All we hear these days is that Green Belt policy in the Housing White Paper is unchanged. Not sure I see at that way.
Why? Because the longstanding principle that exceptional circumstances cannot be defined (because they are exceptional) appears to have been pushed aside. Paragraph 39 appears to do exactly that. It confirms that Green Belt boundaries can only be amended when other options (which are then helpfully defined) have all been examined AND where local policies ensure the impact will be offset (again guidance on how to do this offsetting is provided).
In effect a sequential approach applies – GB releases can be allowed if there are no other options to meet the defined housing need plus some offsetting provisions.
Elsewhere in the document, most notably at paragraphs:
- 1.6 – 1.9 (getting plans in place)
- 1.12 – 1.15 (assessing housing requirements)
- 2.47 – 2.51 (housing delivery test)
- it seems that the Government expects housing need to be accurately assessed, defined in a local plan and then sanctions will result if supply dips under the assessed requirements.
That must feel a bit like a rock or a hard place for the 100 or so anti-development LAs who have traditionally defined artificially low targets, citing capacity constraints due to Green Belt and then deliberately undersupplied. Going forward, under the HWP if you cannot meet your own need on non-Green Belt land, and neither can your neighbours, then the defined exceptional circumstances which necessitate Green Belt releases are in play.
Of course paragraph 1.22 of the HWP stills provides a ‘get out’ by saying that other NPPF development constraint policies can provide a justification for not meeting need. And Green Belt is one of those. Nevertheless it feels like HWP is providing fewer opportunities for these recalcitrant GB LAs to duck the issue of meeting their housing needs.
Albeit lets see what the NPPF changes actually say when published in the summer.
So what does this means for planners? Well in areas like Cambridge perhaps very little. Major GB releases can (some would argue should) be avoided by exporting the need beyond the Green Belt to non-GB areas within the same housing market area. Undoubtedly less stainable but it preserves the sanctity of the green belt.
But for LAs around Birmingham, Manchester, London and Bristol the position perhaps appears more difficult. Here it will not be possible to simply export the need beyond the green belt into a completely separate housing market area. Needs are to be met and green belt releases are fully justified by the newly defined exceptional circumstances in the HWP.
This ‘new’ policy is sensible. It is plainly wrong that towns and villages within green belt, located where employment and housing needs are strongest, (and affordability worst) have historically been free to avoid releasing land because the ‘presumption in favour’ carries no weight there.
Whilst, at the same time, other similar settlements in less sustainable locations, and often more sensitive countryside, have soaked up high housing numbers year after year. Some of them bombarded by planning applications benefitting from the presumption in favour.
But two key questions remain:
1. Is this optimism naive? Are the conclusions derived simply from an unintended loophole which, will soon be closed off via the NPPF changes?
2. Even if the policy is a deliberate attempt to increase housing output where most needed will it actually change behaviours in anti-housing LAs? Some have successfully gamed the system for decades and will perhaps find a way to continue?
But as of now my view is that the HWP is clearly signposting harder times for those anti-development Green Belt LAs. That is a good thing thing and needs to be applauded.
It also gives more justification to the courageous planners and civic leaders in Manchester, Birmingham and Oxford to stay the course on their bold plans to match economic growth with housing growth via a sensible approach to growth on the urban edge.
Perhaps ironic that as we trigger Article 50 we are maybe introducing a more European approach to the urban edges of our great cities.