James Dunn, Graduate Planner, leads us through the complexities of altering Green Belt boundaries and how citing Exceptional Circumstances could help us meet the Government’s ambitious housing targets.
Given the push from Government to build more homes - one way of tackling the soaring house prices that make homeownership unattainable for so many young people - Local Housing Need figures in many authority areas will rise. Planning Authorities will increasingly need to turn to altering their Green Belt boundaries in order to sustainably allocate land for these new homes.
Our Strategic Planning Team frequently act on behalf of landowners and land promoters to get their land interests allocated for development in Local Development Plans, which form the starting point when it comes to determining planning applications further down the line. Planning Authorities typically produce a new plan at least once every 15 years and are under an obligation to review Plans at least once every five years, to assess whether they need updating, and then to update them accordingly (NPPF 2019, para 33). There are a number of opportunities throughout the preparation of new Plans and the updating of existing ones to make the case for the allocation of promoted land interests.
Local Plan policies need to be kept up to date to allocate sufficient sites for housing, to ensure a robust pipeline of new homes will be built to meet local needs into the future. Cameron Austin-Fell, one of our Strategic Land Team directors, has recently written on the Government’s proposed new approach to determining figures for Local Housing Need. It is often the case that Planning Authorities will consider that the most sustainable places to allocate housing land will be in areas which are designated as Green Belt. Green Belt boundaries can only be altered through the preparation of a new Local Development Plan, or through updating an existing Plan.
In order to alter an established Green Belt boundary, this must be justified on the basis that Exceptional Circumstances are demonstrated (NPPF 2019, para 136). To demonstrate Exceptional Circumstances, a Planning Authority must show that it has examined fully all other reasonable options for meeting its identified need for development* (NPPF 2019, Para 137). It will be a matter for the Inspector at the Local Plan Examination to determine whether Exceptional Circumstances are demonstrated.
*In particular, the Planning Authority is required to demonstrate that: 1. As much use as possible has been made of brownfield and underutilised land; 2. Development density has been optimised, including an uplift in density standards in towns and city centres and other public transport-accessible locations; and 3. Discussions with neighbouring authorities as to whether they can accommodate some of a constrained authority’s housing need, have not been fruitful, or sufficiently fruitful.
To gain a better insight into when proposals to amend Green Belt boundaries are found sound, we conducted an analysis of Local Plans adopted between January 2019 and September 2020 in which Exceptional Circumstances were cited to amend Green Belt boundaries.
In total there are 14 plans where the Inspector concluded Exceptional Circumstances are demonstrated, the reasoning for which is summarised in our report which can be downloaded here. Reviewing the Inspector’s reports, we established that the majority of the reasoning in relation to strategic-level Exceptional Circumstances relates to the need to accommodate a certain level of housing development into the future, and the inability of Local Planning Authorities to do so given the level of constraints they face.
From our analysis, we have developed an understanding of how Inspectors have approached the amendment of Green Belt boundaries in recent Local Plan Examinations and can harness this knowledge to ensure we assist with land allocation, especially where there is a Green Belt designation.
Proposals are currently under consultation for a new Standard Method, which results in a national Local Housing Need figure of 337,000 new homes annually, some 67,000 more than the current methodology. The Government’s focus on delivering larger numbers of new homes, will result in increased Local Housing Need figures for many authority areas. The imperative to alter Green Belt boundaries will become ever more pressing in the future if these targets are to be met.
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