NPPF Changes Consultation 2015

Ensuring Housing Is Delivered On Land Allocated In Plans - Page 14

Question 20.

Should planning policy be amended to allow redevelopment of brownfield sites for starter homes through a more flexible approach to assessing the impact on openness?

  • No. We object strongly to any threats of this type to the Green Belt. The fact that it is for starter homes does not make redevelopment of brownfield land any more acceptable. Policies on brownfield sites in the Green Belt should not be dealt with in the same way as brownfield land in urban locations.
  • We believe the changes proposed will result in unexpected consequences in the Green Belt. There is a perverse incentive to owners of commercial land in the Green Belt to close viable commercial operations that are a source of rural employment and put forward their site for either starter homes or affordable housing development. 
  • We oppose any revision to the NPPF that allows ‘islands’ of housing (starter or affordable by any criteria) to appear in the Green Belt on previously developed land because the opportunity exists for LPAs to ‘inset’ and then build out into the Green Belt using the ‘urban extension’ argument during Local Plan revisions where the option to redraw Green Belt boundaries where ‘exceptional circumstances’ are proposed and approved by PINS. This will lead to the long-term deterioration of the Green Belt into a patchwork of commuter ‘islands’, leading to a loss of ‘openness’ of the Green Belt, with new settlements accessible only by car, increasing rural air pollution, rural congestion, damaging contiguous areas of wildlife habitat.
  • We propose the specific exclusion of garden centres in the Green Belt from any definition of what constitutes ‘brownfield’ land in the Green Belt. Garden centres are horticultural businesses that address rural employment objectives and attract visitors to further stimulate the rural economy.


2017 Guildford Local Plan

Guildford’s NEW local Plan has just opened for consultation. PLEASE RESPOND before 24th July 2017.  GGG has published its responses to Local Plan Policies here 


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