June 2025 Update for the Green Belt Alliance
NPF4 Implementation – Scottish Parliament review process
In March APRS responded to the Scottish Parliament’s Local Government, Housing and Planning Committee’s call for views on the progress of implementing NPF4. Our evidence included comments about the implementation of Policy 3 on Biodiversity particularly highlighting the urgent need for guidance to be finalised and for this to be properly resourced. We also highlighted some of the concerns that emerged from our joint webinar series earlier in the year around how community knowledge about biodiversity can be captured and on the monitoring and enforcement of biodiversity conditions.
The call for written evidence was followed by several meetings where the Committee took oral evidence from a range of planners and stakeholders, which can be viewed on Scottish Parliament TV. A representative of Scottish Environment LINK’s planning group (of which APRS is a member) gave evidence on 3 June and Planning Democracy appeared on 17 June. We were concerned that Homes for Scotland were calling for a return to the presumption in favour of sustainable development in the Scottish Planning Policy that NPF4 superseded, which frequently favoured the approval of speculative housing applications on designated Green Belt. However, a range of speakers in the second meeting supported the NPF4 approach and suggested this wasn’t a sensible way forward. The Committee are expected to write to the Scottish Government with their findings and recommendations.
Planning Case Update – housing/mixed development in North Lanarkshire
North Lanarkshire Council last week (12 June) voted to refuse planning permission for the long-running Europark application for a mixed, housing-led development on designated Green Belt between Calderbank and Coatbridge.
Save Woodhall and Faskine local action group first contacted APRS in April 2024 about their concerns over a proposed huge major housing development on a nature and history-rich area of Green Belt. In the years since we have seen a new Planning Act (2019), the adoption of a new North Lanarkshire local development plan (July 2022) and the introduction of NPF4 in 2023. The proposed development has also changed from housing to mixed development with various iterations of the application.
There has also been a growing appreciation of the importance of nature and green spaces to people’s health and wellbeing and the critical need to address the interlinked nature and climate crises by making sustainable decisions about development. The site in question is still designated Green Belt, it wasn’t allocated for development in the LDP and the Scottish Government turned it down as a National Development when the applicant submitted it to the consultation on the then draft NPF4. The North Lanarkshire Council (NLC) Planning Portal lists 39 constraints on the site from flood risk, post coal mining risks, listed buildings, scheduled ancient monuments a local Nature Reserve and at least 8 sites of interest for nature conservation (SINCs).
Since the initial 2018 application, there have been many thousands of objections from local people with addendums after changes to the application and to planning policy. APRS objected to the proposal in 2018, again in November 2021 and most recently in April 2024. Other objectors include the Woodland Trust Scotland, highlighting the loss and fragmentation of ancient woodland.
The meeting of the council at Motherwell Civic Centre to decide planning application 18/00890/PPP (Land To North Of A8 & South Of Sykeside Road & Calderbank Road Sykeside Road, Airdrie) was lengthy with representations from the developers and supporters and members of the local community who opposed the plan including members of the original local action group that contacted us – now the Woodhall, Faskine and Palacecraig Conservation group SCO48862. Ahead of the meeting the North Lanarkshire Council planners report on the case was published giving a strong recommendation to refuse the application. The grounds for the refusal were given as “The proposal is contrary to National Planning Framework 4 and to the North Lanarkshire Local Development Plan 2022 and would represent a significant departure from the development plan spatial strategy. It is not considered that any material considerations have been demonstrated which would justify the release of this site from the Green Belt for the proposed purposes.”
The recommendations for refusal noted that the proposal is contrary to the LDP and to many policies in NPF4 including those covering Green Belt; Climate and Nature; Brownfield; Design, Quality and Place; Quality Homes; Business and Industry; City, Town, Local and Commercial Centres; Retail; Climate Mitigation and Adaption; Sustainable Transport; Local Living and 20 Minute Neighbourhoods; Historic Assets and Places; and Blue and Green Infrastructure.
The meeting included a lengthy session of questions from Councillors with a final vote of 18 in favour of approval and 42 for refusal. It is not yet known if the developer will appeal. A longer news blog on the case can be seen here.
Planning Fees for Appeals
The Scottish Government has recently introduced a fee for most planning permission appeals. APRS responded to a consultation called ‘Investing in Planning’ last year, which included a proposal for this.
Before 9 June 2025, developers could appeal against refusal of planning permission with no additional fee. Communities and third parties of course have no similar right of appeal against the granting of planning permission – even when the application is contrary to the agreed development plan.
Fees will vary depending on the application in question and there are some exemptions. There is a single rate of £143 for s.42 applications (which cover variation of conditions) with a formula for a sliding scale for other types, from £286 for one dwelling house up to a maximum of around £35,000 for residential planning permission in principle, and a maximum of more than £70,000 for wind turbines. However, applications can be appealed for non-determination without a fee being charged (ie when the timescale for a decision is exceeded) which perhaps could persuade applicants to appeal sooner rather than wait to see if a planning authority approves their application somewhat belatedly. The other tactic that might potentially be used more frequently as a result of this change is the “free go” where a refused application is amended and then resubmitted within 12 months of the application being refused. The fresh application has to be for the same character or description of development and on the same site.
For more detail see Planning circular 3/2025: fees for local reviews and appeals
Progress on LDP reviews – evidence reports and gate checks
2 Evidence Reports are currently with the DPEA for the gate check process (June 2025) – Inverclyde; Perth & Kinross;
6 Evidence Reports have now been approved at gate check so the LAs can continue to prepare the LDP – Stirling (June 2025); Glasgow (April 2025); Falkirk (January 2025); East Renfrewshire (December 2024); Midlothian (September 2024); Moray (August 2024).
3 LAs have to resubmit their evidence report to gate check as the evidence submitted was deemed insufficient: Dumfries and Galloway (April 2025); East Lothian (April 2025); Fife (July 2024).
For information on the LDP process in your area check the local planning authority’s website, sign up for updates or read the participation statement included in the Development Plan Scheme which should lay out the expected timescale for opportunities to input and influence the LDP in your area. General information on LDPs is available on the APRS website.
Energy Developments
Everyone will be aware of the high level of applications for energy developments across Scotland. These include new grid infrastructure, different types of renewable generation, hydrogen plants, pumped hydro and battery storage developments (BESS). Applications below 50MW are dealt with by local planning authorities under the planning system, while those above 50MW are decided by the Scottish Government’s Energy Consents Unit. APRS continues to receive enquiries about energy proposals and is acutely aware of the difficulty of balancing impacts on landscape, nature and communities with the need to decarbonise. We are aware of a growing number of battery storage proposals on Green Belt. Some people have voiced concerns that more storage is being given permission than is required by government targets and query what will happen to greenfield sites with permission if they eventually go undeveloped or are abandoned. Others are concerned that there appears to be little effort to minimise energy consumption or that the speculative approach to energy storage applications might stymie a more strategic approach to energy infrastructure in future.
Last year APRS put in a representation to the ECU on the Whitehall BESS proposal (still under consideration) which raised various concerns due to its Green Belt location, but we don’t have the resources to consider and respond directly to each application we see. We do now have a volunteer project up and running to look at the data available around battery storage applications and the degree of proliferation and impact on Green Belts. We hope to report findings from it later in the year.
New ERCS Guidance on Planning Enforcement
The Environmental Rights Centre Scotland has produced new helpful guidance about planning enforcement. This explains how enforcement should work and the tools a planning authority can use for enforcement. It also explains what you can do if you think there has been a breach of planning control including where planning conditions have not been fulfilled. The guidance is here.
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