Navigating Green Belt Development: Utilising the Greenbelt Development Toolkit

The recent government consultation on the revised National Planning Policy Framework (NPPF) introduces significant changes to the planning system, especially regarding housing delivery targets and development in the Green Belt. For developers and local authorities, this brings both challenges and opportunities. At ET Planning, we have developed a comprehensive Green Belt Toolkit to help navigate these new requirements effectively. This Toolkit includes the following:

• Green Belt Statement (including land supply analysis and Green Belt sequential test)

• Sustainability Statement

• Statement of Community Involvement

• Affordable Housing Statement (development viability assessments)

Understanding Green Belt Development Requirements

The NPPF consultation draft clearly outlines the specific circumstances under which development in the Green Belt can be considered appropriate:

• Inappropriate Development: Any development in the Green Belt is generally deemed inappropriate unless it falls within an exception criteria or meets very special circumstances, such as significant community benefits or addressing urgent local housing needs.
• Exceptions: Certain developments, including development on previously developed land,  agricultural buildings, outdoor sports facilities, and limited infilling in villages, or circumstances where a housing land supply is not being maintained, can be exceptions if they maintain the openness of the Green Belt and do not conflict with its purposes​​.
• Very Special Circumstances: Development that provides substantial community benefits, such as affordable housing, may in addition be considered under very special circumstances. This is particularly relevant when local authorities cannot demonstrate a five-year supply of deliverable housing sites​​.

Golden Rules for Developing in the Green Belt

In light of the government’s revised housing targets and new planning policies, there are essential guidelines for proposing development in the Green Belt, referred to by the government as the ‘Golden Rules’. These rules seek to ensure that while accommodating housing needs, the integrity and purpose of the Green Belt are maintained.

1. Affordable Housing Mandate: All developments on Green Belt land must deliver at least 50% affordable housing (subject to viability). This is crucial for addressing local housing shortages while maintaining social equity.
2. Grey Belt Prioritisation: Before considering Green Belt land, councils must identify and prioritise ‘Grey Belt’ areas — land that is on the edge of existing settlements or underutilised, such as old petrol stations or car parks, or land currently within the Green Belt that has little functional value.
3. Enhanced Access to Green Spaces: Development plans or proposals for development in the Green Belt should incorporate increased access to green spaces, ensuring that new communities benefit from high-quality outdoor environments.
4. Infrastructure Integration: Necessary infrastructure, including schools, GP surgeries, and transport links, must be planned and integrated into new developments, or demonstrate local supply/provision already exists. This ensures that new housing is sustainable and supports community well-being.
5. Environmental Safeguards: Any land safeguarded for environmental reasons must remain protected. Development proposals must still demonstrate a net gain in biodiversity and not compromise these areas.

The Challenge of the Five-Year Housing Land Supply

One of the critical issues highlighted in the consultation is the ability of local authorities to demonstrate a five-year housing land supply. With the proposed 50% uplift in housing targets, many authorities will find it challenging to meet these requirements, especially in areas with significant Green Belt land and a history of under delivery of housing against local housing targets. As part of the comprehensive approach offered by our Green Belt Toolkit, we offer two products within this Toolkit  which are specifically designed to address these challenges:

• Land Supply Analysis: We conduct thorough analyses to identify and assess suitable land within and outside the Green Belt that can contribute to meeting the new housing land supply requirements, ranking the sites suitability and sustainability. In the context of development proposals in the Green Belt, this can help demonstrate that there are no alternative sites that might meet the housing needs in a better way than the scheme being promoted.
• Development Viability Assessments: Our team assesses the financial viability of potential developments, ensuring that projects are feasible within the constraints of Green Belt policies and other planning regulations​​.

The Importance of Development Viability in the Green Belt

The NPPF consultation draft provides additional guidance on development viability in relation to Green Belt release. While the government aims for at least 50% affordable housing in major developments on former Green Belt land, there are situations where delivering this target might not be feasible. Annex 4 outlines the criteria under which delivering less than 50% affordable housing could be considered appropriate:

1. Benchmark Land Value: A benchmark land value, based on the existing use value (EUV) of the land plus a reasonable premium for the landowner, should be established. This value should guide both plan-making and decision-taking processes​​. At ET Planning we can help establish and evidence the benchmark land value.
2. Policy Compliance and Land Transactions: If land is transacted above the benchmark land value and cannot deliver policy-compliant development (including affordable housing targets), planning permission should generally not be granted. Conversely, if the land is transacted below the benchmark value but still cannot meet policy requirements, the applicant must justify the need for a viability assessment​​ to explain the level of affordable housing provision that can be provided. At ET Planning we can produce a Financial Viability Assessment, that sets out the level of affordable housing that can be supported by a development proposal. No development should be ‘required’ to provide more that 50% affordable housing.
3. Viability Negotiations: In cases where a viability assessment is warranted, and a negotiation leads to a reduction in policy delivery (including affordable housing), a late-stage review should be conducted. This review assesses whether further contributions can be made as the development progresses​​.

What can you do?

Navigating the complexities of Green Belt development can be daunting, but with the right expertise and tools, it is achievable. At ET Planning, our Green Belt Toolkit is designed to provide comprehensive support, from initial site appraisals, through to site promotion and/or planning application submissions.

Contact David Wetherill , Head of Strategic, Derek Clarke, Director of Economics and Ben Temple, Executive Director on how ET Planning may unlock the development potential of your Green Belt site. Email office@etplanning.co.uk or call us on 01344 508 048.

By leveraging our expertise and tailored services, you can navigate the challenges of Green Belt development and contribute to meeting the urgent housing needs of your community.