enhancement.
105. SportScotland objects to the exclusion of motorised activities in SPP. It argues that, although these can sometimes be intrusive, the countryside should not be exclusively for quiet enjoyment and it is often the urban fringe where provision is most needed. It also suggests there may be areas of degraded or derelict land where motorised recreation would be a positive use.
106. The Ramblers' Association questions whether golf courses should be considered appropriate development, seeing them as "a highly unnatural type of development which needs to be sensitively designed if they are not to impede access and remove large parts of the green belt from public use." It notes that most golf course users travel by car which means building car parks. Another response thinks recreational uses are fine in the green belt but argues for limits on new buildings, referring specifically to those associated with golf courses. Another sees artificial surfaces as no compensation for loss of green space.
107. Previous circulars had identified institutions as appropriate green belt uses. Renfrewshire Council welcomes their omission from the draft SPP, but a couple of responses want the reference reinstated. There is also a suggestion that burial grounds be included as an appropriate use.
Scale, form and intensity
108. References to scale, form and intensity of use are welcomed across respondent groups. There is a general recognition that not all development in the green belt is necessarily damaging, and responses describe how small scale development can improve green belt quality, mainly in terms of landscape but also for bio-diversity. Respondents make the point that some uses, and a certain amount of human settlement, can help to support the attractiveness of green belts, which need hedges, ditches, and investment in time and money if they are not to degenerate into scrub. The statements about re-use of historic buildings are also remarked on positively, as are those on the promoting public transport, walking and cycling. A number of planning professionals emphasise that single houses, or small clusters of housing can be appropriate in certain circumstances, and the Farningham McCreadie Partnership feels that the redevelopment of brown field sites needs to be recognised. SportScotland asks for clearer explanation of the terms "compatibility with an agricultural or natural setting" and "low intensity".
109. Architecture and Design Scotland welcomes the draft SPP's reference to high quality design, seeing development in green belts and development up to green belts at the urban edge as two sides of the same coin. It stresses that urban edge development also needs to give attention to design, architecture and landscape, particularly in terms of prominent views into settlements. It puts forward a series of criteria that can be applied to urban edge developments.
Rural development and diversification
110. Paragraph 22 makes several respondents uneasy. They think the role of SPP15 should have been more clearly defined, or that the relationship between paragraphs 20 and 22 needs clarification. There's a view among planning authorities that unless the relative role of SPP15 is more clearly set out, green belt policy will be weakened by inappropriate development under the guise of rural diversification. Some ask for the kinds of rural diversification that would be right for the green belt to be spelled out. The Scottish Rural Property and Business Association finds the references to the re-use of agricultural buildings too restrictive and recommends that "appropriate uses" be extended to cover all development under the Farm Business Diversification Scheme ( FBDS), including the conversion of farm buildings for residential letting.
Infrastructure
111. The Royal Town Planning Institute notes that the draft makes no reference to developments outside the statutory planning system like motorways, major wind farms, transmission lines, and pipelines. This issue is picked up by Aberdeen City Council and an Aberdeen based consultant who both draw attention to the fact that the draft SPP does not address the issue of infrastructure projects that require a green belt location, citing the example of the Aberdeen Western Peripheral Route. It is argued that infrastructure developments such as these should be delivered through the planning system and regarded as appropriate green belts uses, and that branding them as non-conforming uses is unhelpful.
112 Scottish Water makes special reference to this part of the draft, noting that the list of appropriate uses omits water and wastewater facilities, many of which occur in the green belt. This, it says, can present challenges when it seeks to upgrade or establish new facilities. It argues that categorising these developments as contrary to green belt policy risks delay and additional costs and sends a confused message to society that Scottish Water's activities appear not to be in the public interest. It concludes it would be better to exclude Scottish Water facilities from green belt than treat them as an established use.
Treatment of established uses- paragraph 23
113. The proposal that existing settlements should be excluded from green belt designations is welcomed, with nobody suggesting the opposite. Excluding certain major land uses is also welcomed for the most part, but there are those who disagree or think further clarification is needed, with the term major use clarified, and perhaps even what constitutes a settlement elaborated on. There is some doubt about whether institutions are established uses. It is noted that paragraph 23 refers to major educational and research uses, for example, but that the term institutions does not appear till paragraph 25.
114. Some respondents would like to see a reference to the re-use of brownfield land in paragraph 23, one argument being that taking major derelict brownfield sites out of the greenbelt will encourage their reuse and redevelopment. A flexible approach to existing settlements is advocated by one business respondent, who sees small but useful brownfield opportunities offered by redundant agri-industrial premises across Scotland which could help to sustain smaller communities.
115. Several community councils and environment and heritage groups are less certain about the proposals. They worry that over-relaxation of green belt policies for existing established uses and non-conforming uses could lead to unnecessary loss and damage to green belts or a green belt peppered with holes. Particular concern has been expressed over educational uses and airports because of the amount of traffic they generate, and there is also a concern that established uses may pursue development unconnected with their main purpose: housing to raise funds for a research institute for example. It is suggested that where existing uses make an important contribution to green belt objectives they should be retained as green belt land.
116. A few respondents would like a clear statement that their uses should be excluded from any green belt designation. The British Holiday & Home Parks Association Ltd points out that many members have established businesses in the countryside and make a big contribution to the Scottish tourist economy. It feels that the ability to reasonably develop these should not be inhibited by designation. And as noted already, Scottish Water also believes its operational facilities and infrastructure should be amongst the established uses explicitly excluded from GB designations (see previous section).
Proposals for non-conforming uses- paragraphs 24-26
117. The responses indicate that the draft policy statement on non-conforming uses is generally welcomed, and some hope it will lead to more consistent decisions for developments in the green belt. Some of the responses, mostly from planning authorities and environment and heritage groups, argue that the wording could be more precise. There is a worry for example that the terms "established need" and "no other suitable site available" are open to wide interpretation and could become loopholes for inappropriate development. There is a feeling that the present wording could jeopardise the "strong presumption against development" outlined earlier in the draft and that the exceptionality of non-conforming uses should therefore be more forcefully expressed.
118. There is recognition that existing institutions can exert pressure on the green belt, not only within but also adjacent to their grounds, and little disagreement that some provision should be made for their expansion. One respondent did observe that pressure on the green belt is not simply from private sector developers and landowners and that some of the biggest breaches in the green belt have come from the Scottish Executive, for example, major hospitals or new buildings for national agencies. However, on the whole, the consultation responses endorse the idea that developments that meet an established need or national priority should be allowed where they are highlighted through the development plan. There is a view that for this to be effective development plans must be kept up to date, and in a similar token there is a feeling that non-conforming uses should be widely publicised so that local communities can be better involved in the decision of whether a development should be permitted or not.
119. There is general agreement that some provision should be made for the redevelopment of redundant institutional grounds, but again this is accompanied by some concern that the wording in the draft SPP is too relaxed and could give undue encouragement to the establishment of non-conforming uses. The use of comprehensive development schemes is welcomed, and it is also suggested that inappropriate redevelopment could be avoided by greater use of the development plan as a vehicle for guidance. One response suggests that non-conforming uses should not be restricted to redundant institutional uses and could cover any redundant uses that lie in green belts.
120. The responses indicated that there are circumstances when allowing new development is sometimes necessary for the successful conversion of listed buildings. The Farningham McCreadie Partnership goes further and suggests that enabling development should also be allowed for the conversion of non listed buildings. There is an acceptance that the redevelopment of institutional or corporate estates in the green belt needs to be sympathetic to its surroundings and this is seen as particularly important where listed buildings or their settings need to be safeguarded.
121. The idea of green belt exceptions to meet national priorities or established needs where suitable alternative sites are not available gets support from some quarters, Scottish Enterprise Edinburgh & Lothian for example. Others are more cautious, Peter Branney taking the view that this approach seems too broad, and warning that while exceptions should be highlighted in development plans, the public must be involved in these decisions which should not be left to negotiations between developers and planners.
Departures from the development plan- paragraph 27
122. Only a small number of responses comment on this section of the draft SPP, most supporting the notification arrangements or welcoming the review of the circular. One stresses the need for Scottish Ministers to be consistent in their decisions, and two take the view that only significant non-conforming developments should require to be notified.
Managing the green belt resource - paragraphs 28-30
Managing the green belt resource: spread of comments from respondents
123. This section draws comments from all the respondent groups, with a good number from planning authorities and professionals. Overall, responses welcome the emphasis on the positive management of green belt, but there is some scepticism from authorities about how such a policy could be implemented successfully.
124. For example Fife Council warns that there is a limit to how far planning can change land management, and East Lothian Council asks whether green belt gives any more impetus for positive management than other planning policies. Renfrewshire Council is unclear where the remit for identifying management initiatives lies. Several responses think that more guidance on green belt management is required, perhaps in the form of a planning advice note. Others emphasise that successful management needs matching resources, whether to look after woodlands, develop new path networks, or tackle fly tipping.
125. There is general support for mechanisms like management agreements and community planning partnerships. Measures that improve access to the countryside seem to be particularly welcome as are those that involve communities, landowners, and other stakeholders. One response makes the link between landscape improvements and the creation of defensible green belt boundaries.
126. Some respondents suggest that the effect of edge-of-settlement planning on green belts needs care and attention, and one points out that protection through planning conditions might support a more positive approach to management. Pressures of litter and vandalism can lead to long-term degradation which can make holdings difficult to use as mainstream rural land. This response suggests that since landowners in the green belt forfeit potential development gains, it would be sensible to work with them to invest to make green belt land as useful and attractive as possible.
Conclusions - paragraph 31
127. Very few responses mention this final section of the draft SPP. Jackton & Thorntonhall Community Council supports the conclusions, the Edinburgh and Lothian Greenbelt Network suggests some minor re-wording, and the Helensburgh Study Group thinks that a glossary would make a useful addition.
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