Issue 2.2 The Green Belt and Related Designations The Green Belt and Related Development Reporter: [Note: For DPEA Designations (pages 12 – 14, Plan reference: use only.] paragraphs 3.1 – 3.9) Body or person(s) submitting a representation raising the issue (including reference number):

Avant Homes () Ltd (032238) Juniper Green Community Council CALA Management Ltd (929806) (028859) Cockburn Association (037249) Liberton and District Community Council Community Council (790396) (040316) Mactaggart and Mickel Homes (038949) and Barnton Community Mr Mike Martin (798523) Council (803443) Mrs Mirabelle Maslin (928549) Damhead and District Community D and L McAuslan (040611) Council (039328) Green Party (778339) Association of Community NHS Lothian Public Health and Health Councils (040476) Policy (840024) Esk Valley Trust (037349) Prestonpans Community Council Eskbank and Newbattle Community (039835) Council (891202) Rosewell and District Community Friends of the River Almond Walkway Council (790523) (925870) Roslin and Bilston Community Council Gladman Scotland (783418) (790524) Grange and Prestonfield Community Scottish National Parks Strategy Project Council (790304) (930044) Mr Jon Grounsell (786916) Scottish Natural Heritage (790587) Gullane Area Community Council Scottish Wildlife Trust (038549) (037068) sportscotland (029346) H and H Group Plc (927998) Mr Charles Strang (907037)

Provision of the The Spatial Strategy – Green Belts and Development Plan to which countryside. the issue relates: Planning Authority’s summary of the representation(s):

Avant Homes (Scotland) Ltd (032238) Consider that the approach in the Midlothian Proposed Local Development Plan (LDP) conflicts with the Proposed Plan as it identifies land as green belt which is not identified in Figure 3.2. Need to provide more explicit guidance to LDPs to ensure that the location of green belts is properly interpreted. Support approach to strategic growth and recognition of the growth potential of Eskbank.

CALA Management Ltd (929806) Prevention of coalescence is not a function of green belt as set out in Scottish Planning Policy (SPP) paragraph 49 and should be deleted.

Cockburn Association (037249) Growth on the scale envisaged for Edinburgh, will severely damage its green belt. Allowing development in the green belt creates windfall gains in land values which will accrue to landowners and developers, and amenity benefits to house purchasers, at the expense of losses in amenity to the wider community and in public value. Green belt development also fails to increase the supply of affordable housing where the main pressures and shortages occur. The degree of protection for the green belt residue is not specified. The green belt should be maintained to enhance the amenity and landscape of the area around the city, to sustain the natural environment, and to preserve the natural boundaries and context of the city and prevent coalescence with neighbouring communities. A robust mechanism must be implemented to protect green belt ‘residues’ in perpetuity.

Corstorphine Community Council (040316) There is a conflict between paragraph 3.8 and paragraph 5.17 on maintaining the green belt and enhanced green networks and paragraph 3.4 which directs LDPs to release land including from the green belt. Long term growth corridors in West Edinburgh are also covered by the Edinburgh and West Strategic Green Network Priority Area. Development that incorporates green belt or other parts of the green network will fracture such green networks, leading to isolated green pockets / wedges.

Cramond and Barnton Community Council (803443) Support proposals for a strong and extensive green belt around Edinburgh. The challenge will be to adequately protect the values of the green belt to prevent further erosion.

Cramond and Barnton Community Council (803443), Friends of the River Almond Walkway (925870) Concerned that the City of Edinburgh Council will fail to protect the green belt under pressure from developers, as has been the case in North and West Edinburgh throughout period of Strategic Development Plan (SDP) 1.

Damhead and District Community Council (039328) The A701 relief road is contrary to this policy position.

Edinburgh Association of Community Councils (040476), Grange and Prestonfield Community Council (790304) There should be no direction to release land from the green belt (paragraph 3.4) without at the same time providing land of green belt / open space / green network designation of equal or better quality to that lost.

Esk Valley Trust (037349) Welcome the retention of the green belt as a major positive element in the landscape and in protecting the amenity of places to live and places to work. Green belt release must be resisted.

Eskbank and Newbattle Community Council (891202) There is no indication as to why LDPs are directed to release land in the green belt in paragraph 3.4. The principle that green belts will be secured to maintain identity, character and landscape, etc in paragraph 3.8 is very positive.

Gladman Scotland (783418) Concerned that paragraph 3.1 on green belts does not emphasise clearly enough that green belts, whilst being important tools for the control of development, are not sacrosanct and should be monitored and managed in the same way as any other planning land-use designation or policy tool as set out in SPP.

Mr Jon Grounsell (786916) Disagree with emphasis on green networks and growth corridors building through the green belt.

Gullane Area Community Council (037068) It is essential that the countryside around towns policy, conservation area designations and enhanced green infrastructure and networks are enforced.

H and H Group Plc (927998) Do not consider a full and proper review of the current green belt has been addressed.

Juniper Green Community Council (028859) The growth corridor strategy would lead to ribbon development and severely damage the Edinburgh green belt. The protection of the green belt continues to be eroded. The Edinburgh green belt should be maintained to enhance the amenity and landscape of the area around the City to sustain the natural environment and prevent coalescence of neighbouring communities. A mechanism to protect the green belt in perpetuity should be implemented.

Liberton and District Community Council (790396) A debate on the future role of the green belt (both areas for development and areas to be protected long term) should take place as soon as possible to obtain consensus with those on the urban fringe. This should not be facilitated via the Green Network Priority Areas as indicated in the Enhanced Green Network section of the Plan. Until this is resolved the existing green belt outside Strategic Development Areas should be protected from development.

Mactaggart and Mickel Homes (038949) Designations being introduced at LDP level - e.g. countryside around towns in East Lothian should be given careful consideration, with a view to not prejudicing potential future development or plan allocations in the period 2030+.

Mr Mike Martin (798523) Support the maintenance of the green belt, as it prevents coalescence, loss of community identity, congestion, and landscape / amenity values. We note and approve the continued inclusion of in the green belt and will seek to resist developer plans to build in it.

Mrs Mirabelle Maslin (928549) Why release land from the green belt (paragraph 3.4) when two-thirds of respondents to a MORI IPSOS poll of 2015 said that they did not want more of the green belt to be destroyed? Paragraph 3.8 - Due to the strategy of SDP1, coalescence is already taking place. Erosion of community identity is known to result in an increase in the incidence of mental health problems. There are new developments where there is little or no access to open space. How can it be ensured that this trend is halted and that green space is provided where currently there is none?

D and L McAuslan (040611) The green belt should be offered protection in order to fulfil the plans vision of maintaining and improving green belts and the green network.

Midlothian Green Party (778339) Paragraph 3.8 includes an overly narrow view of the potential of green belts.

NHS Lothian Public Health and Health Policy (840024) The decision to release some parts of the green belt for housing development is understood but it is important that this is not viewed as a model for future plans. One plan does not set the precedent for the next.

Prestonpans Community Council (039835) The Plan allows for green belt release on the basis that wedges of green belt survive. This is an open invitation to developers and will allow for coalescence between communities and loss of their landscape settings.

Rosewell and District Community Council (790523) Do not agree with releasing land from the green belt. Provision must be made for safeguarding.

Roslin and Bilston Community Council (790524) Two-thirds of respondents to a MORI poll of 2015 expressly said they did not want the green belt to be destroyed.

Scottish National Parks Strategy Project (930044) The Plan should propose the establishment of a new national park centred on the northern flanks of the Cheviots.

Scottish Natural Heritage (790587) While green networks have a role in protecting and enhancing natural heritage assets, this differs from the purpose of green belt policy. We recommend that policy in paragraph 3.4 is updated so that it more clearly sets out that the green belt and any future green networks will have distinct planning purposes, albeit with some degree of complementarity.

Support for paragraph 3.8 (page 14) which directs LDPs to identify and maintain green belts, but seek clarity on the final sentence: 'In doing so, Local Development Plans will take into account any relevant guidance on green networks'.

Scottish Wildlife Trust (038549) The contribution to the overall green network should be made a material consideration of development. Assessing the green quality of a development has been highlighted as an issue by local authorities and by developers. Scottish Wildlife Trust has been developing the Natural Capital Planning Standard which aims to give each development an overall rating in terms of the ecosystem services it is delivering. sportscotland (029346) Support the approach set out in paragraph 3.8. Some forms of sports development require an outdoor countryside location and policies which do not seek to preclude all forms of development in the green belt nor impose a blanket ban are supported.

Mr Charles Strang (907037) LDPs should ensure the preparation of detailed Management Plans for green belts, and the suggestion that green wedges can replace green belts, if that is the interpretation to be placed on the second half of paragraph 3.4, should be resisted.

Modifications sought by those submitting representations:

Avant Homes (Scotland) Ltd (032238) Amend paragraph 3.8 to: "Figure 3.1 Identifies the broad location of the existing green belts around Edinburgh and to the west of Dunfermline. Local Development Plans will identify and maintain green belts in the broad locations shown on Figure 3.1 and other countryside designations fulfilling a similar function where they are needed: To maintain the identity, character and landscape setting of settlements and prevent coalescence, To protect and provide access to open space, To direct development to the most appropriate locations and support regeneration. In doing so, Local Development Plans will take into account the broad location of the green belts set out in Figures 3.1, 3.2, 3.3, 3.4 and 3.5, and any relevant guidance on green networks.”

CALA Management Ltd (929806) Delete bullet point 2 under paragraph 3.8.

Corstorphine Community Council (040316) Paragraph 3.4 should be modified to stress the importance of the green belt and green network and that any release is a last resort. Development in such areas would be expected to include exceptional green infrastructure with cycle and walking routes. The direction in paragraph 3.4 should be reflected in paragraph 5.17 onwards (Enhanced Green Networks).

Cramond and Barnton Community Council (803443) No modification is specified, representation indicates that the focus of the strategy on Edinburgh should be reduced and that opportunities for new villages and towns with good digital communications around the region should be investigated. This would thereby reduce commuting to / within Edinburgh and retain / improve the quality of life of Edinburgh's citizens.

Edinburgh Association of Community Councils (040476) No modification specified, representations indicates that reference to the provision of green belt / open space / green network to compensate for any green belt release should be added to paragraph 3.4. Modify paragraph 3.8 to stress the importance of keeping land near urban centres for food production.

H and H Group Plc (927998) A detailed review to assess exactly how other growth will take place should be undertaken. Require member authorities to undertake detailed review of the green belt. Remove Heriot Watt campus from green belt notation in key diagram and Edinburgh and West.

Mactaggart and Mickel Homes (038949) Modify key diagram to extend long term growth corridor 2030+ from Haddington towards East Linton and onwards towards Dunbar.

Midlothian Green Party (778339) No modification specified, representation indicates that paragraph 3.8 should include positive policy support for the sustainable agricultural use of the green belt especially for local food production.

Scottish National Parks Strategy Project (930044) Modify spatial strategy to add a new national park allocation on the northern flanks of the Cheviots.

Scottish Natural Heritage (790587) Modify paragraph 3.4 to make a clearer distinction between 'green belt' and 'green networks', both in planning policy and general definition terms of each.

Scottish Wildlife Trust (038549) Add the following text to the bullet point list under paragraph 3.8: ‘To act as a buffer to designated sites, such as SSSIs, or locally important wildlife sites’. sportscotland (029346) No modification specified, representation indicates that further clarity should be added to paragraph 3.8 that sport and recreation development which has a site specific locational need, would be an appropriate form of development to be permissible in the green belt in accordance with SPP.

Summary of responses (including reasons) by Planning Authority:

Perceived Risks to Green Belts Cockburn Association (037249), Cramond and Barnton Community Council (803443), Esk Valley Trust (037349), Friends of the River Almond Walkway (925870), Mr Jon Grounsell (786916), Gullane Area Community Council (037068), Mr Mike Martin (798523), Mrs Mirabelle Maslin (928549), Prestonpans Community Council (039835), Roslin and Bilston Community Council (790524), Scottish Wildlife Trust (038549) SESplan recognises that there are and will continue to be development pressures on green belt land in some locations. The Proposed Plan Key Diagram Figure 3.1 continues to identify two green belts, one around Edinburgh and another at Dunfermline.

The proposed strategy is designed to concentrate strategic growth within or close to existing settlements. This is intended to improve access to jobs, services, and facilities (including open space), reduce the need to travel by car and protect the countryside. The green belts and green network priority areas are important components of the spatial strategy. They are one way of contributing to objectives of protecting countryside around towns from development. The green network approach is also integral to improving place quality and supporting active lifestyles. This strategy is clearly set out in Figure 3.1 and related maps on subsequent pages.

Given the variety of competing and often conflicting challenges SESplan is satisfied that the proposed strategy is best placed to meet all of these collective challenges.

The detailed identification of sites and boundaries for green belt and development site allocations will be critical and this will be a matter for the respective LDPs. SESplan is satisfied that this strategy is clear and appropriate and therefore no modifications are proposed.

Paragraphs 51 and 52 of SPP (ASD06) are already clear about development that is acceptable within a green belt and the circumstances in which LDPs should identify these types of development. SESplan does not propose to repeat SPP.

SPP is also clear about the protection of important historic and natural assets. These historic and natural assets and sensitive locations are already a material consideration in planning decisions. SPP is already clear on the approach and procedures for these matters and SESplan does not propose to repeat these. These principles are also reflected in Table 3.1 Placemaking Principles on pages 16 and 17 of the Proposed Plan.

For clarity it is not inevitable that there will be green belt release around Edinburgh in the next round of LDPs. This will depend on the work carried out in preparing those LDPs, including the identification of brownfield land and other sites that are not within the green belt. No modification proposed.

Designation and Management of Green Belts Avant Homes (Scotland) Ltd (032238), Gladman Scotland (783418), Juniper Green Community Council (028859), Liberton and District Community Council (790396), Rosewell and District Community Council (790523), sportscotland (029346) The SESplan proposed strategy is clear that strategic growth will be focused in the largest settlements, and particularly in and around Edinburgh. Green belts and green networks form an integral part of this strategy as set out in Figure 3.1 on page 13 and related maps and text.

Green belts are designed to perform several functions that are described in paragraphs 49 to 52 of SPP (ASD06). Green belts do not represent a blanket ban on development but instead a policy approach to limit the types of development that can take place. SPP makes clear that green belts are part of a settlement strategy and that they should be reviewed, this means that they do not remain in perpetuity, although it is plausible that many green belt areas will remain part of the green belt.

SPP makes clear that the exact boundaries of a green belt will be defined by LDPs. LDPs will also identify types of development that are appropriate within green belt areas. Paragraph 52 of SPP (ASD06) lists examples of these; including recreational uses which could include some sports facilities. SESplan is satisfied that the Proposed Plan provides an appropriate level of detail to enable councils to prepare their LDPs.

SESplan does not intend to repeat SPP. No modification proposed.

Avant Homes (Scotland) Ltd (032238) Regarding matters of conformity it is for the engagement and examination process to ensure that an LDP conforms to the respective approved SDP. No modification proposed.

CALA Management Ltd (929806) SESplan agrees that paragraph 49 of SPP (ASD06) does not mention the word ‘coalescence’. However, bullets 1 and 2 of this paragraph clearly mean that the prevention of coalescence is one outcome. SESplan sees no problems in using the word ‘coalescence’ since the preservation of settlement identity and issues of landscape setting have formed integral parts of the thinking about ‘the most appropriate locations’ for development and supporting regeneration. No modification proposed.

Edinburgh Association of Community Councils (040476), Grange and Prestonfield Community Council (790304) There are significant operational challenges in implementing the idea of designating compensatory green belt land if some is lost to development. These include: • The green belt boundaries are designated in LDPs and therefore compensatory designation of new land would trigger an LDP review. This would be disproportionately expensive and time consuming and, crucially, would bring together a decision on a planning application with plan review processes. This is not practical since some may use the LDP review to challenge the basis for a planning decision. • It would be unclear where the new green belt land ought to be and this would present major practicalities of its own. • Such an approach could effectively invite inappropriate development to green belt locations with the offer of compensatory land elsewhere. It is likely that this would result in a pattern of development that the strategy is designed to avoid.

SESplan is satisfied that the current strategy of concentrating strategic growth within and around the largest settlements, particularly in and around Edinburgh, remains rational. This will continue to be supported by the designation of green belts, whose exact boundary will be determined by the LDPs. Broader green network objectives and the specific identification of allocated sites and their boundaries will also be a matter for individual LDPs. No modification proposed.

H and H Group Plc (927998) SESplan has considered that the continuation of the existing green belt remains appropriate. No evidence has been presented to justify a contrary position. Paragraph 52 of SPP (ASD06) is clear on the role of LDPs in identifying the exact boundaries of the green belt. SESplan is therefore not persuaded that there is any evidence to justify an alternative set of conclusions. No modification proposed.

D and L McAuslan (040611) The green belt is already a designation that limits the range of land uses that can take place in areas it covers. The strategy identifies the green belts, both within and outwith some of the growth corridors. SESplan is satisfied that the proposed strategy makes appropriately clear where green belt land is located; accepting that the exact boundaries will be defined by LDPs. The designation and management of green belt land is already made clear by paragraphs 49 to 52 of SPP (ASD06). SESplan does not propose to repeat these. No modification proposed.

Midlothian Green Party (778339) SESplan does not agree that paragraph 3.8 represents an overly narrow view of the potential of green belts. Their role, function and management are already described in paragraphs 49 to 52 of SPP (ASD06) and SESplan does not propose to repeat these. No modification proposed.

Proposed Plan Paragraph 3.4 Eskbank and Newbattle Community Council (891202), Corstorphine Community Council (040316), NHS Lothian Public Health and Health Policy (840024), Mr Charles Strang (907037) Paragraphs 51 and 52 of SPP (ASD06) already make clear that green belts do not represent a complete ban on all forms of development. Therefore some forms of development will be appropriate within green belt areas. SESplan does not propose to repeat SPP.

Paragraph 3.4 describes a possible situation in the future regarding the extent and operation of the green belts. This is a strategic, long term issue. It is appropriate to make this clear now so that thinking can begin early, whilst the current strategy is being implemented. For clarity it is not inevitable that there will be green belt release around Edinburgh in the next round of LDPs. This will depend on the work carried out in preparing those LDPs, including the identification of brownfield land and other sites that are not within the green belt. No modification proposed.

Other Issues Damhead and District Community Council (039328) SESplan is not persuaded that the A701 relief road (see Table 6.1 on pages 60 to 61) represents a position contrary to policy. Table 6.1 identifies a series of transport infrastructure upgrades required alongside the enhancement of green networks and the delivery of new development. No modification proposed.

Mactaggart and Mickel Homes (038949) SESplan is satisfied that the broad strategy remains the most rational approach. Countryside around towns and other such designations are a matter for LDPs. No modification proposed.

Scottish National Parks Strategy Project (930044) The designation of national parks is a matter for Scottish Government through the appropriate legislation. Were there to be a new national park on the northern flanks of the Cheviots this area would be independent of SESplan because Strategic Development Planning Authorities do not cover national parks. No modification proposed.

Scottish Natural Heritage (790587) The sentence 'In doing so, Local Development Plans will take into account any relevant guidance on green networks' recognises that there is multiple guidance on green networks which may change. SESplan considers this to be an appropriate form of words to recognise this. No modification proposed.

Reporter’s conclusions: [Note: For DPEA use only.] Reporter’s recommendations: [Note: For DPEA use only.]