NPPF Deep Dive: Green Belt September 2024

Slides from NPPF Deep Dive: Green Belt from 2 September 2024.

1. Proposed reforms to the NPPF consultation and other changes to the planning system consultation: Green Belt reforms August 2024

2. Brownfield, 'Grey Belt' and the Green Belt Key Principles Overarching objective of meetin g development needs while: Maintaining a brownfield-first approach; Preserving purposes and overall function of the Green Belt; Enabling a more strategic and targeted approach to Green Belt release; Remaining l ocally and plan-led

3. Grey Belt definition

4. Grey Belt definition Links to how Green Belt is (often) assessed through Green Belt reviews. Supporting information (para 10 of Con Doc) proposed to provide greater clarity/ consistency in approach. Not prescribed specific and quantifiable measures of terms (i.e. “substantial built development”), given the likely variation across different areas. All protections on other important assets and environmental land remain in place.

5. Plan-making Sequential approach that a pplies to Housing, Commercial, or Other need Underpinning thread of sustainability – LPAs should only look to bring forward development in sustainable locations and should continue to prioritise the most sustainable development in the best locations. Development should not fundamentally undermine the function of the Green Belt over the plan area Development must satisfy “Golden Rules”

6. Green Belt Reviews We are interested in whether: Existing Green Belt reviews can be drawn upon to identify Grey Belt? It would be possible to perform a ‘light touch’ update to existing Green Belt reviews to ensure they align with proposed policy position? Further guidance, or assistance from PAS, would be helpful in achieving this?

7. Decision-making Previously Developed Land Redevelopment of PDL not inappropriate where: Does not cause substantial harm to the Green Belt Seeking views on expansion to include hardstanding and glasshouses Grey Belt Housing, commercial, and other development on Grey Belt not inappropriate where: The Local Authority: cannot demonstrate a five year supply of deliverable housing sites, or where the Housing Delivery Test indicates that the delivery of housing was below 75%, or Has a demonstrable need for land to be released for development of local, regional or national importance And the development: utilises Grey Belt land in sustainable locations, and Provides “Golden Rule” contributions, and Does not fundamentally undermine the function of the Green Belt over the plan area

8. Safeguards We are interested in reflections on whether these safeguards are sufficient to ensure that the Green Belt will continue to be protected in the right places, and whether further Guidance needed on any of these points?

9. Key questions Is the definition of Grey Belt clear? To what extent is further guidance needed? Do existing Green Belt reviews serve to identify Grey Belt, as defined in the consultation document? Is further guidance needed here? Do our proposals successfully balance the prioritisation of PDL and Grey Belt, with the requirement to bring forward the most sustainable development? How can we best ensure that our decision-making proposals do not lead to poor-quality development? For decision-making, what are appropriate ‘triggers’ for commercial/ other development? Do our safeguards give sufficient protection to the overall function of the Green Belt?

10. Golden rules Our proposed ‘ Golden Rules ’ requires the following when Green Belt land is released through plan-making or decision-making: 1. In the case of schemes involving the provision of housing, at least 50% affordable housing , with an appropriate proportion being Social Rent , subject to viability; 2. Necessary improvements to local or national infrastructure , and 3. The provision of new, or improvements to existing , local green spaces that are accessible to the public. The ‘Golden Rules’ will run with the land (i.e. if land is released from the Green Belt, the Golden Rules will still apply ). Aim: Ensure Green Belt release land fully contributes to infrastructure, environmental improvements and affordable housing need, while enabling negotiation to allow less viable sites to come forward only in circumstances where it is absolutely necessary to enable development.

11. 11 For viability assessments, it is recognised that a landowner premium above EUV is needed to incentivise a landowner to bring land forward for development. Current g uidance states that p lan-makers should establish a reasonable premium using professional judgement and best available evidence. Landowner Premium T he value of the land in its existing use. It is not the price paid and should disregard hope value. Existing Use Value This is comprised of a site’s Existing Use Value (EUV) plus a landowner premium (EUV+). Benchmark Land Value Golden Rules: principles of viability

12. Government sets Benchmark Land Values 12 Late-stage review mechanisms will be undertaken to test actual costs and revenues against assumptions made in the viability assessment This will help secure any potential additional contributions Where development can deliver the ‘Golden Rules’, we don’t mind what value the land transacts at. LPAs shouldn’t be seeking more than the ‘Golden Rules’ set out However, if land transacts at a higher price than the BLV, then viability assessment should not generally be undertaken . Contributions below affordable housing policy should be negotiated only if the land is transacting at or below BLV We are proposing that Government should set BLVs , to inform local policy making. We are interested in feedback on where and how BLVs should be set It will be harder to access viability assessments Late-stage reviews should be used if contributions are negotiated downwards Golden Rules: strengthening viability

13. Golden rules: Benefits for Nature The Rule Accessible green space is integral to making quality places Golden rule for the environment aims to bolster existing environmental requirements, such as biodiversity net gain, by setting out additional requirements This includes an objective for new residents to be able to access good quality green spaces within a short walk of their homes The golden rule will apply to residential and commercial development, as well as speculative development Standards The draft NPPF includes reference to the role of standards Where local standards and local planning policy exist in local plans, development proposals should adhere to them Where no locally specific standards exist, development should meet national standards such as Natural England standards on accessible green space, the urban greening factor and Green Flag Criteria

14. Key questions Should lower affordable housing targets be set in lower value areas? Will our proposed approach to strengthening viability assessment work effectively? What is your view on nationally-set Benchmark Land Values, given the underlying objective of providing sufficient incentives to landowners, while securing significant public benefit from the value uplift? What should Government take into account when setting indicative Benchmark Land Values? Does the proposed policy secure benefits for nature and access to green space?