Cambridge Joint Inspectors Want More City Fringe Green Belt Development – The Lesson

A letter from the joint inspectors on plans I was deeply involved with.  The plans had undertaken a Green Belt review and proposed small scale release.

A number of respondents have questioned the methodology employed in the Green Belt Review and we have found it difficult, in some cases, to understand how the assessment of ‘importance to Green Belt’ has been derived from the underlying assessments of importance to setting, character and separation. … Whatever the shortcomings of the Green Belt Review may be, the Councils accept that it does not take account of the need to promote sustainable patterns of development, as required by paragraph 85 of the National Planning Policy Framework. In response to our question on this point under Matter 6Aiii, the Councils indicated that this requirement had been taken into account in the wider evidence base across a range of documents. Following a further request the Councils provided a more detailed Note of where this information could be found. The Note provides more detailed references across a significant number of documents, but this kind of paper trail does not aid clear comprehension and we have found it difficult to understand how the various dimensions of sustainable development were assessed in accordance with the requirements of paragraph 85 of the National Planning Policy Framework.

The situation being is the assessment on certain key sites was deliberately fudged because cllrs considered there was too much development in the Trumpington Area (especially) already – lesson never ever do this you will always be found out.

It might be expected that such an exercise would be carried out through the SEA/SA process. However, larger releases of Green Belt land to meet development needs were rejected at an early stage in the process of sustainability appraisal. No further consideration was given to a number of proposals for development on the urban edge on the grounds that these could not be considered as reasonable alternatives. Bearing in mind the conclusions of the SDSR and the apparent shortcomings of the Green Belt Page 3 of 5 Review (see above) we have significant concerns regarding the robustness of the SEA/SA process.

Senior officers in both authorities undertook long and personal attacks on me simply for daring to suggest that reasonable alternatives should be considered.  How much money has this now wasted.

This is not to state that Green Belt release is easy around Cambridge or that most sites are not problematic in some way, but not even to consider some of the better ones?

The inspectors conclusion sums up the perversity of the Boles doctrine

if the Green Belt is to be protected, the plans should make it clear that the Sustainable Development Strategy will not be pursued beyond the completion of existing commitments and the very limited releases of Green Belt proposed through the Plans currently under examination.

 

Ok protect every inch of the Green Belt if you wish but dont pretend this is sustainable seems to be the conclusion.

To summarise, we are concerned that an apparent inconsistency between the SDSR and the Plans’ reliance on meeting development needs in new settlements may lead to a finding of unsoundness. Without further work we are not confident that we could recommend modifications to overcome these concerns.

They have an important finding on the NPPF issue of the affordability ‘boost’

There is no evidence before us that the Councils have carried out the kind of assessment of market signals envisaged in the Guidance; or considered whether an upward adjustment to planned housing numbers would be appropriate. It is not, in our view, adequate simply to express doubts as to whether such an upward adjustment would achieve an increase in the provision of affordable housing (which appeared to be the approach taken by the Councils at the hearing), or to suggest, as in the Councils’ Matter 3 Statement, that this could only be tackled across the HMA, rather than in individual districts. There should be clear evidence that the Councils have fully considered the implications and likely outcomes of an upward revision in housing numbers on the provision of affordable housing.

Of course you need a big boost to make a modest difference, but that does not mean it is wise to make no boost to not make a small difference.  It is always wise to add a couple of thousand to assuage inspectors on this point.

we consider that the best course of action would be for the Examinations to be suspended while the Councils revisit the sustainability appraisals so as to appraise all reasonable alternatives (including sites on the urban edge) to the same level as the preferred option, and to suggest modifications based on that work. For the avoidance of any doubt this letter should not be interpreted as an indication that further releases of Green Belt land would be necessary to ensure soundness.

This puts two options, land at Trumpington Meadows (a small site) and south of Cambridge (Great Shelford) in the frame, the other options are very landscape sensitive.  The political problem is the latter is almost entirely in South Cambs, and the landowner has presented a dreadful masterplan, but that should not stop the councils putting forward its own with rail and guided bus links. The new settlements in Cambridgeshire will take a long time to come online, and it is not acceptable for Cambridge to suffer some of the higehst house prices in the country when a soft fringe site exists which so happens to be Green Belt.

One thought on “Cambridge Joint Inspectors Want More City Fringe Green Belt Development – The Lesson

  1. In St Albans, Stage 1 of an independent Green Belt Review identified just 16 sites worthy of consideration: 8 large ones and 8 smaller ones. The Councillors immediately dropped the 8 smaller ones and asked the consultants to consider only the other 8 in more detail in Stage 2.

    The consultants (Sinclair Knight Merz) did this and eventually ranked the 8 in terms of the significance each made to the Green Belt. Two sites adjacent to Hemel were considered to contribute the most to the Green Belt and so were ranked below the other six in order of suitability for release. The Councillors then instructed Officers to produce a sustainability assessment of all 8, and those results produced a different ranking in which the two Hemel sites came out on top.

    Amazingly, the relative harm to the Green Belt that the 8 sites made became irrelevant: in respect of potential site allocations, the Councillors were content to put weight solely on the in-house assessment of the relative sustainability of the sites.

    That sustainability assessment remains riddled with factual inaccuracies and unclear weightings. However, the lack of any weighting for Green Belt harm is the most serious failing of all.

    Furthermore, whilst part of one of the large 8 sites was considered (North West Harpenden), the Councillors refused to assess and compare parts of the other 7 large sites and none of the 8 smaller sites. So, as in the Cambridge City and South Cambridgeshire example you cite here, it is clear that not all of the reasonable alternatives have been considered.

    As it is, St Albans Council is only proposing to build on 4 of the large sites (including the two adjacent to Hemel, for which it has no agreement from Dacorum), because it argues it only has to release sufficient Green Belt land to contribute towards 436 dwellings per annum for its 2011-31 Plan Period: 436 representing, the Councillors insist, the full, objectively assessed need for housing.

    This is still the Councillors’ position today despite:

    (a) a Housing Needs Study (published Dec 2013 and limited to the District Boundary) identifying the housing need as 586 per annum, and

    (b) the DCLG 2012 household projections (published Feb 2015), identifying it as 637 per annum (the “starting point”, to which the PPG requires account to be taken of past under-delivery, market signals and – as the Cambridge Note covers, too – the deliverability of affordable housing!)

    Dr Turkington of Housing Vision carried out the Housing Needs Study in 2013 and will be presenting a revised Report to Councillors at a public meeting which will be webcast on 11th June 2015.

    It will be interesting to see:
    * how much Dr Turkington revises up his previous recommendation of 586 dwellings per annum in light of the PPG requirements and the DCLG household projections;
    * whether or not the Councillors finally concede that 436 is an obvious and significant under-calculation of the full, objectively assessed need for housing; and
    * whether or not Officers will brief Councillors on the Cambridge City and South Cambridgeshire experience.

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