REMOVING THE SPECIAL PROTECTION OF PRIME QUALITY AGRICULTURAL LAND FROM DEVELOPMENT: DIGEST OF RESPONSES TO CONSULTATION
Individuals
Anthony Ramsay
Executive should not remove the national protection it gives under the planning system to prime quality agricultural land. The greatest value of the planning system is the consistent application of countrywide policies. Protection of prime quality agricultural land protects agricultural and horticultural growing capacity.
Removal of such protection would seriously jeopardise the aim of sustainability in that these categories (1, 2 & 3.1) represent a crucial strategic resource particularly suitable for the growing of grain and root crops. National protection should at the very least be maintained for prime land categories 1 & 2. Another idea would be to establish special "QUANGO" boards to administer the present system of protection to land in categories 1 & 2. I would stress the importance of accessibility to a network of rural paths for walking over farmland within feasible reach of where the bulk of the Scottish population lives.
John Bonington
The proposal to remove protection controls should be resisted because: i) it will greatly increase the development of greenfield sites, especially for residential housing, at the expense of appropriate use of brownfield of restorative schemes; ii) such development will lead to unsustainable pressures on local authority services such as education and transport, core services which are under severe financial pressure; iii) abandoning protection will lead to reduced future capability to become self-sustaining in food production and/or bio-based transport fuel substitutes.
Nick Randall
Whilst farming is in a depressive situation now, in 20 - 30 years we may need prime agricultural land for food. We should preserve land to be self-sufficient if the need arises. The existing system works and is established. Local Authorities are too easily influenced by developers and valuable land could be lost for good. Planning and sustainable development is about thinking ahead in the long term. Building on prime agricultural land would be very short sighted, not complying with aims of sustainability.
Bill Lindsay
Agricultural land is a finite resource and prime land is particularly important in that context. It is, in the longer term, a national asset, which should be subject to a national overview to safeguard the interests of future generations' requirements. These requirements conceivably include a high degree of self-sufficiency in agricultural production and supporting produce for export.
Local authorities will often be under pressure to make judgement in their own interests (e.g. the release of agricultural land for economic or residential development). All local authorities should be subject to the checks and balances that come from the national protection. The status of prime land should form part of any national overview document to be prepared by the Executive - as proposed in the consultation paper on the Review of Strategic Planning.
John Paton
I support the view that the Executive should remove the national protection given to prime quality agricultural land. The reason is that adequate alternative means exist for the protection of such land through the policies of development plans, and in the processing and determining of planning applications.
The removal of national protection for prime quality agricultural land would not seriously affect the Executive's objective of sustainable development because this objective is now a fundamental guiding principle in the Scottish planning system both at national and local level. NPPG 1 sets the key principles towards the goal of sustainable development and forms the overview for the development planning and development control systems.
Christopher Miller
I do not think the national protection to prime agricultural land should be removed. It would seriously affect the Executive's objectives for sustainable development because without this protection the Scottish countryside is likely to be further degraded by unsuitable, unsympathetic and inappropriate development. Until local authorities are able to clearly demonstrate that they can control the design of buildings and halt the suburban sprawl in rural areas, there should be no relaxation of the planning restrictions.
Fiona C Cuthill
There will be a greater need for agricultural land, and especially prime quality land, in the future, due to the over-fishing of the oceans, with the consequent reduction of fish as a food source. As a general principle, it is wiser to have the capacity to be more, rather than less, self-sufficient in food supply.
While it is recognised that it would be beneficial to locate more industry closer to where people live to reduce the volume of commuting to cities, this benefit should be weighed against the loss of large areas of the countryside for recreational pursuits.
Leaving the determination of the appropriate degree of protection of prime agricultural land to local planning authorities would leave the matter to be considered in a purely local context, and monitoring of the cumulative effect of such planning decisions would be purely local. Serious erosion, gradual or otherwise, of Scotland's supply of prime agricultural land could take place without the gravity of the situation being timeously recognised by Parliament. It is considered that all planning applications relative to areas of ten hectares or more of prime agricultural land should be notified to the Minister in order that the situation may be monitored and recorded centrally.
Maurice Checker
Removal from protection of prime agricultural land is a very undesirable prospect. Prime agricultural land is a precious asset. In Scotland it can help to reduce air, sea and land 'miles', also to contribute to the 'organic' demand, 3/4 of which at present comes from abroad with some form of subsidy.
Sourcing food locally, encouraging local interaction and reducing our dependence on foreign trade may become more relevant post 11 September.
Public Bodies
Royal Fine Art Commission for Scotland
The protection of farmed prime agricultural land from irreversible development has in the past been a national concern. It is also acknowledged as a valuable resource in the form of top soil which can take centuries to establish. No indication of the number of hectares of prime quality agricultural land which would be affected by this deregulation is made in the Consultation Paper. The proposal should not go further until the estimate has been made when the first step should be the fullest possible debate amongst all interested bodies.
The removal of adequate protection of prime quality land would seem to be inconsistent with the wider agenda of sustainability. Communities increasingly demand fresh locally grown produce from land managed in an environmentally friendly way. The most accessible areas of prime quality land most suitable to those methods would also in the Commission's experience often be those under pressure for development. The protection of such areas is well understood by the general public and represents an achievement by the planning system which is generally appreciated and supported.
Although Scotland still has hugely extensive reserves of spoiled brownfield land, the Commission would not object in principle to prime quality land 'lying fallow' by being developed not for buildings but for instance as forestry or as a golf course. The Commission concludes that it views this as a retrograde proposal which it is bound to oppose for reasons of long-term sustainability.
SEPA
It is SEPA's view that the protection of prime agricultural land from development should be retained as part of an integrated approach aimed at enabling agricultural extensification. Extensification should be one of the key objectives in promoting more sustainable Scottish agriculture and it is very likely that prime agricultural land would play a key role in enabling extensification to take place. However, there has yet to be a coherent programme for extensification or, indeed, land use more generally, presented by the Executive. Until such time as a programme for extensification is set out in context and the role prime agricultural land would have to play in its implementation understood, it is considered to be premature to withdraw protection from a small and irreplaceable national resource.
SEPA considers that sustainable solutions to Scottish agriculture should focus around extensification to allow enhancement of the natural heritage value of agricultural land and to reduce diffuse pollution from intensive agricultural practices; and diversification in order to enable a vibrant rural economy.
It is recognised that reviving the rural economy requires that appropriate new development takes place which allows diversification. In line with NPPG15 (Rural Development), SEPA supports efforts to enable diversification of agriculture to create alternative income generating opportunities and rural employment where environmentally appropriate. However, it is contested that such development should, where possible, be directed to areas of lower grade agricultural land. Part of rural diversification must also be to capitalise on the opportunities presented by the increase in organic farming and again, if Scotland is to grasp these opportunities then prime agricultural land as a finite resource may well be required to facilitate this.
Removing protection of prime agricultural land may reduce the ability to pursue an effective policy of agricultural extensification in the future. Agricultural extensification is required in order to pursue sustainable development, given the potential environmental consequences of intensive agricultural practice (including soil acidification, diffuse pollution of ground and surface water and habitat loss). Accordingly, SEPA considers that the proposal does affect the Executive's objective of sustainable development.
Health & Safety Executive
Much of the pipeline network of cross country hazardous pipelines in Scotland runs through agricultural land. Developments near to the pipelines are sometimes advised against by HSE because of the dangers to the proposed population. This is but one factor to take into account when freeing up land for development.
All Planning Authorities in Scotland have details from HSE of such pipelines with consultation zones drawn around them indicating where development would be problematical so it should be possible to identify those areas where development may be restricted in the areas described in the consultation paper.
Scottish Natural Heritage
From a strictly natural heritage perspective, SNH would be relatively relaxed about the removal of special protection from prime quality agricultural land. By its very nature such land is usually intensively cultivated and of limited natural heritage interest, supporting little in the way of wildlife or landscape features. From that standpoint it may well be preferable as a location for development to other land of lower agricultural productivity.
There could be some benefits is the release of prime agricultural land for development assisted the diversification of farming businesses or contributed in other ways to sustainable rural development. Similarly, if it permitted new housing to be situated closer to the residents' places of work and other facilities, it could help to reduce travel and the associated emissions.
But there is also a precautionary argument against too readily giving up the country's most flexible agricultural resource when there is so much uncertainty about the planet's future climate and food supplies. In these circumstances, SNH would urge a degree of caution in relaxing the current level of protection, with the quality of agricultural land at stake remaining a valid consideration in the assessment of development proposals. It would then only be released for development if the development in question would deliver clear benefits from a sustainability standpoint which were not achievable to the same extent elsewhere.
Registers of Scotland
No comments.
Environmental Bodies/Interests
The Association for the Protection of Rural Scotland
We strongly oppose the proposal to remove special protection of prime agricultural land. We believe its removal would seriously affect the Executive's objective of sustainable development. The loss of such a valuable asset will indeed affect future generations, the crux of sustainability. We also believe that, without this protection, there will be further unwelcome intrusions into the Scottish countryside.
Much of Scotland's most fertile land lies in the central belt where development pressure is at its greatest. Removing this special protection will surely put the balance of power even more firmly with the developers. We think further encouraging farmers to diversify, for example, by offering incentives for bringing redundant farm buildings back into use, is far more sustainable.
Scottish Wildlife Trust
If prime quality land is lost to development, it can cause a process of displacement of intensification and production onto other agricultural land, which may result in significant environmental losses (eg through hedgerow removal, drainage etc). The proposals for Land Management Contracts (contained in the same Forward Strategy for Scottish Agriculture) bring the prospect of enabling improved biodiversity at all levels of land quality, including the prime quality land areas.
To encourage sustainable development, planning must be able to resist effectively inappropriate development on greenfield land. The key Scottish Executive objective of sustainable development will be damaged if this element of the planning case for minimising greenfield loss were no longer to be available to the planning authorities.
The consultation paper makes only passing reference to the current NPPG guidance to local authorities on the protection of agricultural land, and so is very unclear about what degree of protection would remain at the local authority level. A very powerful message would be sent out by the proposed change, which would make it difficult for any planning case involving agricultural considerations to be sustained.
A key point is that the requirement under consideration is only of notification. If refusal of a case is deemed not to be 'justified on agricultural grounds alone', then the Minister can simply permit the development. There is ample scope for ensuring that the decision regime is in tune with current realities without changing the notification system. It is noted that no such notification cases have arisen in the past five years, with any potential cases being resolved at local level. This fact argues for leaving the system as it is, not for changing it. The current arrangements may be having a useful overall influence for sustainable development and land-use without creating any work for Ministers or undue delay to the development process.
Edinburgh Green Belt Trust
The Trust recognises that the provision of protection for prime quality agricultural land by current planning policy should be reviewed. Although originally justified on agricultural and food production grounds, it is the case that this blanket national protection has prevented inappropriate development within areas that often possess special landscape and environmental qualities. If a relaxation of current policy is to occur, this must take place only when accompanied by measures to strengthen the protection of existing and new designated and special areas, such as greenbelts, combined with improvements to the enforcement of that protection.
Inevitably, a relaxation or removal of the blanket protection of prime quality agricultural land will substantially increase the pressure for the development of greenfield sites, especially around the fringe of urban areas. Any future development should be appropriate in a rural context and measured against stringent criteria such as environmental impact, the scale of development and the level of infrastructural support. Although the removal of a blanket national protection will allow a degree of local flexibility in decision making, it will create a fragmentation of policy and decision making across the country. It will become increasingly difficult for local planning authorities to defend individual planning application decisions when challenged by developers using precedents set elsewhere.
With regard to sustainability it should be recognised that prime quality agricultural land is a limited and non-renewable resource which once lost to development cannot be recovered. Although many agricultural products are currently in surplus this is likely not be the case in the future. Factors such as global warming and the much needed development of more sustainable farming practices suggest that such simple assumptions regarding the future demand for agricultural land and food production cannot be so easily made. The Trust would wish to reserve its judgement until more detailed proposals are put forward.
The St Andrews Green Belt Forum
Few, if any, reasons are presented in detail in the document to justify what amounts to a radical shift in policy towards short-termism. Insufficient thought has been given to the possible consequences of an increase in the less intensive use of agricultural land, for example, through the increased adoption of organic farming methods. Although some agricultural products may be in surplus at the present time, this situation may be a temporary phenomenon. The Scottish Executive's objective of sustainability must surely involve the reduction of 'food miles', and this in turn implies an increased emphasis on the local production of food.
A further factor to be considered is the possibility of climate changes involving higher average temperatures. This would lead to a greater diversification in the types of foodstuff which could be grown in the various regions of Scotland, and would bring into play agricultural land which appears surplus to present requirements.
The Executive should not remove the national protection it gives under the planning system to prime quality agricultural land. The removal of this protection would seriously undermine the Executive's objective of sustainable development.
Woodland Trust Scotland
We would like to see the focus shifted from development to the variety of other uses that prime agricultural land could be put to such as new habitat creation, especially native woodland expansion. Woodland is a true multi-use activity contributing to every aspect of sustainable development - environmental, social and economic. Native woodland creation would provide opportunities to place bordering semi-natural habitats on a more sustainable footing and would provide a valuable resource for informal recreation for local communities, as well as potentially providing some economic benefits.
We would also like to see recognition in this paper of the impact that developing prime agricultural land might have on ancient and semi-natural woodland and other semi-natural habitats. Although it is far from ideal for intensively farmed land to border onto semi-natural habitats, this situation would not be improved by developing this land. The Woodland Trust Scotland strongly believes that any land that comes out of agricultural production that is adjacent to ancient or semi-natural woodland should be given over to natural habitat creation rather than development.
Protection for prime agricultural land from development should be maintained, not on agricultural grounds alone, but on the grounds that this land could in future be turned over to valuable habitat creation. We would like to see Executive policy on this land shifted away from maximising agricultural production and towards recognising the potential contribution that it has to make to sustainable development by helping to protect the environment.
Central Scotland Countryside Trust
CSCT recognises the need to diversify the rural economy in order to sustain family-run farms/businesses and the wider rural population. We agree that there should be more scope within the Planning framework to allow sensitively planned development initiatives which would assist the broadening and diversification of the rural economy. However, it is the opinion of CSCT that the size of the developments on prime agricultural land from which special planning protection would be lifted (i.e. 10 hectares or more) would lead to the type of large scale development better suited to existing settlements, and that this would to some extent occur at the expense of genuinely sustainable, long term rural development. We do not believe the Executive should remove the requirement to consult on a change of use of 10 hectares or more of prime agricultural land.
Removal of special planning protection from prime quality agricultural land would seriously affect the Executive's objective of sustainable development. Large scale industrial and residential development in areas formerly of rural landscape character, would lead to reduced attractiveness of landscapes for sustainable tourism and recreation. There would be a reduced incentive to develop sites within existing settlements and a possible increase in long commuting journeys by car.
There would be a reduced area of prime quality agricultural land for the re-structuring of agriculture to suit current and future markets and a reduced capacity for national self-sufficiency in the long term future. Irreversible development of prime quality land would affect this capacity over generations.
Community Groups
The Church of Scotland General Trustees
The General Trustees are opposed to your proposal to remove special protection from prime quality agricultural land. The percentage of prime quality agricultural land in Scotland is very small and should therefore be preserved. If such land is developed then it will not revert in the future to being prime quality agricultural land should the need for development cease or should the need for good agricultural land increase. While at this time there may be a surplus of some agricultural products, this situation could change.
The Scottish Civic Trust
The Trust wish to strongly object to this proposal. There was wide-scale disappointment that support for organic farming practices did not have greater emphasis in the FMD recovery programme outlined by the Executive. Such practices tend to have a larger "land demand" than current practices as management practices such as crop rotation demand more space to run a farm unit. Consumer demand for organically produced products is also growing, underlining a general dissatisfaction with some of the current practices.
Much of Scotland's class 1, 2 and 3.1 grade land is concentrated in areas that have higher development pressures placed on them. Other policies such as Green Belt designation do not offer the protection from development required as the experience from many Public Local Inquiries demonstrates. There is more than enough evidence to show that the strategic housing land supply will be given greater priority in decision-making that the protection of the green belt or countryside.
The Ferryhill Heritage Society
Our response is as follows: Q1 - No; Q2 - The Green Belt is so important. Infrastructure requires to be in place before sustainable development gets the go ahead. We feel that building on such sites as the Macaulay Land Research Institute in Aberdeen and the proposals for the Kingswell's Green Belt is inappropriate and should be discouraged.
Colinton Amenity Association
The Scottish Executive should not remove the national protection it gives under the planning system to prime agricultural land. Rather, the Executive should amend the current policy set out in Circular 18/1987 as amended by Circular 25/1994.
The removal of national protection for prime quality agricultural land would seriously affect the Executive's objective of sustainable development. Prime quality agricultural land is a non-renewable resource. As such, it should be used wisely and sparingly, at a rate which does not restrict the options of future generations. Demand for prime quality agricultural land may not be confined to built development as there may be alternative uses such as carbon sink forestry that could have higher environmental priorities relative to global warming.
A blanket removal of the protection of prime agricultural land under the Planning Acts could be seen as giving Planning Authorities 'carte blanche' to disregard its unique qualities and lead to increased pressure for the development of greenfield sites, especially within Green Belts where demand for land for development is already intense. The precautionary principle should be adopted by making present policies more flexible without totally removing the protection for such land. The CAA considers that it is essential that the Executive continues to monitor the use and levels of prime agricultural land in a comprehensive system that also accounts for activities outwith planning control.
West End Community Council, Dundee
We do not support the removal of the blanket national protection. There is a clear requirement to have a Scottish wide approach to the protection of a national resource. Plus there are ways in which prime agricultural land can be built upon as at present. The fact that no cases have been brought to Ministers in the past five years is irrelevant.
It is clear that sustainability is about the management of resources to ensure that we do not undermine future generations. Allowing the decisions to be taken locally will remove the ability to control the loss of prime land. This approach cannot be considered sustainable. The present protection and strengthening of existing settlements as outlined in NPPG 3 is fine and the proposals to remove prime agricultural land protection will undermine NPPG 3.
Kilmadock Community Council
The removal of national protection of prime agricultural land will provide flexibility in determining the nature and scope of future development in the countryside - a major factor that has previously contributed to the decline of rural communities.
With the likelihood that tourism and other rural activities will become more important to the Scottish economy coupled with the belief that traditional agricultural activities will continue to decline or diversify it is important to remove unfavourable planning controls in order to enable investment to be made in the rural economy.
Landowners/Managers
Kincardine Estate
The proposal to give the power to determine the use of such land to Local Authorities removes any national strategic overview and empowers Local Authorities to make development decisions without consideration of national issues.
The case is made in the paper for removing protection because we have food surpluses. The proposal is bowing to short term expediency and ignoring long term implications. Prime quality agricultural land currently seems to be less important because we import so much food and grow surpluses. The recent and rapid turnabout in global stability following the terrorist attacks on New York demonstrates how fragile the situation is. Political unrest or a global emergency may give rise to extreme need to grow food domestically. Prime quality agricultural land is obviously the best and most productive land to use for food production.
Dependency on intensive farming techniques which produces surpluses or on importation is not compatible with the Executive's stated objective (paragraph 10) of sustainable development. Changes, in the form of greater domestic production to reduce imports or extensification to reduce damaging intensive agricultural practices both will require more land to be used. In the meantime prime quality agricultural land, if not required for food production, is able to produce bio-feedstocks or energy crops to support sustainable development. This 'rural diversification' has the advantage of supporting the rural economy while retaining the land for re-use for agriculture should the global or national situation demand it.
Halliday Fraser Munro (on behalf of Dunalastair Estates Group)
Given the state of the agricultural industry it is considered that the Executive must remove the protection which it currently gives to prime quality agricultural land from development. Such a proposal would provide opportunities for landowners and those involved in the agricultural industry to diversify into other income generating businesses. The removal of the national protection would not affect the Executive's objective of sustainable development. It must be recognised that all land, whether or not of 'prime quality' would still be protected by other designations e.g Green Belt, Countryside and AGLV policies. Consequently it is unlikely that a significant proportion would be developed in an irreversible nature.
Arbuthnott Estate
Protection should be removed from all land, particularly land graded 3.1. There are other safeguards in place to ensure sustainable development - for example the requirement to publish Local Authority Plans for public consultation. It would give land managers much more flexibility in their businesses and make land-based industries more secure. The loss of larger areas of land is protected by the 10 hectare rule anyway.
Scottish Landowners' Federation
The SLF membership is not entirely unanimous in its opinion on this matter. SLF considers that the 'presumption against' must be maintained, as this does allow for appropriate development in the public interest.
Action 35 of A Forward Strategy for Scottish Agriculture has prompted the consultation on this proposal. However, the SLF remains at a loss as to how such a proposal will allow 'farming' to develop as an integral part of rural development. If subjected to 'irreversible development', those farming businesses 'diversifying' to such an extent will no longer exist and could be effectively removed as engines of growth and employment in a rural economy. The productive potential and its extremely limited availability ensure that prime agricultural land in Scotland has a highly significant and unquantifiable opportunity cost. The SLF consider that the arguments pertaining to agricultural surpluses and the need to encourage the diversification of the rural economy are essentially flawed.
The arable, vegetable and horticultural crops grown on land of Class 1, 2 and 3.1 are imported in vast quantities. Therefore, there is an opportunity to fully utilise this prime agricultural land as a means by which farming business can remain viable and competitive, both domestically and internationally. Local environmental costs would be matched by more global environmental concerns surrounding 'food miles'. The loss of prime agricultural land would increase reliance on imports and undermine local production.
Despite the reservations above, the SLF also recognises that the existing policy does employ a 'presumption against' approach. Circular 18/1987, as amended by Circular 25/1994, states that the best and most versatile land should not be built on unless there is no other site for the purpose. The SLF could accept the removal of the special protection of prime agricultural land from development so long as these Circulars were fully adhered to. The SLF also remains content that the 10 hectare criteria currently in operation would act as a further safeguard. In reality the best quality agricultural land is not the subject of blanket national protection. Local authorities already have the flexibility to determine for themselves whether such land should be used for new development, so long as they adhere to Circular 25/1994 and the principles of NPPG 15.
As a safeguard against inconsistent and inappropriate irreversible development on such an extremely limited or finite resource, the proposals ought to be rejected. There is a need for local authorities to consult the Scottish Executive on applications for planning permission of best agricultural land and there is a need for local authorities to adhere to the requirements of notification to Scottish Ministers. Contrary to the proposal to remove the protection that the planning system gives to such land, the SLF considers that this scarce resource requires security from uncontrolled development.
Social/Cultural Bodies
Council for Scottish Archaeology
Agricultural land is poorly protected from damage or even destruction from current agricultural activities. Even monuments considered as being at the highest national importance and protected by law, Scheduled Ancient Monuments, are still being damaged because existing legislation allows damaging agricultural activity to continue on these sites. Planning Advice offers archaeological remains not on agricultural land greater protection than that offered to those under agricultural management.
There is no onus on the farming community to prevent such damage occurring, except for the small percentage of sites theoretically protected as Scheduled Ancient Monuments. This situation is anomalous as new legislation being discussed by the Scottish Executive proposes that uncultivated land being brought into cultivation should be subject to environmental impact assessment. Similar conditions already apply to land proposed for or under existing forestry management.
It does not seem legitimate that prime agricultural land should be automatically excluded from development, when all other categories of land are subject to the development control process. Removing this protection from prime agricultural land will not significantly harm the archaeological resource and indeed may offer greater protection to archaeological sites in the longer term.
The Scottish Rights of Way and Access Society
We feel that there are many dangers in removing the blanket protection from development which prime quality land receives at present. Many public rights of way pass through land of this type and these routes, which often lead to longer routes into the countryside, are very likely to be in danger of being lost if constraints on development are removed.
If the special protection is removed from this prime land, we would like to see specific mention of Rights of Way and other Access Routes made in paragraph 10 in 'Relevant planning policies and wider Executive objectives would still have to be taken into account."
The Architectural Heritage Society of Scotland
The Architectural Heritage Society of Scotland objects to the proposal outright. If there is concern that protection is inappropriate as agricultural policy, we would ask that it be re-named as a sustainable policy, and its terms can then be fully justified.
Statutory protection does not preclude the possibility of appropriate development on prime land, but it does address the conflicts inherent in managing a sustainable economy through maintaining a presumption against development that impacts negatively on the nation's limited social, natural and cultural resources. Scotland's best land is concentrated in the areas subject at present to the highest development pressures, and it is unreasonable to imagine that without dedicated protection, ordinary considerations will ensure proper management. Removing such protection, and opening up ordinary access to such land for development, will contradict the priorities identified in by the Scottish Executive in NPPG 1 p3 as being supportive of sustainable development. While the Society recognises that the statutory protection of prime land is not a mechanism developed for the promotion of sustainable development itself, it does function as a key tool in managing development within sustainable objectives.
The suggestion in para. 8 of the consultation document that there is no longer a need for the quantity of agricultural land that receives statutory protection is founded on a misunderstanding of the economic pressures to which agricultural land is subject. The industrial style of farming that characterises modern agricultural practice is not a sustainable process, as recent events have testified, and Scotland must at least keep its doors open to the opportunities offered by cleaner, greener and, in the understanding of the international public, more appropriately Scottish, agricultural practices.
Finally, the removal of such protection would further impede access to rural and agricultural environments by the urban public as a whole, and could only be considered to be a further impediment to the attainment of social equity in Scotland.
The Cockburn Association
The Association does not agree that the Special Protection should be removed from Prime Agricultural Land. Of the present Edinburgh Green Belt area, nearly two thirds is agriculture. Approaches to farm owners from major housebuilders are common. These offer sale contracts for land won for development in boundary adjustment challenges to Local Plans.
Land stripped of its natural topsoil for development will, if left, repair an replace itself and its microflora and fauna, at a rate of 20mm every 100 years - a rate so slow as to make our deep productive Class 1, 2 & 3 topsoils effectively non-renewable. We have noted how much of Edinburgh's Green Belt has been lost to development over fifty years, in spite of the assumed productive value of its topsoil.
Farming/Agricultural Bodies
Scottish Crofting Foundation
The Scottish Crofting Foundation does not believe that it would be in the interests of sustainable development to remove planning protection from this land. We do not believe that this land would be adequately safeguarded through local authority planning controls.
Although it may often be the case that the best land is situated in areas where pressures for development exist, we believe that it would be very short-sighted to develop on and jeopardise the future use of this limited resource. To irretrievably remove our most productive and versatile land from food production for short-term economic gain or to counteract over-productivity and surpluses brought about by a short-term subsidy regime cannot possibly be in the best interests of those generations to come. Furthermore, some of our best agricultural land is situated on flood plains and with severe flood events on a more regular basis predicted as the climate changes, there is a particularly strong justification for avoiding all development on flood plains.
Also of direct relevance to sustainable development is the concept of food-miles; it cannot be best use of our limited resources to import food from abroad or indeed haul it long distances throughout the country if we have the potential to produce it ourselves and distribute it as locally as possible. We urge the Executive to look at all the aspects of the supply chain to determine where improvements can be made to the distance that food travels to reach shops and to support and encourage the local sourcing of produce.
The Macaulay Institute
The current protection of prime quality agricultural land against development under the planning system should be retained. The current system provides a national framework, which is well understood by all, guides the development of structure plans by Local Authorities and creates a framework for developers in considering their proposals. The regulation provides a national perspective in relation to land development, which is of particular importance in relation to questions of sustainability. This is a key factor in dealing with the protection of a valuable national resource, which is distributed unevenly across the country.
No consideration appears to have been given either here or in the Forward Strategy for Agriculture to alternative approaches, e.g. tightening the regulation, creating geographic areas of exemption, altering the classes of land incorporated within the regulation or even the range of activities to be permitted in former agricultural land.
The proposed removal of the protection of prime quality agricultural land seriously compromises the Executive's objective of sustainable development. It is our view that the maintenance of natural capital is a key component of sustainability and given that development frequently involves irreversible change we find it difficult to balance this with any definition of sustainability.
Although, at the moment, many agricultural crops are in surplus, the Executive must take a longer-term view in relation to food security. It is becoming clear that profound changes are taking place both in terms of production systems (e.g. organic production) as well as the biophysical environment (e.g. global climate change) and there are significant uncertainties about the effects of these changes in the UK. Two further factors that may impact on the land required for crop production must also be considered. The first of these is a market-led demand for products grown under less intensive conditions (e.g. organic production), which will require greater land area to produce similar quantities of food. The second is the issue of 'food-miles' where it has been argued that long supply chains are not sustainable and in future there may be a return to locally produced food supplies. In these circumstances it is important that we retain flexibility in the future use of our land resource.
There is general support for the Executive's desire to diversify the rural economy but it not certain that this change will contribute to rural diversification. The location of prime quality land does not appear to have been explored in this proposal. However, it is likely that the proposed change will impact most strongly on land close to existing urban centres and developed areas. By definition, prime quality land is the most flexible land in Scotland, i.e. it will support a wide range of agricultural enterprises, thus, diversification in the agricultural sector would be best served by retaining the presumption against development. In our view, the removal of controls on prime quality land will make the brownfield option significantly less attractive and will tend to undermine what has been achieved in this area.
Finally it is important to recognise the range of functions carried out by soil. Whilst the present guidelines are not designed to protect these functions explicitly, they do help to maintain a balance in relation to the range of current land uses across Scotland and help maintain the wide range of soil functions for the future.
NFU Scotland
Farm business restructuring can involve new business development by farmers possibly involving disposal of farmland to developers. As well as manufacturing and services activities which could use redundant farm buildings, options can include forestry and housing, depending on location and site-specific factors.
This consultation relates to possible future planning policy, yet the issue has arisen in the context of the "Forward Strategy for Agriculture" reviewing the priorities and direction of Scottish agriculture in the light of the current economic difficulties faced by the industry. Many farmers on prime quality land may be better placed to withstand such difficulties compared to those whose land is less productive. At the same time much of prime quality land is close to east coast settlements and can come under other pressures associated with urban areas. There are, therefore, good reasons both for retaining this grade of land in agricultural production but also letting it go for development.
On balance, NFUS believes that the answer to the first question should be a qualified yes. The national protection given to prime quality agricultural land should be removed. However, specific directions in NPPGs and Circulars should be given to local authorities within which they would be given flexibility to determine whether such land should be used for new development.
If the appropriate guidance referred to above were observed, part of what is perceived by some as a national asset could be preserved. At the same time, where agricultural grounds no longer justify special protection, relaxation of controls could help to secure delivery of relevant planning policies and the wider objectives of sustainable development.
Academics
Madhu Satsangi, Edinburgh College of Art/Heriot-Watt University
I fully support the Executive's proposal to remove national protection under the planning system to prime quality agricultural land. That protection, in my view, belongs to a now bygone era and is not warranted given the nature of rural economies across the country and the opportunities and difficulties that they face. There is a view that removal of national protection would be helpful in allowing rural communities to deal with affordable housing shortages. Such developments should be considered at the local level and local authorities and their partners should have flexibility to make the land-use determinations that best fit their current and future circumstances. Having national protection for prime quality agricultural land conflicts with this flexibility and local autonomy.
The Executive's objective of sustainable development will largely be delivered through what happens at the local scale. In making land-use decisions, planning authorities will need to be mindful of the extent to which sustainable development criteria are enhanced or undermined. As long as a proper procedure is adhered to, I do not see that removal of national protection would hinder achieving sustainable development goals.
Dr Jeremy Raemakers, Edinburgh College of Art/Heriot-Watt University
I am cautious about this. This is not England, where there is an abundance of arable land, and protection has already been removed by the English rural white paper. I think that to take such a step you have to be very certain of the future. Crops are in surplus within the EU's CAP, and in some cases within the UK, but how self-sufficient is Scotland? I would want to see the figures about the current position and some future scenarios.
The complaints from farmers have been that it is local planning authorities, rather than the agriculture department, which have held back diversification. Research has actually found little hard evidence of it, and besides the Executive has taken steps to counter it through planning guidelines and advice to farmers on dealing with the planning regime.
We were reminded twice last century and now once this century of what a politically and economically uncertain world we inhabit. Add to that the uncertainties about the biophysical resource and I vote for safeguarding this natural asset. Its loss would be irreversible on a timescale of decades and the precautionary principle of sustainability says don't trade it away.
Other
Scottish Enterprise Lanarkshire
It would seem sensible to remove the national protection given to prime agricultural land. This removal would probably not seriously affect the Executive's objective of Sustainable Development.
The mixed rural landscape in West Central Scotland faces a number of problems. In these areas agricultural land is often underused or abandoned and when combined with the extent of derelict land and other land uses, such as mineral extraction, it creates a very poor quality of landscape. Such landscapes are then subject to inappropriate development pressures and are not managed in a sustainable manner. The blanket protection of such land is not always helpful to the development of sustainable solutions.
If farmers cannot manage the landscape and there is no overriding national need in terms of food production then the planning system should be flexible enough to enable other appropriate and sustainable landuses e.g native woodlands, low density low impact housing (Lowland Crofting) or energy crops for renewable energy schemes.
Ayrshire Joint Structure Plan & Transportation Committee
In Ayrshire, the Joint Structure Plan not only protects prime agricultural land but goes further and safeguards 3.2 grade land which is important in terms of crop yields to the dairy economy of Ayrshire. The structure plan also gives protection to in-bye and sensitive hill grazing land in the upland areas and recognises the wider role that managing the soil resource has to promoting the principles of sustainable development.
The recent State of the Environment Soil Quality Report by SEPA has highlighted the importance of the soil resource within Scotland. Soil is essentially a non-renewable resource increasingly under pressure. It supports the agricultural and forestry upon which an economy such as Ayrshire is based. It also helps protect the environment by acting as a "sink" or buffer for may contaminants thus protecting water and air from pollution. The sustainable use of this resource is therefore critical to maintaining these functions.
There would seem to be a strong case for suggesting that until national soil protection strategy is in place any redefinition of a future context for agricultural land practice change is premature. A soil protection strategy would establish a framework within which this proposal can be more properly considered and address the protection of the soil resource in a way consistent with sustainable objectives.
Scottish Liberal Democrats
The Scottish Liberal Democrats are concerned that over-intensive farming practices may not prove popular in the long term and that lower-intensity and organic farming may become dominant. In this case there will be a need to use prime agricultural land to make sure that suitable quantity of produce can be achieved. If prime quality land were removed from agricultural use, then lower-intensity farming methods would be burdened with an additional problem of having to be sustained on less favourable ground.
It is suggested that diversification of the rural economy should be focussed on land that is not prime quality and that a national protection should remain in force to reduce the opportunity for prime land to be permanently withdrawn from use by a local authority.