Green Belts and Planning Update

Green Belts and Housing

Positively, given APRS and Green Belt Alliance advocacy on NPF4, it seems that the clearer policy protection against most developments on designated Green Belts is being supported by decisions. The protection of Green Belt is assisted by changes in the policy on housing land, with a greater focus in NPF4 on delivery of housing on sites allocated in LDPs. However, there are a number of large housing proposals on unallocated sites, some of which are also Green Belt that are currently at appeal, with those appeals (at time of writing) still paused pending a decision on the Mossend Appeal case. Miller Homes v the Scottish Government (XA41/23) was heard at the Court of Session on 24 January and considers in part how NPF4 policy 16 Quality Homes interacts with existing LDPs. It is likely no coincidence that quite a few speculative housing developments which had seemed to be on the backburner are now coming forward with pre-application consultations or new planning applications and these include several on unallocated Green Belt sites. Presumably, developers are hoping that the Mossend case goes against the Scottish Government to some extent and creates less certainty around the current NPF4 policy 16 Quality Homes. Policy 16 allows limited scenarios where large market housing developments on unallocated sites would be supported. We note that even if the result of the case affects how policy 16 is interpreted there are other NPF4 policies (eg policy 8 Green Belt and 9 Brownfield) that would not support such developments on designated Green Belt and would prioritise development on appropriate brownfield sites outwith the Green Belt.


The NPF4 approach to protecting and enhancing nature and indeed promoting nature networks and the recovery of biodiversity has perhaps got off to a hesitant start. The stronger policies have been referenced and seemed influential in some planning decisions but not in others. This might be partly because the development of supporting guidance from NatureScot and Scottish Government is still ongoing but probably also reflects a lack of expert resources in planning departments and a lack of understanding and training on biodiversity for many Councillors. The recent calling in of a decision by Scottish Government where the proposed development would impact highly designated nature sites and a recent, very well attended parliamentary event organised by Planning Democracy which highlighted issues with NPF4 and biodiversity are hopeful suggestions that the need for improvement is being recognised.


NPF4 covers the challenge of rapidly transitioning to a less carbon intensive economy with a spatial strategy and policies that give strong general support to renewable energy (or related) developments. This is reflected in the wide definition of energy developments that fall under National Development 3. Policy 11 Energy does set out a list of impacts that must be addressed in development proposals including “cumulative impacts” but it is currently not very clear how this can be fairly assessed given some of the proposals submitted are speculative commercial ventures rather than clearly part of an overall national strategy. There are clearly tensions between devolved and UK-wide decision making processes playing out and increasing tension between how energy targets can be met and a desire to protect Scotland’s landscapes.

The topics highlighted above mainly reflect the types of enquiries APRS has been receiving and the range of questions at our recent webinars that have covered aspects of NPF4. In the coming months NPF4 will be being reviewed by the Scottish Parliament’s Local Government Housing and Planning committee. We will post details on the website in due course.

We recently updated our Green Belts Advice Note taking in the changes arising from the implementation of the 2019 Planning Act and the adoption of NPF4 last year. You can find the new Advice Note on our Green Belt Alliance pages.

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