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Questions - Part 3 - National Planning Policy continued

47. Policy 29: Urban edges and the green belt. Do you agree that this policy will increase the density of our settlements, restore nature and promote local living by limiting urban expansion and using the land around our towns and cities wisely?

Do you agree that this policy will increase the density of our settlements, restore nature and promote local living by limiting urban expansion and using the land around our towns and cities wisely?
Yes, I strongly support policy 29 and the clear setting out of the
multiple benefits of Green Belts in the two paragraphs of preamble and in policy 29 a).
I support the clear link in policy 29 a) between the use (and protection) of Green Belts and the prevention of unsustainable
development with resulting benefits to the environment and quality of life.
I support 29 a) particularly the specific references to the roles of
Green Belts in benefiting quality of life and minimising unsustainable travel and hope the Scottish Government will encourage the further designation of Green Belts in pressurised areas, where appropriate.
I strongly support the presumption against most types of development on Green Belt as set out in 29 b) but suggest it should be made clear that all the potential exceptions in 29 b), not just the 4th bullet on recreation and sport, should be compatible with a countryside or natural setting. The mainly open landscape of the Green Belt should be protected, as should the ability for people to access it responsibly.
I am also concerned that the reference to directly connected retailing in the second bullet of 29 b) needs to be tightened up as it could be used to justify more large retail garden centres with substantial associated catering and retail developments which encourage unsustainable travel rather than on-site horticulture or market gardening.
I ask for a tighter definition of ‘established need’ for development as referred to in the fifth bullet of policy 29 b), particularly given the
climate and biodiversity crises and the cumulative “cost” to the
environment of all development.
I strongly support 29 c), including the four bullets. However, the first bullet refers to the purpose of the green belt at that location without stating what that purpose might be and where it is stated. So we suggest that a clarification should be added to the effect that all the roles, uses and benefits given in the preamble to the policy (under Urban edges and the Green Belt) and those purposes mentioned in 29 a) are considered ‘purposes’.
I agree with the part of 29 c) that says the primary consideration will be whether the development could instead be located on an alternative site outwith the Green Belt and why a Green Belt location is essential. The subsequent wording relating to the ‘qualities of successful places’ should mirror that used elsewhere in the document and say “the six qualities of successful places” to make clear it refers to those set out in policy 6.
We strongly support policy 29 d) which in conjunction with 30 c) will help to strengthen many of the other policies in the NPF4 aimed at reducing emissions, protecting countryside and biodiversity and making settlements more liveable and sustainable.
Overall I welcome the suite of policies in the draft NPF4 that together mean that shortfalls in housing land supply calculations will no longer be considered a valid reason for allowing otherwise unacceptable speculative housing development on Green Belt land.
Local development plans should promote the positive management of Green Belt areas for wider environmental, landscape and recreation benefits.
Additionally, we suggest that the term ‘Green Belt’ is added to the
glossary so that all stakeholders have a clear definition to refer to and would suggest the following:
Green Belts are areas of open land around, beside or within a settlement where there is a presumption against most forms of development. The purposes of Green Belts are to protect the valued landscape settings of settlements and to prevent urban sprawl by directing development to more appropriate sites. Green Belts can also provide significant benefits for climate mitigation, nature recovery, public access and recreation, particularly given their proximity to centres of population. Green Belt boundaries are designated by Local Planning Authorities in Local Development Plans.
For consistency the title of Policy 29 in the text of NPF4 should read
“Urban Edges and the Green Belt” rather than just “Urban edges” as it does at present.

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