A Subtle Reprieve by Barwell for Bradford’s Green Belt

From the letter removing the local plan holding direction.

The Secretary of State acknowledges that the Plan does not alter the existing boundaries of the Green Belt and that any future changes to Green Belt boundaries will be through the preparation of Site Allocation Development Plan Documents (“Site Allocations”).

The National Planning Framework is clear that Green Belt boundaries should be amended only “in exceptional circumstances” when plans are being prepared. In removing the holding direction the Secretary of State is not accepting that the exceptional circumstances exist to justify the amendment of any specific Green Belt boundaries. The powers of intervention available to the Secretary of State under sections 21 and 21A of the Planning and Compulsory Purchase Act 2004 can be exercised on any development plan document and the Secretary of State will consider their use on any Site Allocations brought forward. The Housing White Paper (February 2017) set out certain proposed amendments to the Framework to make clear that authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements.

The Government is consulting on these proposed amendments. If the National Planning Policy Framework were to be amended to implement the proposals in the White Paper the Secretary of State would expect the Site Allocations to clearly set out that all other reasonable options for meeting the need identified in the Plan have been examined.

The Government will be consulting on proposals to introduce a new standard methodology for calculating objectively assessed need. Depending on the outcome of the consultation, it may be appropriate for the Council to consider whether an early review of the Plan should be undertaken, which in turn should inform any housing development strategy set out in future Site Allocations. Under section 26 of the Planning and Compulsory Purchase Act 2004 the Secretary of State retains the ability to direct local planning authorities to review any development plan document.

The letter is not particularly well written in the first highlighted clause.  It does not mean that the SoS thinks exceptional circumstances dont exist.  Absence of a positive at this stage does not imply a negative.  It would have been better put – this decision does not imply that the SoS considers that the exceptional circumstances test has been met for any specific Green Belt boundary.  Such a decision is uncessary at this stage and the SoS has not been called on to make it.

However the standardised methodology issue is crucial.  As the LP Inspector acknowledged the OAN was based on 2012 data, and the latest household projkections using the ‘standardised methodology’ imply 10,000 less.  This by itself would remove most of the need for Green Belt releases.  However there is an issue over whether the methodology properly compensentaes for supression of household formation during the Great Recession.  A critical issue for inspectors at many recent inquiries.

As I understand it though the ‘standard’ method would result in big increases in the South and Souith East in some Northern Cities such as Leeds and Bradford it implies big reductions.  So it is clear the SoS is holding his powder dry, and Braford should move swifly onto a review and not just a narrow site allocations document.  In any event the programme defined by Braford was odd, Green Belt definition is a strategic matter not a site allocations matter.


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