Draft Scottish Planning Policy 21: Green Belts: Analysis of Consultation Responses

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Outline of the responses

1. The consultation on draft Scottish Planning Policy 21: Green Belts attracted 173 responses from a wide range of groups, individuals and organisations. This is a lot more than other recent SPP consultations such as SPP15: Rural Development.

2. It is worth making the point right away that comments across the range of respondents support many of the draft SPP's key elements. That the Scottish Executive should now take steps to renew and clarify this longstanding policy instrument is welcomed almost unanimously, even though there are different views on whether ideas about its limitations are being carried too far or not far enough. And there is remarkable agreement from different kinds of respondent about large parts of the document. There is a gap of course between greater clarity and permanence and the inviolability sought by some.

3. Beyond this, there is a focus on boundary treatment, release mechanisms, consistency between one area and another, and the scope for greater use of the green belt as a well-understood way to meet similar objectives around smaller settlements.

4. As ever, the devil is in the detail. Operating close to the issues, some respondents in the development, community and planning fields feel that greater clarity will be needed to guide them over the uncertainties. Others want a greater emphasis on quality and design. Others want closer integration between green belt policy and other Scottish planning policies. Before we explore these views further, we can look more closely at the different sources of the responses received.

Origin of responses

5. Responses come from a wide range of interests and can be grouped into these categories:

Number of responses

Individual (some with more than one per response)

81

Planning & national park authorities & joint plan teams

24

Environment & heritage groups

20

Community councils

16

Businesses & developers

12

Planning and related professionals

11

National & regional agencies

8

Other

1

TOTAL

173

Roughly half of the responses (85) were submitted in a standard form suggested by the Scottish Green Belt Alliance and of these the vast majority come from individuals (75 responses). Standard responses also make up just over half of the responses from Community Councils (9). One standard response is from an environment and heritage group.

Individuals

6. As the table shows, the consultation attracted a strong return of 81 responses from individual members of the public. 75 of these responses have been made in the standard form suggested by the Scottish Green Belt Alliance, with occasional additions or deletions. Responses from individuals come almost exclusively from areas with an existing green belt, with clusters of responses from Ayr, Helensburgh and the Clydebank / Dalmuir area west of Glasgow. There is little response from individuals in Edinburgh (2) or green belt areas in central Scotland, and a low response in Aberdeen (4).

Planning authorities, national parks, joint plan teams

7. 22 of Scotland's 32 local authorities have responded to the consultation. The local authorities that currently contain green belts are well represented, but responses have also been received from authorities without green belts such as Angus and Shetland. Both the Glasgow and Clyde Valley and Ayrshire joint structure plan joint committees have responded to the consultation.

Environment & heritage groups

8. The responses from environment and heritage groups can be arranged in three broad strands. Just under half come from local groups associated with a particular geographical area and covering a variety of environmental and heritage interests (e.g Inveresk Village Society, Moray Friends of the Earth). A similar number are from groups with a specific green belt focus like the Scottish Green Belt Alliance and the Helensburgh Green Belt Group. A smaller number of responses come from national organisations like The Scottish Civic Trust and the Ramblers' Association.

Community councils

9. Over 15 community councils have responded to the consultation. They are predominantly from communities in existing green belts and more than half the responses have been submitted in the standard form suggested by the Scottish Green Belt Alliance.

Planning and related professionals

10. Just under half of the responses in this category are from professional associations such as the Royal Incorporation of Architects in Scotland and the Royal Town Planning Institute in Scotland), but planning consultants are also well represented. Two chartered town planners respond individually to the consultation.

Business & developers

11. Housebuilders account for most of the responses in this category. The rest come from what could be described as trade-related groups or organisations such as the British Holiday & Home Parks Association Ltd. An estates-related response from Glasgow University is also included here.

National & regional agencies

12. Responses have been submitted by a number of national and regional agencies with policy remits closely related to the issue of green belts like SportScotland and Scottish Natural Heritage, or to urban form like Architecture+Design Scotland. This category also includes two departments of the Scottish Executive who have responded internally to the consultation.

Other

13. One response, from the Brethren's Gospel Trusts (a religious organisation), does not fit easily into the above categories.

Spread of responses

Spread of responses image

14. The graph above counts the number of responses containing a comment relevant to each sub section of the draft SPP. Nearly all responses have something to say about the SPP objectives, but there is also a good deal of comment about boundaries, timeframes and uses in the green belt.

15. The graphs below, drawn from the above data, show how the responses relate to the various sections of the SPP. The first includes the standard responses and indicates that comments from individuals and community councils were more likely to concentrate on the role and function of green belts and development planning issues. The second omits the standard responses and demonstrates that the other responses showed more interest in the earlier part of the draft SPP about managing the growth of towns and cities. A statistical breakdown of these by respondent type is provided below at the start of each section.

Responses by section (all) image

Responses by section (non-standard only) image

Page updated: Monday, April 24, 2006