Chapter 13
130) Do you agree that policy GB1 provides appropriate criteria for establishing new Green Belts? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
131) Please provide your reasons, particularly if you disagree.
The RTPI supports the amendments made to the policy to reassert that Green Belts should not inhibit sustainable development. Although we would recommend language around encouraging sustainable development.
132) Do you agree policy GB2 gives sufficient detail on the expected roles spatial development strategies and local plans play in assessing Green belt land? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI believes this policy fails to clearly delineate the role of SDSs from local plans in these regards. In particular, the RTPI would recommend a clearer delineation and the areas of reciprocity between GB2(1) and GB2(3). To support arrangements in the transition period, this would also include a recognition of the need for Green Belt assessments undertaken in order to prepare local plans feeding into SDSs where an adopted SDS is not already in place. An understanding of how such processes would be twin tracked would also be welcomed. Given the critical need to conduct strategic Green Belt assessments across the country in order to inform the preparation of development plans, as set out in response to Q192(a), the RTPI believes that the Government should make a central resource available which will contain the technical specialist capabilities in order to support the preparation of such assessments across the country. Such resource should be targeted towards SDSs in the first instance to support the hierarchy of Green Belt assessment set out in this policy.
133) Do you agree with proposals to better enable development opportunities around suitable stations to be brought forward? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI strongly supports the targeting of new development towards sustainable locations, however within the Green Belt the historical lack of other infrastructure use types needs to be considered. Please see our response to Q40(a) and Q138 in regard to such matters.
134) Do you agree the expectations set out in policy GB5 are appropriate and deliverable in Local Plans? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly disagree.
135) Please provide your reasons, particularly if you disagree.
The RTPI does not support the inclusion of GB5 given that it does not support the objectives set out in Chapter 13 or the application of policy GB2. It also does not support decision-making, with GB7 comfortably able to deal with development that is not inappropriate in the Green Belt. The RTPI believes that the policy intent as set out in GB5 would be more usefully included under policy HC2 to clearly highlight the role of local green space and safeguarding green areas for the benefit of community and nature.
We note that GB5 again references the Development Plan. Matters contained in GB5 may be too detailed to be dealt with at SDS level if they are to solely focus set out broad areas of Green Belt to be reviewed. The policy appears more appropriately targeted at local plans as the question suggests. Additional clarifications in these regards may help support the interrelationships between spatial plans when managing Green Belt review.
136) Do you agree policies GB6 and GB7 set out appropriate tests for considering development on Green Belt land? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the consolidation, clarification and increased proportionately. The RTPI would recommend the removal of the phraseology ‘not inappropriate’ to be replaced by ‘appropriate’ to supports its application.
137) Do you agree policy GB7(1h) successfully targets appropriate development types and locations in the Green Belt, including that it applies only to housing and mixed-use development capable of meeting the density requirements in chapter 12? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
138) Please provide your reasons, including any evidence that this policy would lead to adverse impacts on Gypsies and Travellers.
As set out in response to Q40(a) the RTPI would welcome a stronger steer regarding well-connected train stations and plan preparation. We do note some concerns around ensuring that communities are supported by all the relevant infrastructure requirements to ensure great placemaking being particularly challenging in such locations, with the historically less permissive approach to development.
We would welcome the inclusion of ‘and’ to this part of the policy to support its application. We do note the inclusion of the word ‘capable’ in GB7(1)(h)(i), which vastly increases the locations which could be considered. This may require further clarifications of footnote 52, especially around wording relating to ‘reasonable prospect of being served due to planned upgrades’.
139) Do you agree that site-specific viability assessment should be permitted on development proposals subject to the Golden Rules in these three circumstances? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the introduction in GB8 of clear and limited circumstances where a site-specific viability assessment may be justified to enable development in the Green Belt. We would welcome further detail of how such proposals will work in tandem with PM12 and DM5. We acknowledge and await the publication of viability planning practice guidance which we hope can provide further details in the application of this policy, including circumstances where development models would be considered a departure from viability assessments set out in local plans.
140) With regards to previously developed land, are there further changes to policy or guidance that could be made to help ensure site-specific viability assessments are used only for genuinely previously developed land, and not predominantly greenfield sites?
Beyond the current approach whereby determining authorities have to assess such matters on a site-by-site basis, the future review and potential strengthening of the grey belt definition may provide the most practical means of addressing this.
141) Do you agree with setting an affordable housing ‘floor’ for schemes subject to the Golden Rules accompanied by a viability assessment subject to the terms set out? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Neither agree nor disagree.
142) Please explain your answer, including your view on the appropriate approach to setting a ‘floor’, and the right level for this?
The RTPI would support option (b) whereby the affordable housing floor be set to better reflect local circumstances. The relevant Affordable Housing Need assessment could be used to set the right level through local policy. To be able to better reflect local circumstances, as set out in response to Q49, the RTPI would welcome further guidance on assessing the need of different groups who require specialist social and affordable housing provision.
We would however raise some concerns as to the complexity and detail of doing such work and the resourcing requirements of the planning system in order to do so.
143) Do you agree with local planning authorities testing viability at the plan-making stage using a standardised Benchmark Land Values scenario of 10 times Existing Use Value for greenfield, Green Belt land? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please explain your answer.
As set out in response to Q16(a) the significant variation at a regional and local level around land values and market conditions would make a policy proposal, such as this, difficult to apply.
144) Do you have any other comments on the use of nationally standardised Benchmark Land Values for local planning authorities to test viability at the plan-making stage?
The RTPI recognises the laudable intensions of nationally standardised Benchmark Land Values for local planning authorities to test viability. The current proposed approach of applying Existing Use Value plus premium is intended to create a reasonable incentive for landowners to bring development land forward for sale, in comparison with other options available, whilst allowing a sufficient contribution to fully comply with policy requirements. However, in practice it is unlikely that site purchasers are going to pay 20% more in market value once a site is fully assessed and such a premium will likely serve to reduce developer contributions. The RTPI would submit that alternative uses, looking at sites with and without planning permission is a better form of sensitivity testing.
145) Do you agree that proposed changes to the grey belt definition will improve the operability of the grey belt definition, without undermining the general protections given to other footnote 7 areas? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI supports the proposed changes to grey belt definition in order to provide better clarity.
