St Albans fails to show Green Belt review in structured Two Stage Approach

Inspectors Letter

The Local Plan proposes substantial Green Belt boundary alterations
to enable land to come forward for development. National Policy
sets out that Green Belt boundaries should only be altered in
exceptional circumstances. The nature and extent of the harm to
the Green Belt and the effect on the Green Belt objectives must be
considered in the assessment as to whether exceptional
circumstances are demonstrated.
13. As set out in our Initial Question 16, in seeking to re-draw the
Green Belt boundary we would expect to see that the Council has
followed a two- staged approach. Stage 1 concerns the evidence
gathering and assessment that leads to an in principle decision that
a review of the GB boundary may be justified to help meet
development needs in a sustainable way. It is set out at paragraph
137 of the National Planning Policy Framework (the Framework) and
requires the Council to demonstrate that it has examined fully all
other reasonable options for meeting its identified need for
14. Step 1 of this staged approach requires a thorough investigation of
the capacity of the existing urban areas (suitable brownfield sites
and underutilised land) and whether this has been maximised
having regard to optimising densities. Subtracting this from the
OAHN figure leaves the amount of development that cannot be
accommodated within the urban areas. This process also needs to
be informed by discussions with neighbouring authorities about
whether they could accommodate some of the identified need. Step
2 involves considering if there is any non-Green Belt rural land
which could meet any of the unmet need (steps 1 and 2 are
recognised at paragraph 12.1.6 of the St Albans Green Belt Review
(Doc GB001)).
15. Together these steps give a scale of unmet need which could only
be met by Green Belt release and are necessary to determine
whether the review of the Green Belt is justified in principle. Stage
2 then determines which sites would best meet the identified need
having regard to Green Belt harm and other relevant considerations
including whether they are suitably located and developable. All
these factors are then considered to reach a conclusion as to
whether exceptional circumstances exist for each of the individual
Green Belt releases.

20. As previously requested, this information needs presenting in a
Green Belt Topic paper to cover the stages, steps and questions set
out above, in order to enable our understanding of the Council’s
rationale and approach with regards to this important matter.


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