By Nikki Sinclair, Green Belts Alliance Manager , APRS | The Association for the Protection of Rural Scotland
Scotland’s Green Belts
A Green Belt is the designated open land around, beside or within an urban area where there is a presumption against most types of development. Green Belts are designated by local authorities in their Local Development Plans (LDPs) to: help protect countryside by containing urban sprawl; preserve and enhance the landscape settings of towns and cities; give urban residents access to open areas; and direct any necessary growth into more appropriate locations within settlements. Scotland has 11 Green Belts designated by 21 Local Authorities – maps of all the Green Belts can be found on the APRS website.
Scottish Planning Policy
The purposes of Green Belts and the limited types of development allowed on them are currently set out in Scottish Planning Policy, 2014 (SPP 2014). As they are viewed by some developers as restrictive and inflexible there have been calls for reviews of Green Belt policy in order to weakening the protection against development they offer. Since 2014, Scotland’s Green Belts have been reduced by both planned land releases during LDP reviews and by significant speculative developments, mostly for housing. Many of the latter have been permitted on appeal despite being contrary to the LDP, via a loophole in SPP 2014 that allows contributions to housing land supply to be given more weight in planning decisions than other aspects of sustainable development.
The Scottish Government tried to address this loophole in 2020 with amendments to SPP. However, these changes were overturned at the Court of Session in July 2021 in a case brought by two developers who argued the manner in which the consultation had been undertaken was unfair. Part of the Government’s motivation to amend SPP urgently was that the loophole applies when more than 5 years have elapsed since an LDP was adopted. Covid has exacerbated the usual delays with LDP reviews, and on top of this, many planning authorities held off reviewing their plans until NPF4 and the proposed new guidance for LDPs were in place – both of which have been delayed themselves.
It is possible that 14 of the 21 local authorities which have Green Belts will have ‘out-of-date’ LDPs by the end of 2022, although hopefully a few of these will adopt replacement plans before then. Unfortunately, the introduction of an NPF4 which removes the current loophole will not come soon enough for some areas of Green Belt and other unallocated Greenfield sites that developers have their eye on.
Benefits of Green Belts
Throughout the NPF4 consultation stages APRS has promoted strengthening the presumption against development on Green Belt land and the upholding of a plan-led system. APRS has been making the case that designating and limiting development on Green Belts has multiple benefits in terms of climate, biodiversity, and landscape. In addition, as became even clearer during the pandemic lockdowns, they offer access to nearby countryside which can improve quality of life and wellbeing for the large proportion of the Scottish population that live in urban areas.
Green Belts contain significant areas of prime agricultural land, and semi-natural woodland. Even if much Green Belt is not considered important enough to be protected for nature conservation alone, by remaining as open land or ‘green infrastructure’ it can allow greater connectivity between key sites. They can also reduce urban air pollution and alleviate flooding. Green Belts have potential, through appropriate management, to do even more to tackle the climate emergency and nature crisis and to provide opportunities for home-grown food, outdoor education, improved active travel and recreation for local communities.
In terms of climate and meeting net-zero, Green Belts help direct development to more appropriate and sustainable brownfield sites, including vacant and derelict land, and encourage the re-use of existing buildings. In the recommendations from Scotland’s Climate Assembly (2021) there was 95% support for the call to “Strengthen planning restrictions immediately so that development on greenfield sites should not be permitted until all other development options, such as brownfield and existing building repurposing, have been considered and legitimately rejected”. There was even more support for “Create thriving town centres by focusing on the conversion of existing properties into high quality housing and community spaces rather than building more edge of town developments”. These recommendations perhaps recognise that the loss of open land near urban centres is regrettable in itself but also that more urban fringe developments are unlikely to enable future residents to have sustainable lifestyles, making net-zero targets ever harder to reach.
The Draft NPF4
Specific policy on Green Belt is contained in the section of the draft NPF4 titled “Urban edges and the green belt”. The clear statements of the multiple benefits of Green Belts to the environment and quality of life which are set out in the two paragraphs of preamble and in policy 29 a) are welcomed. The rest of Policy 29 is also supported although APRS will be making some suggestions for improved wording and the inclusion of the term Green Belt in the glossary. We welcome the removal of the above mentioned loophole from national planning policy and hope Scottish Government resist any calls to insert replacements for it in either the final NPF4 or the delivery programme. This would undermine the framework where policies such as reinvigorating town centres, planning 20-minute neighbourhoods, brownfield first and protecting Green Belts all support each other.
The six Universal Policies must apply to all planning decisions and their wording must be clear enough to ensure appropriate weight is given to the climate and nature emergencies in both LDPs and decisions.
“Perhaps the most important aspect of today’s Green Belt is that a legacy of open land has been passed down to us from previous generations. They did not squander it for short-term gain: neither should we. It is a precious resource that should be used responsibly and passed on to future generations.” From: Repurposing the Green Belt in the 21st Century (2020), Peter Bishop, Alona Martinez Perez, Rob Roggema and Lesley Williams, UCL Press, London
Further information on Scotland’s Green Belts and on the APRS Green Belts Alliance – a network of interested local groups and individuals – is available on the APRS website.
Nikki Sinclair
APRS | The Association for the Protection of Rural Scotland
Scottish Charity No SC016139
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