Anyone hoping for radical reform to Green Belt policy will be bitterly disappointed with this draft NPPF - but perhaps not surprised.
Given the demonstrable need in housing – especially in the south east of England where the constraints of the Green Belt are most prevalent – we are once again questioning if the text will deliver its fundamental aim of securing sustainable development and ensuring sufficient homes can be provided to meet the needs of present and future generations.
Carried forward policy
Much of existing Green Belt policy (Chapter 9) is carried forward in the new document. The five purposes remain unchanged, as do the tests for setting or amending Green Belt boundaries.
The emerging theme of a tiered structure of strategic and local policy is made clear early within the new Chapter 13: “Strategic plans should establish the need for any changes to Green Belt boundaries” and “detailed amendments to those boundaries may be made through local policies, including neighbourhood plans”.
Of greater significance however is paragraph 136 of the proposed text. It sets out a sequential approach to assessing if the exceptional circumstances exist to justify revised Green Belt policy.
It includes a brownfield first approach, a requirement for policy to optimise density (including but not only, in town and city centres, and other accessible locations) and a need for policy to think across boundaries through the statement of common ground.
It will be interesting to see these tests applied once the full weight is given to the document, six months from its final publication.
No simplification of Green Belt assessment
You will also be feeling somewhat disheartened if you were hoping for a simplification of the assessment of applications on Green Belt sites. Paragraphs 87, 88 and 89 remain mostly unchanged:
- Development remains inappropriate by definition. It should not be approved except in very special circumstances.
- ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations. (In a slight revision to wording, “substantial weight [should be] given to any harm to the Green Belt”).
- Finally, there are a number of exceptions where the development would not be considered to be inappropriate.
These exceptions remain principally as set out at paragraphs 89 and 90 of the existing text. However,
- “Provision of appropriate facilities for outdoor sport, outdoor recreation, and for cemeteries” now includes burial grounds and allotments and also makes provision for existing or proposed uses of land;
- “Limited infilling or the partial or complete redevelopment of previously developed land” has been refined to make the tests easier to reach in respect of affordable housing schemes; and
- Where neighbourhood forums take a positive and proactive approach to development, “development brought forward under a Community Right to Build Order or Neighbourhood Development Order” is also ‘not inappropriate’, where it retains openness.
One step forward, two steps back
On the face of it, this wording represents a relaxation of existing policy however, when you review the revised definition of previously developed land (which now excludes land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape) we are left with a feeling of ‘one step forward and two steps back’.
On a more positive note however, we have not seen a move to tighten Green Belt policy as set out within the draft London Plan (Dec 2017). Within the context of London, hopefully this will lead the Mayor to reconsider his approach.
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