Architects, landowners and developers are often wary of
Green Belt sites as they think it cannot be built on. In fact, keys parts of
local and national planning policies actually encourage development of Green
Belt sites, so long as it is the right kind of building, supporting the right
kind of use.
This article looks at how the key planning policies promote Green Belt development and how you can use them to guide your scheme towards gaining
planning permission.
Making sense of
‘Planning Policy Guidance 2: Green Belts’*
The touchstone for all Green Belt policy is the document
‘Planning Policy Guidance 2: Green Belts’, also known as PPG2. Planning policy
in England and Wales consists of national, regional and local policies, which
describe the general and the specific of how all planning applications should
be decided. Where Green Belts are concerned, you should always check local and
regional plans for site specific policies, but many local authorities simply
refer back to central government’s guidance contained in PPG2.
PPG2 is summed up in two key paragraphs, one of which you
may find very helpful as an architect or developer and one which you will most
likely find frustrating. Paragraph 1.5 is the difficult one and explains the
criteria for designating land as Green Belt. This process is carried out by the
local planning authority and is beyond your control. Five reasons are given,
but they all basically add up to keeping the landscape open or free from
‘encroachment’. The positive outcome of this paragraph is to push development
(buildings, jobs, homes) back into urban areas. However, the local consequence
is that every square inch of Green belt is all too often treated as sacrosanct,
the last line of defence against an unending barrage of change.
The next point, however, is overwhelmingly positive. The
reason for creating Green Belts is not to create a forbidding choke-hold around
our cities. It is to provide access to open spaces within reach of crowded
cities. Paragraph 1.6 describes what activities or land uses are ‘appropriate’
for Green Belt land. If you can argue that your development will open up your
Green Belt site to the public and encourage people to appreciate its value as a
landscape (not a townscape), then you can argue that PPG2 supports your scheme.
To quote paragraph 1.6 ‘the use of land in them (Green Belt developments) has a
positive role to play in fulfilling
the following objectives;
- to provide opportunities
for access to the open countryside
for the urban population;
- to provide opportunities
for outdoor sport and recreation near
urban areas;
- to retain attractive landscapes, and enhance landscapes, near to where people live;
- to improve
damaged and derelict land around towns;
- to secure
nature conservation interest; and
- to retain land in agricultural, forestry and related uses’
I have highlighted the words that I feel encourage
development of the Green Belt and a strengthening of ties between town and
fringe.
The most frustrating thing about PPG2 is the way that it is
often misinterpreted by local planning authorities as a way of blocking
development. The Green Belt is seen as a defence against the city for rural
residents, whereas in fact it is meant to be an extension to, and integral part
of the town that it surrounds.
So, what can you
build?
The answer to that is everything and nothing.
PPG2 is very non-specific about what can and cannot be built
on Green Belt land. Only developments
judged ‘appropriate’ in terms of maintaining openness and fulfilling the
objectives such as creating opportunities for outdoor sport should be approved
but there is little guidance on what counts as ‘appropriate’ and even
'inappropriate' developments can be approved under 'very special
circumstances'.
There are no specific references to planning use classes
like D2 Assembly and Leisure or C3 Dwellinghouses. Instead, guidance on what is
'appropriate' is given in a fit of double negatives in paragraph 3.4;
‘The
construction of new buildings inside a Green Belt is inappropriate unless it is
for the following purposes:
- agriculture
and forestry (unless permitted development rights have been withdrawn – see paragraph
D2 of Annex D);
- essential
facilities for outdoor sport and outdoor recreation, for cemeteries, and for
other uses of land which preserve the openness of the Green Belt and which do
not conflict with the purposes of including land in it (see paragraph 3.5
below);
- limited
extension, alteration or replacement of existing dwellings (subject to
paragraph 3.6 below);
- limited
infilling in existing villages (under the circumstances described in the box
following paragraph 2.11), and limited affordable housing for local community
needs under development plan policies according with PPG3 (see Annex E, and the
box following paragraph 2.11); or
- limited
infilling or redevelopment of major existing developed sites identified in
adopted local plans, which meets the criteria in paragraph C3 or C4 of Annex C1'
There is little
official guidance on 'very special circumstances', but these can
include economic factors, the need for job-specific workers'
accommodation or a proven local shortage of affordable housing.
Contradiction
Herein lies the inherent contradiction
within Green Belt policy.
Any new building or development will by
definition represent a form of ‘encroachment’, in that it will
encourage people from both sides of the belt to use the space in
between. But that is exactly what other parts of the policy encourage
as opportunities for ‘access to the open countryside . . . outdoor
sport and outdoor recreation’. Paragraph 1.7 says that the openness
argument should always take precedence over the (useful) land use
objectives. But with no clarity provided on ‘openness’,
‘encroachment’, ‘sprawl’ or ‘essential facilities’, these
terms are all up for grabs and open to interpretation. If you can
show that your new building will have an acceptable effect on
‘openness’ whilst enabling an open-air use of the site, then you
can argue that your scheme is appropriate.
Who decides?
Ultimately, local planning officers and
local councillors will be the arbiters of what is 'appropriate' and
how much building is tolerable before 'encroachment' becomes an
issue. They will also decide what counts as 'very special
circumstances' and you may find that councillors will forget that
such circumstances are only needed when the use is inappropriate.
You may also find that the local
planning officer interprets ‘essential facilities’ to mean the
bare minimum requirements. This effectively threatens a hiatus on any
new leisure activities on our urban fringes or at the very least puts
the onus onto the applicant to prove the minimal nature of their
scheme, even if it is not in fact the 'minimum'. Consider, for
instance, changing rooms for sports pitches. A local sports team
might want separate changing rooms and showers for each team, plus
the referees and a small shelter for spectators (or parents). This
would be quite modest but way above the bare minimum, whereby
everyone must arrive by car already in their kit and leave the site
unwashed. This minimum does not need a building at all but falls far
short most teams' idea of 'essential'.
Unfortunately, I’m not (yet) aware of
any precedents that can challenge the restrictive, minimum
interpretation of 'essential facilities'.
In practice I have found that relying
on an 'appropriate' use is not enough when it comes to convincing
local planning officers or committee members. You generally have to
justify every square inch of footprint as 'essential', minimal and
'very special' to get any traction.
Green Belt 'appropriate' photos of
zorbing, sports pitches and car boot sales courtesy of;
eddiemcfish -
http://www.flickr.com/photos/eddiemcfish/
robertpaulyoung -
http://www.flickr.com/photos/robertpaulyoung/