To Local Government Minister re LDP

T H E    B O R D E R S   N E T W O R K

O F    C O N S E R V A T I O N    G R O U P S


c\o Crookston Old Mill


Scottish Borders

EH38 5YS 


11 February 2016


Mr Marco Biagi MSP 

Minister for Local Government and Community Empowerment

Scottish Government




Dear Mr Biagi,


Scottish Borders Council Local Development Plan


The Borders Network of Conservation Groups was constituted to promote appreciation and protection of the unique and beautiful landscape of the Scottish Borders.  We believe this is necessary because of the value of the landscape to the economy, culture, recreation and ecology of the area.  The Network is a not-for-profit umbrella organisation with no party political alignment.


Our current focus is the lawful and rational consideration of wind energy development in the Scottish Borders and so we have followed with interest the process of creating the latest version of the SBC Local Development Plan, indeed our members contributed to the public consultation.  However, we were surprised and very concerned at the Reporters’ response to that part of the LDP which relates to Policy ED9 on Renewable Energy Development.


Our understanding is that an LDP is intended to build on Scottish Government policy and guidelines and add local context and considerations to these for the guidance of all interested parties.  We are aware that a significant amount of research, local consultation, landscape study and capacity assessment was undertaken by SBC, and those contracted by them, to create an objective and reasoned Policy ED9.  


It appears to us that the Reporters have deliberately and forensically removed so much of that local context that Policy ED9 now reads as if it were written by the Scottish Government with no knowledge or account taken of any particular aspects of the circumstances and landscape of the Scottish Borders.  In fact, we also note that what few references to the independent studies by consultants remained after the ‘localectomy’ had been executed do not reflect the balanced assessments of these consultants but suggest a favour towards renewable energy development which was not present in the totality of the assessments. 


We are aware that almost exactly the same thing has been done to the LDPs of many other local authorities and so assume that there has been a national, centrally-driven impetus to impose a one-size-fits-all development plan across the country.


We note that SBC, whilst expressing disappointment at this expungement of all that is local, has understandably not formally objected, believing that possible future legal challenge could leave it for too long without an updated LDP in order to best serve its planning duties.  You will be well aware that the Scottish Government’s failure to keep to its own timetable when considering the LDP means that there has already been unacceptable delay so we would urge you to expedite the next stage in the process of adoption, otherwise SBC will have no up-dated LDP to use for some very large planning applications in the pipeline, and the sceptical amongst us might begin to think that delays at national level are deliberate.  


On the main issue of the excisions to the LDP we wish to register our considerable concern that a process which is intended to arrive at an objective, rational and local development plan appears to have been subverted by what we can only suspect to be undue political influence.  This issue deserves wider public scrutiny -  the suppression of local government, local democracy and local community views surely cannot be what the present Scottish Government seeks to achieve?  Or can it?


We would welcome your individual response to these points.


Yours sincerely,




John Williams







Mr Fergus Ewing MSP

Minister for Business, Energy and Tourism

Scottish Government


Councillor Ron Smith

Chair of Planning and Building Standards Committee

Scotttish Borders Council