Planning Policy and the Green Belt by Karen Charles, Executive Director, Boyer (part of Leaders Romans Group)

More than two years ago, we were promised a radical shake-up of the planning system. But the revised National Planning Policy Framework (NPPF), published for consultation just before Christmas, is far from radical: it is retrogressive and contrary to a wider Government aspiration to address the country’s housing crisis.

This is exemplified in its revised Green Belt policy. The Green Belt is now over 70-year old and covers 13% of the UK, surrounding 14 of the country’s 20 largest towns and cities, mostly, but not exclusively, in the south.

Since the Green Belt was introduced in the 1950s largely to control the unplanned sprawl of housing into the countryside, the UK population has grown from around 51 million to over 68 million. Housing need, and especially the requirement for affordable housing, has never been more acute.

Green Belt policy has been a success, but has led to significant house price inflation in these areas which makes owning or renting a decent home out of reach for many, including essential key workers such as  nurses and teachers.  This then has consequences for delivering public services.  Its common for those in affluent Green Belt areas to complain about not being able to get a doctor’s appointment or to get their child into the local school, or that their grown-up children have to move out of the area to get a step on the housing ladder – but do they appreciate that this problem is (at least in part) due to the failure to release Green Belt land to meet housing need?

Many local authorities are unable to meet their housing need without strategically reviewing, and ultimately accepting some development within the Green Belt.  Current Green Belt policy in the NPPF allows for this, by enabling local authorities to review Green Belt boundaries when preparing their Local Plan where exceptional circumstances can be demonstrated.  There is nothing wrong this with approach, but it relies on local authorities preparing and adopting a Local Plan; and this in itself requires local political support for Green Belt release.  Often against local opposition, elected representatives have reluctantly supported the adoption of Local Plans which release land from the Green Belt for housing to meet local housing need. 

Specifically, Chapter 13 of the proposed revisions to the NPPF, it states that, ‘Green Belt boundaries are not required to be reviewed and altered if this would be the only means of meeting the objectively assessed need for housing over the plan period.’  So, if local authorities are not required to review Green Belt boundaries to meet housing need, then doesn’t this present them with the option to reject a review of the Green Belt and consequently allows them to legitimately fail to meet local housing need?

Currently local authorities can review local Green Belt boundaries where exceptional circumstances can be demonstrated. Under this approach the Royal Borough of Windsor and Maidenhead released 210 hectares of land, one per cent of its previous total, for housing. The controversial decision followed decades of impasse on the local authority’s Local Plan and a judicial review by residents which was ultimately unsuccessful. Elected representatives of Windsor and Maidenhead – who in my opinion made the right decision, both in terms of planning policy and meeting housing need, may be kicking themselves now. Because under the proposed changes, the emphasis shifts: Green Belt boundaries are not required to be reviewed and altered as the only means of meeting the objectively assessed need for housing over the Plan period, and it will be a matter for the individual planning authority as to whether such a review takes place.

Unsurprisingly, some local authorities with a similar profile, have declared that following the proposed revisions to the NPPF, and as they may no longer have an obligation to release Green Belt land if it is the only means of meeting housing need, are considering a review of their housing targets and housing strategy.  The result of the proposed changes to the NPPF around Green Belt policy, is therefore already starting to slow down or stall plan making.  And without a Local Plan which reviews Green Belt boundaries to meet housing need, there is little prospect of these areas meeting their housing need.

Contrary to commonly held beliefs, Green Belt policy is a constraint policy, not one to protect bucolic landscapes. But rather than address this misconception and allow the controlled release of land which doesn’t fulfil the purposes of the Green Belt as defined by the NPPF, to meet housing need, the Green Belt continues to grow. 2022 saw the largest reported annual rise for 25 years. No less than 1,638,150 hectares of land in England (12.6% of all land) is allocated as Green Belt: a 1.5% increase on 2021. This is in contrast to 8% of land which is of ‘developed use’, 11% of which is classified as ‘built-up’, according to Government figures.

Where I am based, in the South East, the issue is reaching crisis point.  Affordability of homes, both to buy and to rent, is inaccessible to many, and we are now facing either delays in plan-making, or worse, Local Plans being prepared which do not properly meet their housing need by allowing for managed Green Belt release.

The sentiment of the proposed NPPF is not a significant change to existing Green Belt policy, but the significance is in the wider implications which could affect housing delivery (and consequently affordability) for generations.

Unfortunately, the proposed revisions to the NPPF prioritises Green Belt over homes, sending a message to the electorate of ‘Green Belt authorities’ that Green Belt land is sacrosanct and they can use this politically to resist unpopular Green Belt release and planned housing through their local plans.   But are they also ready to admit that this will have consequences for their public services and the affordability of homes for future generations.

Furthermore, the proposed revisions to the NPPF may make housing targets themselves a thing of the past. Were there any remaining obligation to release Green Belt to meet housing targets, this would be negated by the fact that housing targets may carry very little weight in the future.

The impact is not confined to the South East. Recently South Staffordshire Council, which predominantly comprises of Green Belt, announced a halt to work on its Local Plan following the publication of the draft changes to the NPPF; and they are not alone. Consultation on its draft Local Plan had concluded immediately prior to Christmas and the document was due to be submitted to the Inspectorate in the spring. It would have delivered 8,881 homes over a twenty year period but the majority were planned across four sites, three of which are entirely, and one partly, in the Green Belt.

Delays have also been reported as having occurred in the administrative areas of Horsham, Teignbridge, North Somerset and Mole Valley. Following the proposed policy changes, Gedling Borough Council has also withdrawn a Green Belt site from the Greater Nottingham Strategic Plan.

As the proposed revised NPPF itself states, fewer than half of local authorities have up-to-date plans (adopted in the past five years) – and this figure is rapidly diminishing.

One of the three objectives as outlined at the start of the consultation is, ‘To swiftly deliver the government’s commitments to building enough of the right homes in the right places with the right infrastructure, ensuring the environment is protected and giving local people a greater say on where and where not to place new, beautiful development’.

 I wholeheartedly support this objective and believe it to be crucial to social and economic growth.  But I believe is that this consultation fails in every respect. It fundamentally risks local authorities, particularly in Green Belt areas, failing to address housing need.  In doing so, they will fail to provide enough affordable housing, fail to attract and retain key workers, fail to maintain vital infrastructure such as schools and hospitals, and fail to deliver quality homes which are built to high environmental standards to minimise climate change.

Although the Government apparently remains committed to delivering 300,000 homes a year, this target – which hasn’t been met since the new towns boom of the 1970s – to me now seems unattainable in light of the proposed policy changes.

The consultation on the revised NPPF runs until 2 March. Whether or not the proposed changes go ahead, some damage has already been done. Already the changes are resulting not only in significant delays to Local Plans, but, as local authorities await further clarity before taking potentially unpopular decisions, to planning applications currently in the pipeline.

Sadly the situation surrounding the Green Belt is indicative of an even more concerning objective that seems to be dominating this Government’s approach to planning: the solely political objective of placating the electorate. The clarity of sound national policy on controlling the release of Green Belt land to meet housing need is being replaced with a surrender to the anti-development lobby, in the knowledge local residents and councillors in Green Belt areas represent much needed votes. The Local Plan risks being demoted from a planning document to a political manifesto.