Scottish Green Belts Alliance

SGBA response to the consultative draft SPP 21

The Alliance welcomes the Communities Minister Malcolm Chisholm's statements about the draft SPP 's aims to strengthen and enhance the role of green belts, to encourage greater stability in their use and to avoid urban sprawl. However, we do have a number of concerns about whether a reasonable balance has been struck between the Executive's top priority to promote growth in Scotland and the need to conserve and enhance the character of towns and cities, the quality of life in their communities and the green belt itself. We have outlined below the key issues, as we see them.

We support the following aspects of the draft SPP 21

  1. Circular 24/1985 has been enhanced to a SPP
  2. Title – maintains well understood 'brand' name
  3. The continued relevance of green belts as an important planning tool to guide the shape of towns and cities and to protect their landscape settings [see Summary]
  4. The aims to 'strengthen and enhance the role of green belts and encourage stability to increase their effectiveness' [see para. 5]
  5. Strong presumption against development within green belts [see para. 20 - 'strong' is a new statement]
  6. Twenty year certainty in Development Plans for the green belt designation [see para. 16]
  7. The stated need to avoid urban sprawl (see Summary)
  8. Priority for urban regeneration to lessen pressure on green belts [see para. 3]
  9. Recognition of quality of life benefits derived from green belts [see para. 10]
  10. Rigorous Strategic Environment Assessment [see para. 14]

We have serious concerns about the following aspects of the draft SPP 21

  1. Key issue: The objectives [para. 6] are incomplete and should also include the following matters:
  1. Providing continuity of green belts through strong presumption against development within them;
  2. Preventing coalescence of settlements;
  3. Avoiding urban sprawl and ribbon development;
  4. More emphasis on protecting the natural and cultural heritage of green belts
  5. Assisting sustainability by redeveloping vacant urban sites
  1. Key Issue: The draft SPP 21 proposes that green belts should be fixed for 20 year periods. We consider it is essential that there is a rigorous review of circumstances at the start of each 20-year green belt period. We suggest that there should be a Circular or PAN setting out the data required for the review and the criteria upon which informed judgements are to be based. It is essential that the principle of ‘strong presumption against development in green belts’ should apply at this review stage as well as during development control.
  2. Lack of an explicit statement that a policy for the equitable distribution of growth throughout Scotland would ease the pressure on certain green belts like Aberdeen and Edinburgh [see para. 5]
  3. Inadequate recognition of differing circumstances across Scotland [see paras. 2 – 6]
  4. Failure to define green belt properly [see para. 8 - The Alliance ‘s report offers a fuller definition]
  5. Lack of emphasis upon the importance of protecting the inner margin of green belts along the urban fringe, from whence most of the quality of life benefits are derived [see para. 13 - this contradicts the SPP ’s statement to want to avoid urban sprawl]
  6. The protection of the landscape character of green belts and access to them are specific objectives. So the reliance upon other countryside policies like Areas of Great Landscape Value [AGLV], which are often not effective, to protect these environments in the urban fringe, is confusing and flawed. [see paras. 7, 8, 12]
  7. Failure to give explicit encouragement for the creation of new green belts, where green belt policies would give greater protection for the natural and cultural heritage surrounding settlements than other countryside policies. [see para. 12]
  8. In places of severe growth pressure like Edinburgh and Aberdeen, extra protection is needed for special areas of high intrinsic qualities and importance for green belt purposes [see para. 9]
  9. Sustainable travel solutions are seriously over emphasised and could encourage unwelcome ribbon development [para. 13]. These would promote incursions into green belts without a comparison of the effects of the resulting loss of these assets and without considering other sustainable aspects.
  10. The identification of areas surrounding towns and cities for expansion that would affect green belts should be carefully assessed and based upon an environmental audit to assess the capacity of areas to accept change without unacceptable damage to their qualities [see para. 16]
  11. Over relaxation of green belt policies to allow growth in existing established uses and non conforming uses could lead to unnecessary loss and damage to green belts [see paras. 23, 25]

Overall, we note and regret that the Scottish Executive’s perspective is predominantly an urban one, to the relative neglect of rural and heritage purposes for green belts.

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