APRS Resources

Falkirk Council LDP topic consultation

This is the APRS response to the consultation on Topics for the LDP (Local Development plan) from Falkirk Council April 2024. Our response covers the Green Belt topic.

Please identify any areas of disagreement with the evidence, including reference to information or sources of information which provide alternative evidence.

The topic paper is focused on green belts and therefore summarises the specific policy on Green Belts in NPF4 (policy 8). It could perhaps also helpfully make clear that NPF4 is intended to be read as a whole and that the green belt policy is effectively supported by other policies – and in turn policy 8 supports other policies and policy aims (eg policies 1,2,3,15,18,19 etc).

Please identify the gaps in the evidence, including reference to any information or sources of information that could fill these gaps.

We appreciate that there are several references to the Falkirk Greenspace Initiative which has had multiple benefits perhaps including the basis of a nature network as referred to in NPF4.  However, it would be helpful for this information to be expanded upon to indicate the local authority’s evidence as to achieving the third policy outcome in NPF4, ie that “Nature networks are supported and land is managed to help tackle climate change”. In particular the shift to giving consideration of tackling climate change much more weight should be addressed in the paper.

Any other comments:

There are several references in the topic paper to “pressure for residential development” in some areas of Green Belt, however, what pressure means in this context is not stated. We presume it means there have been or are proposals for speculative housing development either being discussed, consulted on or applied for? We understand that the  latest (2023) Housing Land Audit shows a ten-year supply on land for new housing that is comfortably in excess of the MATHLR in NPF4 so there does not appear to be any urgent need to add to the allocated housing pipeline in the short term (let alone specifically by releasing areas or green belt).

It might also be worth highlighting more explicitly the part of the Scottish Government’s Local Development Plan Guidance (May 2023) that proposes that green belts may support the spatial strategy in an LDP by:

  • making effective use of land and supporting regeneration (prioritising the re-use or redevelopment of brownfield, vacant and derelict land and empty buildings first, before new development takes place on greenfield sites), and minimising the need to travel using unsustainable modes; and 
  • Protecting, enhancing and providing access to multifunctional blue and green networks and open space.

The topic paper currently notes at 2.6 and 2.7 that the Green Belt is consistent with NPF4 but the Guidance appears to put more emphasis on prioritising the re-use of buildings/brownfield rather than Greenfield, minimising unsustainable travel and access to open space etc.

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