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Renfrewshire Council letter 17042023_Redacted

Renfrewshire Council · 30 May 2023
Back to Local Review Body. — 30 May 2023 and its agenda

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‘Section 25 of the 1997 Act requires that decisions are made in accordance with the
development plan unless material considerations indicate otherwise.   Application of
planning judgement to the circumstances of an individual situation remains essential
to all decision-making, informed by principles of proportionality and reasonableness’. 
The appointed officer suggests that six policies of NPF4 are ‘considered to be
relevant’, namely: 
Policy 1 - Tackling the climate and nature crises.
Policy 2 - Climate mitigation and adaptation
Policy 3 - Biodiversity
Policy 8 - Green Belts
Policy 16 - Quality homes
Policy 17 - Rural homes 
He has, however, provided some detail in responses to only three of these, i.e. 8, 16
and 17, and my comments are as follows: 
Policy 8 – Green Belts 
Response
Policy 8 has, in effect, replaced Clydeplan Policy 14 but the strategic objectives that
underpin the core values of policy remain similar.   What is less clear is that NPF4,
Policy 8, has completely replaced LDP2, Policy ENV1.   On that basis therefore, in
relation to the Green Belt, our understanding is that the Council’s primary strategic
concern, which hasn’t been changed by the introduction of NPF4, Policy 8, is that,
while Green Belt designation is not in place to prevent development from happening,
and while identifying supportable uses, the important consideration is that any
proposed development does not undermine the core role and function of the Green
Belt and, in particular, the intended Policy Outcomes of NPF4, Policy 8, in that the
proposals do not represent unsustainable growth, will not impact negatively on the
character, landscape and natural setting and identity of settlements, nor on nature
networks and land managed to help tackle climate change. 
Policy 8 identifies a number of key policy connections that we consider to be relevant
in this case, namely:

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(i) Policy 9, Brownfield, vacant and derelict land and empty buildings
The Policy Intent is ‘To encourage, promote and facilitate the reuse of
brownfield, vacant .... land, etc’. 
The site is vacant and has been for a considerable period of time.   It is not
recorded on the Council’s Vacant and Derelict Land database but this is
understandable due to the urban focus of this particular survey. 
(ii) Policy 17, Rural Homes
This is returned to later but suffice to state at this stage that it does introduce
the requirement for LDP2s to include  ‘tailored approaches to rural housing’
which is not currently the case in Renfrewshire.   Criterion (ii) refers to the
reuse of brownfield land.   The site is not brownfield but it does qualify as
vacant under the terms of Policy 9. 
(iii) Policy 29, Rural Development
Policy 29 advises that LDPs’ spatial strategies should set out the appropriate
approach to development in rural areas which reflects the identified
characteristics.   The proposals are based on a careful consideration of
topography, landscape setting and the settlement pattern in the immediate
area. 
Criterion (b) states that ‘development proposals in rural areas should be
suitably scaled, sited and designed to be in keeping with the character of the
area’. 
Although these proposals are in principle, we maintain that the information
already submitted confirms that this would be the outcome. 
With the above policies collectively providing, in effect, an overall policy
context, it is our contention, as previously stated in the Supporting
Statement that formed part of refused Planning Application 22/0399/PP
and in the recently submitted Supporting Statement that forms part of
this Request for Review, that the proposals are not entirely incompatible
with the requirements of policy, and that their development would
therefore not significantly implicate or, indeed, undermine the

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effectiveness of these policies here or elsewhere in the LDP area.   The
strategic objectives of Greenbelt Policy would not be compromised. 
In view of the particular locational and physical characteristics of the site
which have not been disputed by the appointed officer, it is difficult if,
that is, they were treated on their own particular merits to conclude
otherwise. 
Policy 16 – Quality Homes
Policy 17 introduces the requirement for LDPs to include ‘tailored approaches to rural
housing’ and goes further to state ‘and, where relevant, include proposals for future
population growth – including provision for small-scale housing ...’ 
The Council’s HNDA 3 divides Renfrewshire into five Housing Market Areas.   The
proposed site falls within the West Renfrewshire Housing Market Sub Area which
includes the villages of Lochwinnoch, Howwood and Kilbarchan, mentioned in the
appointed officer’s response.   There has not yet been an assessment of housing
needs at Renfrewshire Housing Market Sub Market Area level and certainly not
at the level of individual villages. 
The bulk of West Renfrewshire is countryside and therefore classified as rural, and
all of it is Green Belt. 
The essentially top-down approach to the allocation of sites shown in LDP2 is not
therefore the outcome of a ‘tailored approach to rural housing’. 
The proposed site, which is for a single dwelling only, in our opinion, as confirmed in
the Supporting Statement for Planning Application No 22/0399/PP, and further in our
Supporting Statement forming part of the Request for Review, even in the absence of
such a tailor-made policy, presents no threat to the strategic objectives of Green Belt
Policy, satisfying, as it does, all of the requirements relating to sustainability. 
Policy 17 – Rural Homes
The Council’s response recognises that the site falls within a ‘rural area’.   Policy 17
recommends that LDPs should set out tailored approaches to rural housing and,
where relevant, include proposals for future population growth, including provision of
small-scale housing.

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Current LDP policy re the provision of housing in rural areas is not based on such a
bottom-up approach. 
While, as a result, not having, as yet, a clear picture of the details of any responses
to Policy Principle, we maintain that the proposals would not be incompatible with the
ambitions of Policy Intent and Policy Outcomes.   Criterion (a) states that
‘Development proposals for new homes in rural areas will be supported where the
development is suitable scaled, sited and designed to be in keeping with the
character of the area’.   The appointed officer in his Report of Handling re the refusal
of planning application, agreed that ‘the applicant has demonstrated in principle that
the development plot could accommodate a dwellinghouse’ without negative
implications for the context. 
While the site is not brownfield, it is vacant within the terms of connected policy,
Policy 9, Brownfield, vacant and derelict land, where it is stated that the Policy Intent
is ‘to encourage, promote and facilitate the reuse of brownfield, vacant ... land, etc.’ 
While Policy 17 includes reference to a range of acceptable residential uses in rural
areas, which would cumulatively significantly limit the opportunities for new housing,
the primary objective of Criterion (a).   How this, however, ties in with the advice
provided that LDPs ‘should be informed by an understanding of population change
over time, locally specific needs and market circumstances in rural ... areas’ is not
clear.   Indeed, the advice suggests the provision for small-scale housing that is not
all intended for essential workers or retired farmers? 
Other Policies Referred To 
The Planning Authority’s Response identifies the following policies as relevant to this
application but makes no further comment. 
Policy 1 – Tackling the climate and nature crises
There is no disputing the relevance of Policy 1 since its guidelines would, it is
understood, be intended to be universally applied to all applications. 
Policy 1 states that ‘when considering all development proposals, significant weight
will be given to the global climate and nature crises’.

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Since, according to NPF4, the ‘key policy connections’ for Policy 1 are ‘all other
policies’, it has to be assumed that the ‘other policies’ referred to in the Planning
Authority’s Response are the ones considered to be those most likely negatively
implicated by the proposals relative to the requirements of Policy 1. 
We do not agree and, as stated elsewhere, in our opinion these proposals would not
contribute to any undermining of the aspirations of Policy 1 in relation to the climate
and nature crises. 
Policy 2 – Climate mitigation and adaptation
Policy Intent is given as ‘To encourage, promote and facilitate development that
minimises emissions and adapts to the current and future impacts of climate change’. 
This is an application in principle but mindful of the issues focused on in Policy 2, an
indicative response to circumstances was included as part of the planning
application.   A ‘could this work’ approach was taken and the results were generally
supported by the Determining Officer in his Report of Handling.   Should consent be
granted, then the required detail would form part of any subsequent application. 
Policy 3 – Biodiversity
The ‘Policy Intent’ is ‘To protect biodiversity loss, deliver positive effects from
developments and strengthen nature networks.’ 
Criterion (c) states that ‘Proposals for local development will include appropriate
measures to conserve, restore and enhance biodiversity in accordance with national
and local guidance.   Measures should be proportionate to the nature and scale of
development.’ 
The appointed officer has already agreed in his Report of Handling that the proposals
would not have significant negative implications for wildlife.   If, however, there are
any doubts about this, Appendix 1 – Additional Information for Assessment –
Development Guidance provides guidelines for Ecological Appraisals.   If, on a
precautionary basis, the Planning Authority would be seeking a ‘phase 1 habitat
survey’, then this could be made a condition of any consent.

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