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Item 2 is draft Scottish planning policy 21, which is on green belts. The committee will hear evidence from three panels on the draft policy, which proposes changes in the operation of green-belt policy. During the Scottish Executive's consultation, several key issues were raised. The evidence session will allow the committee to hear views before the Deputy Minister for Communities appears before us on 18 January next year to answer questions on how the Executive intends to respond to the consultation.
I suggest that somebody from a local authority should kick off the answers.
When we in East Renfrewshire produced our local plan, we considered the uses that we felt were appropriate in the green belt and in the urban area. Broadly, those uses follow the designated green belt uses that are outlined in the draft SPP. We examined closely the detailed boundary of the green belt and focused on defining factors—the strong features that help to define the green belt's boundary. That was done through site surveys of the green belt by walking round it and looking at its boundaries.
Is that process relatively easy? Do communities express concerns and differ on where boundaries are set, or are communities generally happy with the boundaries that local authorities define?
In my experience, communities have accepted the approaches that we use. Mr McAuley's methodology is applied elsewhere.
Planning consultants see things from a slightly different angle—we see the green belt in its current format, although we are here today to talk about a future format. In its current format, the green belt is potentially, or actually, a defensive mechanism that gives considerable security to communities in—dare one say it?—resisting change. There is a fear of change, and our profession is increasingly facing the challenge of finding the best way to manage that change.
I have no intention of disagreeing with my colleagues; their processes are totally correct. I do, however, represent a wider spectrum of people that includes clients who wish to take issue with green-belt boundaries. I have been involved with local planning inquiries in reporting on-site to inquiry reporters in industrial areas that have green belt running through the middle, but in which the justification for the position of the green-belt boundary has been entirely unclear. Instances such as that call into question the logical definition of boundaries. I agree entirely with John Inman's view that, if we define green belts with defensible boundaries that are clear and understood, we will all be in a much better position.
The convener has asked the question that lies at the heart of the practical business of planning for green belts. It is very hard to answer the question without in the first place understanding exactly the purpose of a green belt. One of the big issues is how the public comprehend what we are trying to achieve through green belts. We cannot just go and look at the countryside surrounding a conurbation and, based on its appearance, make a decision on whether or not to make it a green belt, as opposed to where the boundary should go. We need to consider the role of the green belt in the context of how the conurbation functions. From that point, we can develop a notion of what we are trying to do with the green belt.
Should the Scottish Executive issue a planning advice note that outlines the procedures that are to be used in reviewing green-belt boundaries? Would that be helpful or necessary?
To echo what Graham U'ren has just described, it is not just a case of reviewing the procedures for boundaries, but of reviewing the function of the green belt. In my opinion, although the green belt was originally in a logical form for constraining or directing growth to the right locations—which is what I think we are still about—it has grown, so that vast tracts of our countryside are now covered without there being a need for such limitation.
There may be advantage in advice being given on how to define green-belt boundaries, but there are not many differences in how different authorities go about the process. The key differences relate to the definition of areas for growth; there are big differences in how authorities approach that process and set criteria for defining areas of growth. We experienced that when we produced our local plan, because as part of our green-belt review we proposed a system for identifying the most suitable areas for growth. Our system was devised in-house. Other authorities use different systems, so I would certainly welcome guidance and advice on the matter so that identification of areas for expansion could be done more consistently throughout Scotland.
I am slightly reluctant to have more such guidance, although, as Brian McAuley said, there is always some value in it. I am reluctant largely because a lot of Scottish planning policy is about handing the baton on to local authorities, which have considerable discretion as to how to apply national policy locally. Whether or not to have a green belt is still a matter to be tested through the statutory development plan process, if we are to be able to take a wider strategic view in the current structure plan, or in the city region strategic plan in the future.
I endorse the point that Graham U'ren has made about the importance of development plans; before we came here today, John Smith and I were talking about that. We are well aware that the Planning etc (Scotland) Bill has just reached the public domain, and we are firmly of the view that a lot of the Government's thinking that is coming through in draft SPP 21 will find its true place and achieve its aspiration only within a new style of development plan that is able to engage communities in the process whereby policy is formulated and expressed. We see green-belt policy being reformed in that context: it needs to be reformed, but the debate that will allow that to be addressed relates to reform of development plans.
That conveniently takes us on to my question. Paragraph 12 of the draft policy states:
Green-belt designation normally comes from the strategic planning perspective of structure plans, which are for the longer term in that they have a 20-year horizon. They provide a framework for growth, expansion and containment in an area and offer long-term stability within which local plans define the details of green-belt boundaries.
I find the issue difficult. Given that flexibility has existed in green-belt designations in the past where there were exceptional needs, and given the proposed flexibility in relation to inner boundaries and the statement in paragraph 24 of the draft policy, what new measures in the policy will protect green belts?
A new feature is the emphasis on green belts being used more proactively in defining settlement strategies, which is mentioned at the beginning of the draft policy. Another new feature is that the policy tries to encourage a more proactive approach to enhancing and improving green belts and to using them positively to serve the communities that they surround. Those important aspects of the draft SPP will add strength to the system.
I would not want the comments in the SSDP's submission to obscure the fact that we welcome the Executive's approach and its genuine attempts to give green belts a degree of permanence. The Executive supports that principle and has gone quite a long way in its attempts.
I entirely agree with John Inman's concern about handling long-term release of land. As soon as land is identified for long-term release, there will be pressure to bring the release date forward. If we develop a good plan-led system, we should be able to cope with such pressure. We hope that planning reform will make that leap and allow us to handle the long-term release of land much better. If it does not make that leap, the green belt may be eroded.
You will understand my confusion when I read in paragraph 31 of draft SPP 21 that
Do you mind if I link the two issues together and try to resolve them?
Please do—I would appreciate that.
Within a number of authorities, the green-belt policy and the definition of green belt are seen as constraints to encourage urban regeneration. I have no difficulty with that. When we seek to accommodate growth, my preference is to ensure that green belts are, as you say, robust, defensible and long term. I find, however, that certain authorities just identify the urban edge and say that everything beyond it is green belt, whether it merits it or not. I was involved recently in a case that went all the way through a local plan inquiry, in which the local authority identified vacant urban derelict land as green belt because it saw it as the end of the urban area, without thinking about the benefits that development could bring and which would enhance the area.
You will be aware from our written response that the Scottish Executive commissioned a research project in advance of preparing the draft SPP. Within the research team, which was headed by Professor Bramley, there was a lengthy debate about whether the phrase "green belt" was a misnomer when we are talking about proactivity. A belt implies a corset. As John Smith said, it implies a constraining mechanism, which might bear little relationship to the natural organic requirements of a city or town to change with time on the basis of sustainability principles to do with public transport and ease of access. You might end up with a situation in which the very policy that is being presented runs against the natural forces for change that require to be managed and accommodated.
I will leave it at that, but if you are thinking about a corset to protect something robustly, you cannot have bulges here, there and everywhere. That is basically what we have in the draft policy, which states that
Just to add to the analogy—
No, stop now.
How can I follow that? It is difficult to link to Mary Scanlon's bulges.
No, but if we were to head to the right advice in draft SPP 21, the answer would be yes.
I agree that the current green-belt circular is difficult for planning authorities to implement when they are considering small-scale, incremental and minor developments in the green belt. The strict interpretation of the circular could rule out an attic extension and a range of other very small developments that would not impact on the green belt in a way that the policy is intended to control. For that reason, we have in my area developed a policy that allows a de minimis amount of development.
The principle of having some positive prescription about how the green belt should be managed is an essential part of the package, but we have—because of changes in agriculture—to move forward in our decisions about what uses for the green belt are regarded as appropriate. It is important to have notions of what is appropriate for the green belt.
It is recognised by authorities that green belts are living things, that communities live in them and that they need to change and to cope with the pressures of new development. Green belts are not cast in stone. Sufficient guidance is available to authorities to allow them to develop their own policies to allow for change to take place in their green belts. Most authorities have a green-belt policy that contains a designation within which there is a suite of policies that allow for new development to take place. That development should maintain the life of the green belt for the uses that have been set out for it.
Draft SPP 21 lists appropriate uses for green-belt land, which seem to be like the previous uses. Is the list right and useful, given the comments that Graham U'ren made? Might it constrain local authorities?
The list is appropriate as far as it goes, but other uses for green belt need to be on that list, such as mineral workings, for example. There is scope for accommodating such development. The list is not exclusive, but it enshrines the key objectives of the green belt, which are to provide opportunities for outdoor recreation, agriculture, forestry and for the protection of the landscape. Such activities are fundamental to the preservation of the green belt. However, other uses need to be accommodated in certain circumstances.
Draft SPP 21 seems to say that we have to look to rural communities and the uses there. However, the list of appropriate uses does not seem to allow for such rural uses—it would not allow extraction of sand and gravel, for example, so a local authority might refuse permission for such an activity if it consulted draft SPP 21. Are we being realistic? Is the Scottish Executive really allowing farming communities to examine other ways of making a living while protecting the environment?
Guidance on what is allowed without the right caveats for flexibility tends to limit the opportunities for innovative change. I have already notified the Scottish Executive of two examples that I believe are missing. First, there is no reference to improved road or rail connections. Road improvements are being promoted by the Scottish Executive all the time, and it is more than likely that some of them will run through the green belt, but the list contains no allowance for such improvements.
Perhaps all that is needed is more cross-referencing. There is Scottish Executive guidance on major developments such as in transport, minerals and renewable energy, so maybe we need clearer guidance that would allow the reader to see how policies on those issues relate to one another and how they join up.
From the perspective of areas outwith the cities, it can sometimes appear that green belts offer protection, privileges and rights to cities while imposing duties and burdens on neighbouring areas. Then again, perhaps I would say that.
Perhaps I can answer that from the Edinburgh perspective. A good example of a pragmatic approach is the approach that was taken to the new Royal Bank of Scotland headquarters, which was developed on a brownfield site in the green belt. The planning guidance at the time did not support that type of development, but the City of Edinburgh Council took a pragmatic approach, considered all the angles and decided that it was in the city's interests—and indeed, in the national interest—for that development to proceed.
Do the other witnesses have any thoughts on appropriate development within green belts?
Whether or not we use the word "pragmatic", we must not leave the impression of hypocrisy. I do not read the guidance in draft SPP 21 to mean that major proposals—such as a technology park or an organisation's headquarters—should be considered only when the planning application comes in. My reading of draft SPP 21 is that we should provide for such projects in the review of the development plan so that there can be a full public debate about the principles rather than the public being faced with a fait accompli or a gauntlet being thrown on the table.
I agree. We have a plan-led system and if we get the plan right, we will identify the right locations for sustainable development and get the green belt right. At the moment, the green belt has blanket coverage and there is no accurate description of its boundaries and purpose. If there are brownfield sites within a well-defined green belt, the local plan should indicate the appropriate uses for those locations.
To return to the theme of pragmatic decision making, surprises can happen that nobody thought about when the plan was written or the green-belt boundaries were drawn. We need to enable local authority planners and the Scottish Executive to make appropriate decisions. If something closes down and a site becomes available for redevelopment, it is helpful to be able to apply common sense. Will the proposals make it possible to do that?
I recognise some familiar themes behind that question. My view is that we should go back to the review of development plans that is taking place.
I was a bit concerned about draft SPP 21 giving undue encouragement to the establishment of non-conforming uses on what is described as "institution grounds". The difficulty with that is that some such grounds are quite remote from existing communities, which can lead to unsustainable development. I agree entirely with my colleagues that the plan-led approach is best for securing long-term sustainable development.
Do any of the panellists have thoughts about the proposal for more green belts around towns that do not have them at the moment?
I do not know of any that are being considered at the moment. Some authorities are thinking about removing their green belts, but I say again that it is about the local plan and the development plan process. They take the community and its requirements into account and if a green belt is required, that will be considered through the plan process.
Sometimes when we are looking at protecting areas around towns other than the big conurbations, we are not looking at a prima facie case for a green belt; we are simply looking at the right prescription for that area, whether it is landscape protection or better use through recreation. If the land is valued as an asset, it should be designated in a way that reflects the value of that asset. Too often, green belt has been used as some sort of blanket approach.
Are there any other major issues that have not been covered in this session? Speak now, or forever hold your peace.
There is one point that we have not touched on in any real detail. One of the green-belt policy's key objectives is to protect and enhance the character and landscape setting of towns. It is important that authorities have a clear understanding of the landscape qualities and character of their green belts.
I want to pick up on some of John Home Robertson's points, and I want to be controversial. What is the point of having a green belt, particularly around the cities, when the Edinburgh green belt, for example, has led to increased pressure for housebuilding in Fife?
Indeed.
And everywhere else.
Exactly—and elsewhere. I accept that.
I agree—it is horses for courses in many respects. I can speak only from my point of view, which has a west of Scotland perspective. The green belt has been an essential planning tool in supporting the Government's objectives of securing brownfield renewal and the regeneration of existing communities. It has been an important tool in ensuring that peripheral urban expansion has not taken place in the Glasgow and Clyde valley area and that the problems of dereliction and vacant land in communities have been tackled more directly. Also, the targets for brownfield renewal have been more readily achieved because we have had a strong green-belt policy to bolster and support the efforts to regenerate existing communities.
I agree that there is no scope for any more green belts of the type that we have at the moment in Scotland. There is, however, scope for a new way of addressing how towns and cities should cope with the inevitable pressures for change. We will have a stagnant and backwards-moving economy if we do not accommodate change and we need a new way of accommodating change. Our hope is that over the next few years as we see a new development-plan regime coming in—which will be more sensitive to places and issues and which will have a vision for the future such as our current plans do not—we will make the case for taking away the green belts that we have now because we will have a more sensitive, relevant and contemporary way of dealing with pressures and change
The question was put as a controversial one, and I will try to rise to the challenge without adding unnecessary controversy. Brian McAuley's experience in the west of Scotland is not necessarily a paragon of virtue, but it demonstrates a number of important principles. There are planning tools that can be used effectively to promote urban regeneration, which is a major issue. We in the planning profession in Scotland were very proud when, a few years ago, John Prescott announced the target of 60 per cent brownfield development to meet housing needs. In the west of Scotland, at least, we have been achieving that—and more—for over 20 years, which is down to using those planning tools.
May I add an east-of-Scotland perspective?
Please do.
I would not argue for the complete abandonment of green belts. Tricia Marwick identified some of the negative aspects of green belts, which we as planning authorities have also recognised. They include unsustainable travel patterns; people have been forced to live further from the urban area than they want. Green belts have also put pressure on the housing land supply, which has fed through into house prices. The effect is spreading beyond the city—none of us would deny that. The majority of planning authorities accept that and recognise the difficulties.
I am sure that Scott Barrie is desperate to get in here, but I ask him to bear with me. I did say that I wanted to be controversial. We have brought the debate to life. Although I am pleased that there is a wonderful quality of life in Edinburgh because of the green belt, there is not such quality of life for those who simply cannot afford to live in Edinburgh because they cannot get access to housing and are forced across the bridge to housing developments right along the M90. We now have ribbon development from Dalgety Bay. The quality of life of people living there who have to travel back and forward to get the wonderful jobs that are located in Edinburgh—
John Inman said that there was easy access.
That is certainly not true.
Yes—I heard that. We will leave aside the problems of the Forth bridge.
Yes, I do. Draft SPP 21 gives us a firm basis for reviewing the long-term role of the Edinburgh green belt in that context, and for reviewing how we might move towards a different type of strategic plan that attempts to address the points that Tricia Marwick has made.
I agree. John Inman has said that situations change over time, which is what has happened. It was right to introduce green belts when they were introduced, but they are at the end of their lives. There is probably greater awareness of the systems that we can use in the development plan system that would protect the features that we want to be protected and that are currently protected by green belts.
I apologise for having to leave to attend an Education Committee meeting, but I must move an amendment to a bill in that meeting.
I return to the point that Tricia Marwick made about the need for affordable housing. That issue is acknowledged as being important in the west of Scotland. Its importance has been particularly acknowledged in pressured areas such as East Renfrewshire. There may be scope to allow land to be reserved for affordable housing, particularly on the edge of pressured areas, without necessarily compromising the green-belt policy, which I contend remains a valuable planning tool. There is scope for allowing affordable housing within the green belt, if that is the only place it can go.
That concludes our questions. I thank the witnesses for attending and for their written evidence in advance of the meeting.
Meeting suspended.
On resuming—
I welcome our second panel of witnesses. We are joined by: Allan Lundmark, the director of planning and communications for Homes for Scotland; Michael Levack, the chief executive of Scottish Building; and Jonathon Hall, the head of rural policy for the Scottish Rural Property and Business Association.
Some of Scottish Building's members undertake developments, from large scale to small scale, but I will answer your question from the point of view of a builder rather than from that of a developer.
From the point of view of the housebuilding industry, I can say that clarity and certainty are important. We welcomed draft SPP 21 in the context of other planning advice—particularly SPP 3—about long-term settlement strategies.
I suspect that I come from a slightly different perspective from the previous panel and the other members of this panel in that my organisation represents rural land-based businesses such as farming, forestry and all sorts of estate interests.
Mr Lundmark said that developers seek certainty. Can the planning process be an exact science? Is not there a need for some flexibility, and how can that flexibility be balanced with the certainty that you seek?
The planning process cannot be an exact science—it has to be able to respond to various pressures, particularly changing economic circumstances. However, we have the tools to enable us to do that.
Does the 20-year timescale for green belts give you any concern? Could it form part of your model for master planning, as you have just outlined it?
The 20-year time horizon brings certainty despite the fact that circumstances will change. I return to the idea that the issue should be about how we master plan the development of our communities. If we couple long-term phased releases with proper master planning, we send clear signals to the development industry about where development should take place.
I hope that the 20-year period will provide greater certainty. We are talking about flexibility; development that is acceptable to one person might not be acceptable to another. We have been talking specifically about housing, but taking the point that Jonathon Hall made earlier, we are not just talking about homes; other uses need to be included, including transport, leisure and business.
On the point about inner green-belt boundaries not being drawn too tightly, I note that paragraph 24 of draft SPP 21 states:
I agree with the earlier panel that the matter raises questions about the whole development plan system. We need a more robust system; we need a development plan that addresses such issues and sets clear policy objectives from the beginning. The fact that certain circumstances cannot be anticipated does not necessarily mean that we do not have a robust planning system; we just need procedures and processes in the system to cope with that. Paragraph 24 of draft SPP 21 sits alongside my ambition to have a planning system that sends out robust policy signals about where development can and cannot take place.
There is a contradiction in that green belts should be, as it says in paragraph 31, "robustly protected". I have difficulty with there being a flexible inner boundary and robust protection. Can those two concepts sit comfortably together in one document?
I do not take the phrase "robustly protected" as meaning robustly protecting lines on maps. The green-belt policy is set up to achieve certain wider objectives; it is not an objective in itself. If it is intended that the line of the green belt should be moved to accommodate other pressures, and wider environmental policy objectives must also be accommodated, the robustness will be in the policy mechanism that allows growth while protecting the wider environmental objectives. It is not necessarily—although in many cases it will be the case—about drawing hard lines on maps. That is not the sole way of defining a robust policy position.
From the rural perspective, some of the flexibility that we might require or desire is not written clearly enough—or at all in some senses—in draft SPP 21. Draft SPP 21 needs to take full cognisance of SPP 15 on planning for rural development. I would like a far greater overlap. Cross-referencing of draft SPP 21 with other policy directions through tools from the Executive or other appropriate means was referred to by the first panel. There are many good things in SPP 15 that allow appropriate development in the right place for rural development's sake; there is not simply protection for protection's sake. SPP 15 is not about preserving things in aspic—it is about allowing rural communities and businesses to develop and evolve, while recognising the importance of landscape quality, recreational space and so on.
What is your opinion of the requirement in paragraph 19 to replace open land that is developed in the green belt with open land elsewhere? If we take Tricia Marwick's point about Edinburgh, is not it the case that if we have so much land that is designated for green belt, in order to develop on part of it we have got to designate green belt elsewhere? Is that reasonable and compatible with the need for development flexibility and the coalescence of our towns and cities?
We have to ask why we have green-belt designations. Clearly, we should not designate land as a green belt simply for the sake of it; it should be designated for a purpose, such as to define the limits or setting of a town. In some circumstances, an incursion into the land may be appropriate, because economic or social benefits may flow from it, although we should seek to mitigate any environmental impacts that that may have. The idea that the loss of a piece of green belt should necessarily result in the designation of another area of the exact same size to compensate does not seem to me to be a robust approach, given the aims.
So you think that a quid pro quo is not necessary and you disagree with the point in paragraph 19 that
I am certainly not entirely comfortable with paragraph 19, although I do not want to speculate on how local planning authorities might respond to it.
I envisage the provision acting as something of a constraint, although I am slightly reassured by the fact that it is not overly prescriptive, because it states that consideration "should be given". The consideration might be that the comparison is not like for like. The quid pro quo that Mary Scanlon mentioned would not be appropriate in many situations. Each parcel of land in Scotland is unique, if only because of its location. Therefore, if we develop in one location, we cannot simply say that we must designate green belt in another location. The matter is not as simple as that. To return to Allan Lundmark's point, if that was the case, we would have to question the purpose and function of green-belt designation in the first place. One question that has emerged from this panel and the previous panel is whether the green-belt system is now fit for purpose.
Draft SPP 21 may imply that it would be easier to release green-belt land if land elsewhere was designated.
Not really. Perhaps I was jumping the gun, but that is the issue that I was driving at. At present, if an agricultural business or landowner is within a green belt, they are more constrained than a similar agricultural business or landowner who is beyond the green belt in what one might describe as a truly rural context. As I said, grant assistance is available in all sorts of guises, but particularly through the farm business development scheme, which allows agricultural holdings to be converted for residential letting. That is not simply about diversification of the agricultural business; it is about diversification of the rural economy. Those two issues clearly overlap, but they are different. Some communities that are in a green belt at the conurbation or urban fringe might not be able to adapt, evolve and progress because of their circumstances, but will find themselves in something of a no man's land between the urban context and the rural context, which offer regeneration and other opportunities. In the so-called green belt that lies in the middle, fossilisation of some of the business interests could easily take place.
It might be helpful if you could put in writing how you wish the list of appropriate uses that is given in paragraph 20 to be expanded so that green-belt land could be used not just for agriculture, woodland, horticulture or recreational purposes. That would help us to ensure that the planning policy will be more in line with the existing guidance and will allow for greater diversification by landowners and farmers in the future.
I would be happy to do that.
I have another question for Mr Hall. The term "green belt" conveys an image of an attractive landscape that people like to look at and to have around cities. Is there any risk that the combined effects of lower prices for agricultural produce and the reduction in common agricultural policy subsidies could lead to a situation in which conventional farming in urban-fringe areas may not be entirely viable? Are you aware that there is a possibility that land might be abandoned in such areas, which would create a thistle belt instead of a green belt?
That is a distinct possibility. I am not sure that agricultural activity is viable in any part of Scotland at the moment.
That is a separate story.
You are right—there has been a change in the use of green-belt land in some locations, which has been driven by market forces. Arguably, some of that is the result of the development of rural businesses in the green belt. As one drives around Edinburgh city bypass, one sees that many livery businesses have been set up—there are more horses and stable yards around Edinburgh city bypass than there are cattle, sheep or fields of barley. That trend is simply the result of businesses utilising their locational advantage to the best of their ability. Although that is all well and good, as in all forms of agricultural diversification, there is probably a point at which market saturation will be reached.
The list in draft SPP 21 includes
I imagine that there is such a risk. As well as thistles, there is a lot of ragwort and other plants that none of us particularly cares for spread about the place. If there is an appropriate use for such areas, it should be taken advantage of.
For me, the most important part of draft SPP 21 is the section on development management and appropriate uses in green belts. I am sorry to stay with Jonathon Hall with my question, but I want to tease out what he thinks would be appropriate in that respect. My question is also directed at Michael Levack, who in response to the first question said that we should be clear about what should and should not be permitted. I am not looking for a prescriptive list, but I would value witnesses' input on the matter; after all, we want to find out how the Scottish Executive could make draft SPP 21 clearer.
I am in danger of repeating myself more than anything else. I will go away and give more thought to what we would consider to be appropriate uses in the green belt. We still want to retain the green qualities that were referred to earlier with regard to landscape and amenity value, but not in such a way that we limit business opportunities that should be made available in green belts. I do not think that I can add much more at this stage.
In your response to the consultation document, you seem to say that draft SPP 21 would not allow farm buildings to be used for residential lettings.
That is certainly how I read the document. The list in paragraph 20 does not appear to allow for farm steadings, for example, to be converted into residential lettings. That is not the case in the wider rural context; in fact, the farm business development scheme and other sources provide grant assistance for farm businesses to do exactly that. That contradiction will lead to conurbations being surrounded by a penumbra where the opportunities are much more limited than are those in the sphere beyond it.
The question of how to clarify what might or might not be permissible is certainly difficult and it will not help to take a too-prescriptive approach. For example, John Home Robertson said that the term "green belt" conjures up a certain image. Perhaps that is one of the problems. Do we—or, indeed, members of the public—understand what the green belt is? The perception is that if the land has grass on it, it is green belt, but that is not necessarily the case.
Do we need to focus on what is and what is not allowed when development plans are being drawn up? In your opinion, is that where we need clarity?
Yes. In that way, developers, employers and others who potentially need to build homes, leisure facilities and so on will know what will be allowed. They need a strong guide rather than one that is loose and flexible. Obviously, if they see the development plan being breached, that will set a precedent, but the problem is that we cannot make local authorities scared to make decisions.
People might feel that if the plan is too loose and does not set enough prescription down in black and white, developers will just attack the green-belt areas rather than build on brownfield sites.
People might feel that, but it is, for example, arguable that a golf course is not a blight on the landscape, but that does not mean that the guy whose wee hoose is next door to such a proposed development will want a golf course to be built on what he considers to be green-belt land.
Cathie Craigie referred to developers who "attack the green belt". I do not take issue with that phrase, but we need to consider the nature of that attack. In my experience, attacks on the green belt are rarely attacks on areas of high landscape value. Normally, the pressure comes on areas that are in some way degraded or derelict.
Allan Lundmark mentioned the green-belt designation. However, as has been mentioned already, very few areas in Scotland have been designated as green belts. We need to be careful not to confuse green-belt land with the green space that surrounds developments.
I agree entirely. We have argued elsewhere that there are more robust mechanisms for protecting environmentally sensitive areas that should be protected for positive environmental reasons, or areas that should be protected to safeguard the settings of towns. We tried to encourage the Executive not to approve the green belt that is thrown around Perth in the Perth and Kinross structure plan. Our argument was based on the point that more robust mechanisms are available to the planning system to protect areas that we all agree should be protected.
I do not oppose the protection of green space; I just want equal treatment for all communities, which the Executive says it wants, too. The summary of draft SPP 21 says:
I could not agree more that it is important to focus on that. There are environmental objectives that we should all try to hit. We should have environmental concerns and we should protect such areas because it is in our industries' interests that the environmental quality of our towns and cities be protected so that we can provide developments in quality settings. My concern about green belts is not an argument against strong and robust environmental policies.
Allan Lundmark talked about the growth of the new towns. I lived in a new town; I well remember the master plan in Glenrothes.
I agree up to a point, but I am not sure that I agree 100 per cent that all such growth is unplanned and unmanaged. I concede absolutely that there has been growth in parts of the Lothians and Fife that has been a consequence of the inability to release sufficient development land in Edinburgh and that much of that has to do with issues relating to the green belt. I agree that problems relating to the designation of green belt in Edinburgh have resulted in development in other parts of Scotland that would otherwise not have taken place. For example, many of the planned releases north of the Forth bridgehead were originally designated to plan for growth in Fife's population on a household formation basis. However, the homes have actually been taken up by people from the Edinburgh labour market who cannot afford house prices in Edinburgh and who therefore commute. Undoubtedly, Fife is taking the pressure of the overspill from Edinburgh as well the pressure of its own internal growth. There is also very strong evidence that that is happening in the northern Borders, and it is most certainly happening in East Lothian.
The final sentence of paragraph 12 of draft SPP 21 says:
If we pick the example of Fife—
Why not?
Please do.
The discussions have been steering towards housebuilding and unchecked housing development. However, there are several situations in Fife in which the allowance of retail parks—on land that may not be designated as green belt but perhaps as green space—has been to the detriment of several town centres. It is a question of striking a balance between employment and housing. There is a presumption against development on existing green belts and it is suggested that there may not be significant new green belts, so we return to the master plan of ensuring that there is balance between the housing that local people need and the areas for employment.
Since we are sticking to discussing Fife, particularly the area north of the Forth bridgehead, I should say that it is not just a question of housebuilding; there is also insufficient infrastructure to get people to where they need to be, which is causing some of the greatest pressures in southern Fife. Expansion of housebuilding is not the only issue. Housebuilding in itself would not have been bad if employment was also located north of the river, but as employment is located south of the river, the main problem is creating a sustainable infrastructure. I know that that has nothing to do with the green belt, but it is the major problem.
Does not that tell us that more is at issue than planning policy on the green belt? Infrastructure has to be taken into account in the master plan. There is an inference that existing green-belt land would be released if other land were designated as green belt, but we could flip that over and say that if green-belt land is maintained, we have to allocate sufficient land for housing needs.
There is a problem with releasing sufficient development land for housing need. The inability to open up Edinburgh's green belt for housing need has a direct effect on the quality of life of people in Fife who have to make that dreadful trudge across the river every day.
On that specific example, it could be asked why there is not housing round about the bypass at Gogarburn.
That is because Edinburgh will not offer up its green belt.
We are returning to a theme—
A consensus is developing here.
Yes—it is on a subject with which some members have an obsession.
One of the many roles of the green belt is to safeguard visual and natural amenity. How will that be achieved? Will the safeguarding of visual and natural amenity mean a restriction on the building of wind farms, pylons—[Interruption.] It would not be a meeting of the Communities Committee if I did not mention—
Beauly?
I have to mention the Beauly to Denny power line at some point in every meeting.
My view, which is a personal one, is that green-belt policy should not have anything to do with addressing such major landscape visual impacts.
Thank you.
The checks and balances in other planning provisions ensure that such developments are considered properly to see whether they are in the public interest.
But it is just looking at—
You have had your opportunity to raise your constituency interest today, Mary. I call Patrick Harvie.
I want to pick up on something that Allan Lundmark said a few moments ago. I think that he agreed with Tricia Marwick that there is no reason why the development plan system cannot achieve the objective of protecting green and open spaces. I accept the need to protect those spaces and I accept some of the objectives of draft SPP 21, but am I right in assuming that its provisions will be contingent on the reforms in the Planning etc (Scotland) Bill? I assume that you believe that the new legislation will ensure not only that the development plan system works effectively but that plans will be kept up to date, which is an objective that we all share. Is it your view that we should not abandon or weaken existing tools before the system is working properly?
Yes, absolutely. Mike Levack referred to the fact that designations have to be clear. I hope that none of us would disagree with the statement that no one should build on Arthur's Seat. I said earlier that we need a planning system that identifies land that can be developed to meet development pressures not only for housing but across the board. We do not have such a system at the moment.
The position that you are sketching out is that we should look again at such issues some time down the line, when we know whether we have got the planning system right. Is that correct?
Yes. We have to do that, but it is early days. From my initial reading of the Planning etc (Scotland) Bill and of the discussions that took place on the white paper, the Executive seems to be saying that the planning system should have at its heart how the places in which we live and work look—it is about designing the places of tomorrow. That is about setting clear environmental, social and economic policy objectives. I am reasonably optimistic that many of the issues that are addressed in draft SPP 21 can be addressed more effectively under the new approach to planning that seems to be emerging through the Planning etc (Scotland) Bill.
Gentlemen, we have strayed into a number of areas that do not relate directly to draft SPP 21. If there is anything that we did not cover this morning, this is your chance to tell us about it. We have probably covered everything—and more—that you anticipated.
I hope that we have managed to assist the committee this morning. If there is anything else we can do, we will be more than happy to assist.
Thank you very much.
Meeting suspended.
On resuming—
I welcome our third and final panel this morning. We have been joined by Deryck Irving, who is the senior development officer of Greenspace Scotland; Dr Alastair Macbeth, who is the chairman of Helensburgh green belt group and is representing the Scottish green belts alliance; Douglas Murray, the secretary of the Association of Scottish Community Councils; Helen Todd, the access campaign officer for the Ramblers Association; and David Rice, who is the chairman of Rural Scotland. Thank you all for joining us this morning.
We think that it would be helpful for the Scottish Executive to lay down procedures for reviewing boundaries. As the previous two panels said, draft SPP 21 makes a strong presumption against development in green belts and seeks the avoidance of urban sprawl, the regeneration of towns and cities and long-term certainty. However, one of the problems that emerged during the evidence from the previous panels is that some elements in the draft SPP are not clear and precise, which means that there might be loopholes in how it is implemented. As a result, we think that it would be helpful for the Executive to give clear advice on the review and, in particular, on the 20-year period, which the Scottish green belts alliance thinks should be 30 years. That would show that the Executive is serious about the 20-year period and that it will not be dumped every five years when a development plan is drawn up.
How can we ensure that community councils and representative bodies and organisations are effectively involved in the green-belt boundary review? How should we engage with communities to ensure that they are involved?
Some time ago, I suggested to the Scottish Executive that community councils and other community groups should be given training, help and encouragement to make up their own draft plans for their areas. Those plans could feed into a local authority's planning set-up. Rather than a local authority telling people what it was proposing for their area, local community groups or community councils could come forward first and say what they would prefer to happen; they could try to get the local authorities to get on board or, failing that, give valid reasons why their suggestions were not coherent or applicable—possibly because of infrastructure concerns.
Is there a slightly different approach to the issue? Greenspace might have something to say on this. It is not just a matter of asking people for their opinions—people are often asked for their opinions. Sometimes, those opinions will be taken very seriously and will be reflected in the decisions that are taken, but sometimes they will not. Does Greenspace have any examples of how things could be done differently in order to engage with communities?
That is a difficult question in some ways. Your initial question was about the boundary review. It would be difficult to do it differently. It is a large-scale concept, which covers a fairly wide area if we take the whole of a green belt into account. In such cases, it will probably be community councils and other well-established groups that represent the starting point. For smaller-scale decisions on individual changes, it is possible to start with a different perspective and to work with people in identifying the important issues.
I whole-heartedly endorse Deryck Irving's remarks. He addressed the question specifically in relation to the green belt and illustrated the difficulty of trying to engage effectively with the community on a whole range of planning matters. In my experience, it is much easier for the community to identify with an individual issue that might emerge as a result of a particular planning application. It has been much harder to engage the community effectively with respect to the broader concepts of developing things over a longer period. One of the challenges facing the committee is how to develop the proposed planning legislation in such a way as to involve the community effectively in what are difficult issues.
I do not know whether your officials have circulated to you a document that I provided—it is a buff-coloured document with a cartoon on the front.
No, they have not. You provided it to the clerks only this morning. It is not realistic for papers to be passed to the committee while we are sitting. Perhaps we can reflect on it after today's session.
I fully understand. The clerks encouraged me to bring it along and I would encourage you to have a look at it later. It deals specifically with community involvement and has been produced by a study group that has been examining that issue. Pages 4 to 9 might be of interest to you. I will not weary you with the details at the moment, but I will say that it suggests that there could be some kind of a central body that could assist local communities more than the present one does and that people in those communities need time, expertise and money if they are to be effective. The suggestion is that having local champions who would assist in that regard would be a way forward.
Dr Macbeth and Mr Murray, you have both mentioned the proposed 20-year period for green-belt boundary designation. I wondered how you feel about that time period, particularly given that SPP 21 states:
We in the Scottish green belts alliance feel that there is a need for some feeling of certainty and continuity. The literature on green-belt areas is clear that, without that, there is a tendency for developers to assume that land is always up for grabs, which means that it is always under threat. There can be a greater sense of stability if there is a confidence in a longish period of time.
So you would disagree with the idea that the inner boundaries should be flexible and with the idea in paragraph 24, which says that development should take place if there is an exceptional need. Is that the case?
We think that the statement about not drawing the boundaries too tightly is open to abuse. It is not clear enough. We would agree with the comments that were made earlier by some of the builders, who said that they want to know where they stand. Therefore, we think that that statement should be removed or altered substantially.
Do you not agree that the system must be flexible? Bearing in mind the example of the Royal Bank of Scotland development at Gogarburn, do you agree that planning authorities have to be flexible within the green-belt designation in order to meet needs and demands that cannot be foreseen over a 20-year period?
You are talking about the non-conforming uses element of SPP 21. Certainly, there needs to be clarification. In that section, it has to be made absolutely clear that, where there is a non-conforming use based on existing buildings, that should not be an excuse to go wandering out beyond that area. Doubtless, some of my colleagues, such as David Rice, would have additional comments to make in that regard.
Convener, perhaps I might contribute at this point. There are two points that have just been raised, helpfully, by the member. The first addresses the issue of boundaries. It is perhaps regrettable that the Executive chose the words that it did towards the end of paragraph 16, which states:
Does any of the panel members have views on the use of green belts to prevent the coalescence of urban areas?
That ties in with your previous question. I refer members to the Jackton and Thorntonhall community council submission to the green-belt consultation. It refers to the designation, in 1997, of an area as
The document states:
I see green belts as having a serious role to play in the system. I disagree with ministers when they say that they do not see a need for any additional green belts, or any major green belts.
The document states:
That is what the Executive suggests. Many other areas would like to see the designation of green belts. Whether we are talking about green belt or greenfield goes back to the convener's point. There has to be clarification for the general public of what green belt and greenfield are. As previous witnesses said, the general public identify something with green grass on it as green belt. We need clarity.
How did you reach the view that most communities would want to have designated green belts around them? I am not necessarily sure that that is the case. In many communities, particularly some of our urban communities, green space that has been allowed to go to ruin is often the bane of people's lives. We have to do something with that green space and allow people to use it. There is no point having a piece of land with some trees on it if it does not achieve anything and is not an amenity that people can use. I am not sure that it is accurate to say that most communities in Scotland would want to have green field sites next to them just for the sake of it; they might want other amenities that they can access.
Certainly. I am involved in the green spaces issue. I agree that there are many areas in cities where derelict, brownfield land is just going to waste. There are a number of examples of areas where local authorities are pushing for schemes to use up green spaces, while brownfield sites are sitting derelict and are complete eyesores. In urban areas, people need areas to walk their dog or let their cat out. The green spaces initiatives will help that, but a lot more needs to be built into the system to get the local authorities thinking about their whole strategic approach to the brownfield and green spaces issue. Some local authorities are asking about having an audit of green spaces, which is to be commended, but—
The point is that all that can happen without there being green-belt designation.
It has been suggested that the exclusion of existing major developments inside the green belt could undermine the integrity of the green belt and mean that the controls on expansion are less rigorous. Do any of the witnesses have a view on that?
Where there is an established existing use, such as an airport, there is clearly a danger that any expansion might be thought to undermine the credibility of the continuance of the green belt and to set a precedent for other development, and it might indeed lead to associated development pressures. Those are potentially important national considerations that the Executive would have to take on board in determining its national planning framework. However, in a sense, they should be seen as national exceptions rather than as setting a precedent for subsequent housing or retail development. The need for housing and retail development should properly be met within the context of the development plan system. We should see whether appropriate sites can be identified in existing urban areas or, if that is not possible, at carefully selected sites rather than ride on the back of the opportunism that might be created by a national decision that requires, for example, the expansion of an airport.
I agree that such projects must be regarded as exceptions and must be fully justified. Justification is the nub of much of this discussion. If developers just want to develop something, they should put a thorough case for it with involvement from the public, as distinct from consultation. That goes back to the community issue. Involvement is early and proactive, whereas consultation is late and reactive. There is an important distinction. That ties in with some of the points that we brushed over earlier, such as the avoidance of coalescence. There is a strong feeling that coalescence should be avoided for the sake of community character.
I think other members will want to move on to that issue.
I am sorry.
I also wanted to ask about the list of appropriate uses. You will have heard from the witnesses on earlier panels the suggestion that there is a lack of clarity or an ambiguity in the list and that some uses have not been listed that perhaps should have been. Do any of the panellists have views on the list?
I have a comment about golf courses. Someone mentioned earlier that they are green and look like they are part of the green belt, but in fact they are developments. They can be fine and can add to biodiversity levels. Instead of having monocultural agricultural land, golf courses can be sensitively designed and path networks can be put into them. On the other hand, they can be a huge block to access and can generate many more car journeys in green-belt areas. I would like to see a qualification of that provision in the list.
On the face of it, paragraph 20 of the draft SPP would appear to suggest that the legitimate housing needs of those who are engaged in agriculture and land management might not now be included in the thinking. In the previous 1985 circular, housing on the basis of operational need was accepted as a legitimate development in green belts, and that is fair. This morning, the committee heard evidence about deficiencies in respect of insufficient cross-referencing between the draft policy and other policy documents. There are, of course, questions of farm diversification. My organisation does not wish to be seen as inhibiting farmers and other landowners from legitimately utilising their land resource within the context of its existing condition. We are not saying that Farmer Brown should be able to come along and put in a planning application for 1,200 houses, but we support farmers' management of their holdings of agricultural or woodland properties and their attempts to diversify into other activities, which are being encouraged by the Executive.
I have a question for Helen Todd. Should green-belt land be subject to additional land management requirements?
I am not sure that I am qualified to answer that. The problem with green space that has gone to ruin has been mentioned, and there are many opportunities for farmers to apply for funding under the new agricultural funding system. Certainly, green space brings huge benefits and green belts, by their nature, are near to where people live. Diversification is a new opportunity for farmers. I do not know too much about the common agricultural policy beyond that, I am afraid.
Neither do I.
What is needed is not more land management but positive management. Draft SPP 21 mentions the need for management for public benefit if the green belt is to be something other than a planning tool to prevent urban spread. If it is to provide benefits to communities on the urban fringes and urban dwellers further in, that will require positive management. Mr Home Robertson's point about creating derelict agricultural landscapes within green belts is a real danger. There are confusions in the draft policy about the purpose of the green belt, and that needs to be clarified. Stopping the coalescing of settlements is a valid objective, but it is not listed as an objective of the draft policy, although it is implied in a couple of statements. Paragraph 6 states that two of the key objectives of the green belt policy are
Do you agree with the comments that we heard this morning from other witnesses? They said that the important issue for communities is getting development plans right and that the draft policy is just one piece of the jigsaw.
I agree. One of the views of Greenspace Scotland as an organisation—I perhaps hold it more strongly than my colleagues—is that there is a mismatch between the available tools. Paragraph 7 of draft SPP 21 recognises that the green belt is one of a series of tools, but it has different timescales from some of the other tools and it is applied more rigorously, particularly in Edinburgh.
Thank you very much. That was good evidence, Deryck.
I return to the issue that Mary Scanlon touched on. The final sentence of paragraph 12 of SPP 21 says:
An important point was made once or twice in the earlier panels. The nature of a given green belt must suit the circumstances. There seems to be a danger of generalising about Scotland and all its green belts on the basis of the problems that face Edinburgh. Scotland has about 200,000 hectares of green belt, the majority of which is in the west—especially in the eight authorities in the Glasgow and Clyde valley joint structure plan area, as well as in Ayr and in Argyll and Bute. The falling population in those areas and the considerable areas of dereliction mean that the way in which the green belt operates and is valued can be different from the way in which it operates and is valued in a place such as Edinburgh, where there are specific pressures.
Okay. One of the areas that you have suggested is seeking to create a green belt is St Andrews. I do not represent that area, but I know it because it is in Fife. There are huge problems to do with the shortage of affordable housing in St Andrews and people wanting to live much closer to it. If an effective green belt was created, that would produce the same problems that Edinburgh currently faces, such as people who wish to live there being displaced further away and transport infrastructure problems. Is there not an argument that if we adhere too stringently to restrictions on green-belt development, all we do is to displace problems, particularly with transport infrastructure?
I do not pretend to be able to answer points of detail about the circumstances in St Andrews. One of the points that we made in our report "The Future of Green Belts in Scotland" is that it is wrong to think of green belts as having one shape only—that point has been made before. St Andrews might well require a green belt of a particular type and shape, but I cannot comment on that. I do not know enough about St Andrews or the golf courses that surround it.
We have got to the nub of the matter. Regardless of whether green belts are still thought to have a function and to be desirable to take forward into the future, we must try to secure the effective planning and management of our urban areas.
That was useful.
That concludes our questions. If there any issues that you had hoped would be raised but have not been covered this morning, this is your opportunity to put them on the record.
For the committee's information, the current draft local plan for Perth includes a proposed green belt, but it has also made a land allocation to meet anticipated housing and industrial requirements for the next 20 years, which is not included in the proposed boundary of the green belt. It is possible to work the two together.
A point that has not been adequately discussed, although it has been touched on, is that paragraph 6, on the objectives of the green belt policy, should be expanded to include more of the purposes of green belts. One of the strengths of green belts is that they are multifunctional—they fulfil a range of different objectives in a simple way.
Thank you for your attendance at the committee today. Your evidence has been helpful and it will help to inform our lines of questioning when the minister comes before the committee on 18 January.
Meeting suspended.
On resuming—
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