APRS has been supporting the community of Calderbank in fighting a series of applications for planning for thousands of homes and associated infrastructure on Green Belt land for 9 years. This is our response to the planning appeal that has been lodged after the development was rejected by planners.
DPEA ref: PPA-320-2182
Claire.Seidel@gov.scot
Planning and Environmental Appeals Division, Ground Floor, Hadrian House, Callendar Business Park, Callendar Road, Falkirk, FK1 1XR
9 October 2025
Dear Ms Seidel,
RE: Submission to Planning Permission Appeal (PPA-320-2182)
Land To North Of A8 & South Of Sykeside Road & Calderbank Road, Airdrie
APRS have previously commented on and objected to various iterations of this proposal for development (NLC ref: 18/00890/PPP). These have included submissions to North Lanarkshire Council in 2018, November 2021, and April 2024. APRS asks that this appeal should be dismissed for the reasons given below.
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 North Lanarkshire Local Development Plan 2022, and is contrary to many of the national planning policies in NPF4. The local planning authority decision notice, dated 12 June 2025 which refused planning permission, listed 14 NPF4 policies that the proposal was contrary to. The proposal is therefore not in accordance with the development plan. Scotland has a “plan-led” planning system and this appeal for major development on an unallocated, designated Green Belt site should be refused.
Green Belt
With reference to para 2.3 of Stantec’s Appeal statement Green Belt land is as defined in the adopted development plan. It is not unusual for a designated Green Belt to incorporate existing and previous developments, and this does not mean the whole site should be considered brownfield land as Stantec implies elsewhere in the statement. In fact, as Stantec also states at para 2.6 much of the site is ‘currently agricultural in nature.’ The Green Belt designation should also not be dismissed as ‘historic’ – it is set out in the extant LDP.
During the Examination of the North Lanarkshire LDP Modified Proposed Plan in 2020-21, the applicant made representations to remove this site from the Green Belt and to allocate it for development. However, these representations were unsuccessful: in the
Report of Examination submitted in May 2021 the Reporters stated that the site was not included in the Main Issues Report, had not been the subject of public consultation in relation to the proposed LDP and had not been subject to strategic environmental assessment in relation to the proposed LDP, so it would not be appropriate to recommend altering the proposed LDP in response to the representation.
The current position is that the site is designated as Green Belt in the adopted LDP and the developer is clearly aware of this. Preparations for the next LDP are underway and NLC have already consulted on a Green Belt topic paper as part of evidence gathering. All parties will have the opportunity to make their arguments as to whether any changes should be made during the LDP process. NPF4 Policy 8 is clear that:
“Green belts should be identified or reviewed as part of the preparation of LDPs. Boundary changes may be made to accommodate planned growth, or to extend or alter the area covered as green belt. Detailed green belt boundaries should be based on evidence and should be clearly identified in plans.”
Green Belt designation will be considered in the preparation of the next LDP and it would be premature and contrary to a plan-led approach to development to approve a significant de-facto change to Green Belt by allowing this appeal.
Policy 8 of NPF4, in addition to being clear about the sorts of development that could in theory be supported in a Green Belt location, gives five requirements that would need to be met for that support to be forthcoming. Our view is that the proposal still fails to meet these. We note that the Environmental Statement submitted with the planning application states that “As such, no other locations were considered for the Proposed Development”.
We very much disagree with claims made at section 7.2.3 in the Appeal statement. The proposed development very much will breach the Green Belt objectives and is contrary to the three policy outcomes set out in NPF4 Policy 8. Green Belt is always, at the points nearest town and cities peri-urban, and does not have to take the form of a ring. There can be islands of Green Belt, which still deliver on objectives, directing development to the right locations, protecting and enhancing the landscape and natural setting of settlements and which can provide important links or ‘stepping stones’ in nature networks. They also form important green oases for local people to access nature. The applicant’s suggestions that losing nearly 40% of the green space would not have overall negative impacts on landscape, Green Belt policy objectives and on biodiversity is incomprehensible.
Climate
NPF4 puts significant weight on the climate and nature crises and it is impossible to see how the proposed development can be reconciled with the aims of that overarching policy (NPF4 Policy 1). We would point out that a very similar proposal for the site was put forward as a candidate national development during the consultation stages of the draft NPF4 and was rejected by the Scottish Government on the grounds of its potential harmful climate impacts.
Biodiversity
Contrary to the implication of para 6.2 of the appeal statement, the lack of objections from statutory consultees does not indicate support for the proposed development and cannot be considered materially to validate the application. On biodiversity specifically, NatureScot only object to development proposals in very narrow circumstances which are set out in the public documents “Guidance – Development management and the Natural Heritage” and “Planning for Great Places”. Objections are limited to development that would impact European protected sites (SACs and SPAs) or cause “natural heritage issues of national interest”. The NatureScot document “Identifying Natural heritage issues of national interest in development proposals” makes clear that “We [NatureScot] will only object to proposals when we consider that the consequences of approval for the care and enjoyment of the natural heritage raise issues of national interest” which is a very high bar. This means the lack of objection from NatureScot in no way undermines the Council’s position that this is a valuable and important area of Green Belt for natural heritage and landscape.
Quality Homes
The proposal is for residential led development on land which has not been allocated for housing. The Council is correct to state that there is sufficient housing land to cover the MATHLR over the next ten years. The MATHLR is set at 7,350 units and the latest available Housing Land Audit for 2024 shows a short term supply of 6,574 units, a medium-term supply of 3,962 units and long-term supply of 156 units. This makes a total ten-year supply of 10,692 units – 63% greater than required to meet the MATHLR.
NLC is yet to set a Local Housing Land Requirement or to publish an evidence report for NLLDP2. There is, however, scope for NLC to set a much higher local housing land requirement (LHLR) than the MATHLR and still have an adequate supply of housing land.
As there is no demonstrated housing land shortfall, this cannot be a material consideration in favour of approving this application.
In terms of policy support, the development does not meet the parts of NPF4 Policy 16 which specifically deal with unallocated sites ie policy 16(f). Policy 16(f) is unsupportive because it requires each of the criteria in sub-paragraphs, i, ii, and iii to be met and, in this case, they are not. Policy 16(f) iii) is carefully drafted to give support to additional housing sites when higher-than-expected delivery means that the existing housing land supply may be exhausted. This is not the case in North Lanarkshire – there is more than sufficient capacity from existing allocated sites to meet expected and actual completions.
NLC has, as is acknowledged in the appeal statement (section 7.3.2), a more than sufficient amount of housing land to meet MATHLR. If completions are falling short of expectations it is not due to any shortage of land but to shortage of demand or other factors.
It does not follow as suggested that all truly deliverable sites would have submitted a planning application within 3 years of adoption. There may be many reasons for not doing so – not least of which is the existence of many other sites that already have planning permission.
De-allocation of sites is a matter for the Council in preparing the next LDP. But diverting housebuilding resources to an unallocated site now may impact delivery of other intended development plan outcomes such as regeneration of town centres. Similarly, the socio-economic benefits described by the appeal statement could presumably be delivered by development on other more sustainable and allocated sites. We also note that many of the benefits listed in section 6.3.5 seem uncertain – that the developer “seeks to” deliver a benefit is not an undertaking to ensure it happens. It is also unclear what the arrangements for funding and management in perpetuity of the proposed, so-called country park, but the risks seem likely to fall on an unspecified community.
The assertion in the final paragraph of section 7.3.3 that “the Council is clearly in need of new homes and new homes are not being delivered across the authority” is disputable. Scottish Government Housing Statistics (https://www.gov.scot/collections/housing-statistics/#housingstatistics:excelwebtables) state in 2023/24 there were 789 all-tenure housing completions in North Lanarkshire – very slightly below the ten-year average of 805 units. North Lanarkshire contributed 3.9% of Scotland’s all-tenure output in 2023/24 – compared to a ten-year average of 4.0%.
The appeal statement acknowledges (at section 6.5) that there is a shortage of social rented accommodation in North Lanarkshire but this proposal does not specify that it will deliver any. There is nothing to indicate that it will do anything to alleviate the social rented accommodation shortage. We also understand that the affordable proportion of the proposed housing has also fallen from previous iterations of the application.
Since there is already a more than ample supply of housing land available to meet identified need (MATHLR) in North Lanarkshire if this site were to be approved and to be developed as rapidly as the applicant undertakes, it would likely displace output from other allocated sites. This being so, a departure from policy 16(f) cannot be justified.
Yours sincerely,
Kat Jones,
Director, APRS