In February 2022 APRS sent an objection to the application (22/00042/FUL) raising issues including: the site not being allocated in the LDP, the Green Belt designation, the adequate housing land supply detailed in the Stirling HLA 2021, policies in the draft NPF4, and the site being in the Western Ochils Local Landscape Area and potential impact on the landscape setting.
Dear Planning Services
PLANNING APPLICATION 22/00042/FUL
HOUSING DEVELOPMENT AT BLAIRFORKIE DRIVE, BRIDGE OF ALLAN
OBJECTION
APRS objects to the above planning application for the following reasons:
Development Plan
Planning legislation requires that the determination of a planning application is to be
made in accordance with the development plan unless material considerations indicate
otherwise. This site is not allocated for development in the Stirling Local Development
Plan 2018 (LDP 2018). It is therefore not in accordance with the development plan
and so Planning Permission should be refused. Stirling Council’s Housing Land Audit
2021 shows that the Council has a more than adequate housing land supply, so this
proposed development in the Green Belt is unnecessary.
Stirling Green Belt
The entire site is located in designated Green Belt and therefore LDP 2018 Policy 1.5:
Green Belts applies. The proposed development does not meet that Policy’s
requirement that “Development should preserve the openness of Green Belts and
should not undermine their core role and function by individual or cumulative
impacts”. Neither does it comprise any of the four types of potentially acceptable
development in the Green Belt listed under Policy 1.5. Planning Permission should
therefore be refused.
Draft National Planning Framework 4
National Green Belts policy guides development to the most appropriate locations,
whilst protecting the rural character of the landscape settings of towns and preventing
their coalescence. However, the Scottish Government’s Draft National Planning
Framework 4, issued in November 2021, significantly expands upon the role of Green
Belts and the benefits which they bring to Scotland:
“Green belts can be used as a settlement management tool around Scotland’s towns
and cities to help to direct growth to the most appropriate, sustainable locations.
Green Belts can have a role in protecting and enhancing the character, landscape and
natural setting and identity of settlements, providing outdoor access to green
networks which link urban and rural areas and supporting nature networks.”
“Green Belts can … benefit quality of life and environment in our cities and towns,
increase urban density and minimise the need to travel using unsustainable modes.”
Benefits of Scotland’s Green Belts
Scotland’s Green Belts, including the Stirling Green Belt, are a precious resource of
national importance. Green Belts contribute to tackling the climate emergency
through directing development to more appropriate and sustainable brownfield sites,
including vacant and derelict land and re-use of existing buildings. They provide many
important benefits to quality of life and well-being in addition to their original planning
purposes. They contain significant areas of prime agricultural land, important for
home-grown food production, and semi-natural woodland. They can provide havens
for wildlife so can help to tackle the nature crisis, especially as part of wider nature
networks.
Green Belts have great potential, through appropriate management, to do even more
to tackle the climate emergency and nature crisis and to promote home-grown food,
outdoor education and recreational opportunities for local communities. In a poll of
Scottish residents carried out for APRS by Survation in June 2017, 74.6% of those
who expressed an opinion agreed that “All Green Belt land in Scotland should have
stronger protection from building development”.
Western Ochils Local Landscape Area
The entire site is located within the Western Ochils Local Landscape Area and
therefore LDP 2018 Policy 9.1: Protecting Special Landscapes applies. The applicants
have not demonstrated that “the landscape character, scenic interest and qualities for
which the area has been designated will not be adversely affected”; neither have they
demonstrated that “there is a specific nationally recognised need for the development
at that location which could not be satisfied in a less sensitive area, and any adverse
effects are clearly outweighed by social, environmental or economic benefits of local
importance”. Planning Permission should therefore be refused.
Development of this site would negatively impact the landscape setting of Bridge of
Allan and would be detrimental to the wider Stirling Green Network. It is also
adjacent to a Site of Special Scientific Interest and Special Area of Conservation which
would be adversely affected by the proposal.
Please contact me if you require any further information or clarification.
Yours faithfully
John Mayhew MA MSc DipTP MRTPI
Director