NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.

Green belts

Proposed key objective of NPF4: To direct planned growth to the most appropriate, sustainable locations whilst protecting and enhancing the character, landscape setting and identity of settlements and providing access to countryside recreation.

Many of those commenting on green belts commented on either their value or that they should continue to be protected. Points raised included that green belts are a nationally important resource which help to direct growth into appropriate locations within settlements. The benefits they bring in terms of climate change mitigation, supporting biodiversity and contributing to the quality of life and wellbeing of society were amongst those highlighted.

There was sometimes a concern that the integrity of green belts is under threat, primarily from housing development, and there were references to current proposals to develop within green belts, including those of Aberdeen, Edinburgh, Glasgow, Perth, St Andrews and Stirling. On a similar theme, it was suggested that NPF4 must play a significant role in reducing the constant conflict that exists among government, councils, communities and developers when it comes to planning.

Those raising such concerns tended to call for green belt policy to be strengthened, sometimes also making the connection made with prioritising the use of brownfield sites. In terms of their role and potential going forward, comments included that green belts could:

  • Be made more sustainable and useful to society, for example through encouraging more local food growing, with the development of more allotments and urban crofting sites.
  • Make an important contribution to the development of a Nature Network.
  • Not necessarily encircle settlements but potentially take other forms such as green fingers or wedges, with the role of each individually identified piece of green belt, or finger or wedge set out in development plans.

In terms of ways in which policy could be strengthened or improved, suggestions included by:

  • Encouraging local authorities to extend existing green belts and designate new ones.
  • Providing a clearer definition and degree of differentiation between the green belt and the wider rural area.
  • Requiring local planning authorities to use RSSs, LDPs and a Nature Network to manage green belts more effectively for the long-term benefit of local communities and the climate.
  • Preventing the granting of planning permission for building developments on green belt land while undeveloped brownfield land remains in their area, with unmet housing targets no longer considered a valid reason for development on green belt land.
  • Introducing mechanisms to prevent speculative planning applications for large-scale residential developments on designated green belt land.

It was also suggested that green belt designation and policy can be a key issue for local communities and that a review - outwith the NPF4 consultation - of how it is designated and what development may be acceptable is needed. Also with reference to communities, it was proposed that the role of community councils in relation to planning appeals related only to green belts should be formalised.

While some respondents favoured strengthening green belt protections, an alternative perspective was that green belt policy needs to be reviewed and reconsidered, with NPF4 providing an opportunity to redefine the purpose of green belts and to articulate clearly the difference between them and the wider supply of greenfield land. It was also suggested that the green belt should not continue to be utilised as a de facto landscape designation and that, if a particular place or area is required to be protected for specific reasons, the use of a specific landscape designation is more appropriate. There were also references to considering the green belt's role in terms of supporting sustainable economic growth, development around some settlements and climate change mitigation, including in relation to sustainable energy generation. Further comments included that:

  • Green belt designation should be reviewed each time a relevant LDP is prepared or reviewed.
  • Land that does not meet green belt objectives should be released for other uses, including specifically for the delivery of homes.
  • Where a local authority is constrained by the green belt and is not meeting their housing land need and demand targets, they should be required to release sufficient land from the green belt in the form of Safeguarded Land.
  • Clearer policy for brownfield sites within the green belt would be helpful.

A number of local authority respondents were amongst those commenting on how prescriptive NPF4 should be in identifying the issues for planning authorities to consider when designating green belts and determining planning applications. Views were mixed, with some considering the existing guidance provided by SPP is sufficient. However, it was also suggested that more prescriptive advice could be provided in NPF4 in terms of assisting with the designation of green belts. It was seen as particularly important that NPF is specific and clear about the uses which will and will not be acceptable within green belt areas. For example, it was noted that if proposals relating to hutting are promoted, there would be a need for identification of the types of areas that would be suitable within the green belt.

In relation to whether NPF4/RSSs should have a role in identifying green belts, one view was that the role of identifying and defining green belts should be retained by local authorities, who hold the required local area knowledge to appropriately determine the extents of these areas. However, it was also suggested that while the identification of boundaries should be left to LDPs, where there are cross-boundary issues the RSS may be the more appropriate vehicle for identifying green belt boundaries.



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