BARNSLEY LOCAL PLAN EXAMINATION · result is poorer living conditions and an inadequate ... Quality...

30th June 2017

Prepared By

Helen Howie, M.A.(Hons), M.C.D., MRTPI

BARNSLEY LOCAL PLAN EXAMINATION

MAIN MATTER 6:

Is the plan’s approach to the Green Belt soundly based and consistent with national

policy (Policies GB1 & GB6)?

HEARING STATEMENT

on behalf of J. Cambidge & J. Dryden

Hearing Statement MM6

SA22058 / J. Cambidge & J. Dryden © Berrys P a g e | 2

Main Matter 6 – Hearing Statement on behalf of J. Cambidge & J. Dryden

1. Introduction

1.1. The Green Belt was established in the 1960s at a time when it was balanced by the creation

of new towns across the country. It is one half of a coin, the other half being the development

of the homes and businesses that the country needs. The Green Belt has always, and must

remain, part of an integrated approach to creating sustainable places that meet not only

environmental needs but also social and economic needs.

1.2. We strongly support the release of land from the Green Belt as essential to meeting the

borough’s needs for sustainable development. However we have concerns about the

Council’s choice of which Green Belt sites to allocate for development, and which to safeguard

for development beyond the plan period, which we do not consider justified.

2. Justification for Green Belt amendments

Issue – Do the exceptional circumstances exist to justify the release of land from the Green Belt?

2.1. Without the release of land from the Green Belt, it will not be possible for Barnsley

Metropolitan Borough Council to meet its housing needs. Brownfield sites and current

development boundaries simply do not provide enough land, as clearly shown in the Council’s

housing evidence base. The Council already assume a relatively high density of 40 dwellings

per hectare on the majority of its allocated sites and apply realistic assumptions regarding the

amount of net developable area. There is little scope to squeeze more delivery out of its

current list of sites.

2.2. If a realistic non-delivery rate is factored in, a greater amount of land is required than has

been allocated. DCLG’s statistics presented to the HBF Planning Conference in September

2015 identified a 30-40% gap between planning permissions granted for housing and actual

starts on site, with 15-20% of sites delayed in their delivery timescales and 10-20% never

materialising at all. The reasons for this are often economic, with either the landowner or

developer considering the site to be not financially worthwhile.

2.3. The gap between planning consents and completions reflects the nature of enterprise that not

all business proposals will be implemented. The better schemes with good business viability

will be delivered, and the weak schemes will not materialise. This is a natural part of any free

market economy and it is essential that this economic reality is fully taken into account by the

Local Plan. To ensure that the plan is genuinely deliverable it is necessary to ensure that

over 100% of the land supply that is needed is allocated, in order to reflect market realities.



2.4. The link between the rising cost of housing and the availability of land has been explored by

many economists, including HM Treasury’s Barker Report in 2004. The consensus among top

economists is that “the crisis of affordability” is explained by, “a longstanding and endemic

crisis of housing supply” which itself is “caused primarily by policies that intentionally constrain

the supply of housing” (Paul Cheshire, Professor Emeritus at the London School of

Economics). The Green Belt and limited housing allocations are key mechanism that

constrain housing supply. To improve housing deliverability in Barnsley Metropolitan Borough

Council’s area, it is necessary to release the breaks on land supply by significantly increasing

the amount of land identified as suitable for development.

2.5. A thorough assessment of Barnsley’s strategic housing land availability demonstrates that it

is absolutely necessary to release additional land from the Green Belt in order for the Plan to

be deliverable and effective.

2.6. In addition, some of the Green Belt sites offer highly sustainable locations, for example land

adjoining railway stations. The adverse consequences for sustainable development of not

releasing Green Belt land are sufficient to satisfy the exceptional circumstances test set out

in the National Planning Policy Framework.

2.7. In summary, the Green Belt should improve quality of life, but it will fail in achieving this if the

result is poorer living conditions and an inadequate supply of housing. The social and

economic benefits to current and future generations of tackling the housing crisis outweigh

any environmental loss of the Green Belt, particularly land that is in relatively low value

agricultural uses. Quality development that provides public open space, good landscaping

and ecological enhancements can provide a net environmental benefit that offsets the loss of

arable land, whilst contributing to the environmental aims of reducing dependence on the car

and moving to a low carbon economy. Consequently we support the release of land from the

Green Belt as necessary to the long-term economy and social sustainability of Barnsley and

meeting the three dimensions of sustainable development.

3. New Green Belt land

Issue – Do the exceptional circumstances exist to justify the inclusion of land within the Green Belt?

3.1 We have no comments on these sites.



4. Safeguarded land

Issue – Is the plan’s approach to safeguarded land sound (Policy GB6)?

4.1. The purpose of safeguarded land is to provide for future housing and employment needs in a

sustainable way. All land that is proposed for removal from the Green Belt should meet this

purpose, and to a large extent the ‘safeguarded land’ is effectively a pool of reserve sites

should any of the proposed allocations be deleted or not come forward for any reason.

4.2. The Framework envisages that any major review of the Green Belt will include identifying land

to be safeguarded for future needs. Paragraph 83 of the Framework requires that any revision

to Green Belt boundaries should also have “regard to their intended permanence in the long

term, so that they should be capable of enduring beyond the plan period.” Paragraph 85 of

the Framework requires that when defining boundaries, local planning authorities should,

“where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area

and the Green Belt, in order to meet longer-term development needs stretching well beyond

the plan period.” In light of the Framework, any Green Belt review will inevitably involve

redrawing Green Belt boundaries by more than the minimum required for the plan period.

4.3. We support the Borough Council’s proposals to take land out of the Green Belt as

‘Safeguarded Land’ to meet its longer term development needs. However we query whether

some of the safeguarded sites might be more sustainable than some of the land taken out of

the Green Belt that is proposed to be allocated, and to this extent raise concerns about

whether the proposals are adequately justified.

4.4. We consider that the Green Belt Review undertaken by Arup1 (July 2014) has in some cases

been misleadingly applied and the Council’s subsequent Supplement2 (July 2016) contains

some errors. These are taken in turn below.

1 EB103 Barnsley Green Belt Review, available at https://www.barnsley.gov.uk/services/planning-and-

buildings/local-planning-and-development/our-new-local-plan/green-belt-review/2 EB104 2016 Supplement to Stage 3 Green Belt Review



The evidence base

4.5. The Arup Green Belt Review applies a methodological approach to assessing the degree to

which sites currently contribute to the purposes of the Green Belt. The lower the score out of

25, the less important the site for retention in the Green Belt. Detailed scores are given for

each parcel, with a shorter assessment (without scoring) for residual parcels. The summary

table of Green Belt scores provides the scores for the larger parcels, however can be

misleading in relation to residual parcels, some of which have much lower scores.

4.6. For example, in relation to Green Belt parcel WOM2, the main parcel has a score in the Green

Belt study of 15 out of 25. However the residual parcel WOM2a has a much lower score,

which we have assessed in table 1 overleaf as a score of 9 out of 25.

Figure 1: Green Belt parcel WOM2 & residual parcel WOM2a

4.7. While Green Belt parcel WOM2 has a high score of 4 out of 5 for preventing merging between

Wombwell and urban Barnsley, residual parcel WOM2a merits a much lower score. Arup

acknowledge that, “Development within the southern portion of this General Area is not likely

to compromise this essential gap” but do not quantify this in terms of a score. We consider a

score of 1 out of 5 to be appropriate for residual parcel WOM2a (site AC42). Other elements

of the assessment criteria likewise provide a very different score for the residual parcel

compared to the main Green Belt parcel.



Table 1: Green Belt scores for parcel WOM2a

Purpose of the

Green Belt

Assessment criteria and comments

Our score for

residual

parcel

WOM2a

Green Belt

Study score

whole parcel

WOM2

1.Check

unrestricted

sprawl of large

built-up areas

The existing boundary has dwellings along 2

sides and abandoned allotments and a scrap

yard along a third. Arup noted that removal of

residual parcel WOM2a would neaten and

strengthen the Green Belt boundary, redefined

along Summer Lane/ Pit Lane.

1

Protects open land against urban growth of

Wombwell; will not affect Wombwell wood to the

west of the railway line.

3

Protects strategic gaps between towns - gap is

already more than 1.5km wide

3

Level at which the urban form is contained by

urban form – 50% or more merits a score of 1.

1

Average score for checking unrestricted sprawl 2 4

Assisting in

safeguarding the

countryside from

encroachment

Few beneficial use of the Green Belt – currently

no public rights of way and the allotments have

long been abandoned.

1

The residual parcel is more semi-urban in

character than it is rural. Arup noted release of

residual parcel WOM2a would mirror the recent

development to the south of Hough Lane /B6096

3

Average score for safeguarding the countryside

from encroachment

2 3

Prevent

neighbouring

towns merging

into one another

Removing parcel WOM2a will leave a remaining

gap of 1.2 miles / 2 kilometres between

Wombwell and urban Barnsley. Arup’s

assessment of the whole parcel WOM2 gives a

score of 4, but notes that “Development within

the southern portion of this General Area is not

likely to compromise this essential gap”. On this

basis we consider residual parcel WOM2a merits

a score of 1.

1

Score for preventing merging 1 4

Preserve the

setting and

special character

of historic towns

Low score appropriate as no listed buildings or

designated conservation areas in or near the

Green Belt area.

1

Score for protecting historic character 1 1

Assist in urban

regeneration by

encouraging the

recycling of

derelict and other

urban land

All Green Belt areas are awarded a consistent

baseline score of 3 unless there is significant new

development or large previously developed sites

in the area.

3 3

Score for assisting urban regeneration 3 3

TOTAL SCORE 9 15



The Council’s decisions on safeguarded land

4.8. We consider there to be inadequate justification for the choice of which sites to be removed

from the Green Belt for immediate development and which are to be ‘safeguard’ for later

development. The Council’s rationale appears to be largely contained in its Green Belt

Supplement published July 2016 (EB104). Our comments on the Council’s justification of its

safeguarded land decisions is given in table 2 overleaf.

4.9. We strongly dispute the Council’s rationale for leaving site AC42 as ‘safeguarded land’, which

does not appear to be based on any firm evidence. Its opinion that site AC42 cannot come

forward within the plan period ignores representations made by the site owners in December

2015 that outline a number of ways of providing access to the site, a copy of which is provided

in the attached Appendix 1: Local Plan submission re. site AC42. Pages 3-7 and page 22 in

the Appendix outline five potential access points to the site.

4.10. In relation to wider road issues such as congestion and accident blackspots in the vicinity,

these are addressed through Policy T4 which requires developers to take mitigating action or

to make a financial contribution to make sure any necessary improvements go ahead to

address highway safety problems or efficiency of the highway network.

4.11. Site AC42 has potential for multiple benefits, providing an opportunity to address local

highway issues and encourage greater use of public transport, as it adjoins Wombwell railway

station, which is the second busiest station in the borough. The Council have given insufficient

justification as to why this site should not be developed until beyond the plan period.

Figure 2 Safeguarded land adjoining Wombwell station

AC42 Land south of Pit Lane &

west of Windmill Road,



Table 2. The Council’s justification of its decisions on new Safeguarded Land

Safeguarded Land site

Green Belt Study Ref

Council’s Supplement (July 2016) – EB104 Comment

SAF 5

North of Staincross Common

MPW2

score of 15

“It was concluded that the first site has potential to be suitable for housing development beyond the plan period. However it was determined that given the extent of the safeguarded land needs established beyond the plan period in order to be confident that the new Green Belt boundary would endure beyond the plan period, there were exceptional circumstances to justify safeguarded a portion amounting to approximately half of the resultant parcel. A new Green Belt boundary would be formed by the field boundary which approximately divides the site into two and the existing hedgerow on the field boundary would in time be bolstered by additional planting to create a strongly defensible Green Belt boundary. The balance of the resultant parcel was not considered suitable for development needs because the Council cannot demonstrate exceptional circumstances to justify release of the larger site for development, nor or in the future, especially given the extent of development already planned for this part of the borough.

The second parcel was not considered suitable for development needs on sustainability grounds.”

The proposed new Green Belt boundary is comprised of a field boundary. This does not form an appropriate Green Belt boundary.

There is plenty of development planned for this part of the borough, such that it is difficult to justify further release.

Adjoining parcel rejected on sustainability grounds.

SAF6

West of Barugh

UB3

score of 13

“One of the parcels (UB3A) has been partially taken out of the Green Belt and safeguarded for development needs beyond the plan period (SAF6). This reflects assessment that part of the site has potential to be suitable for development beyond the plan period. It was determined that there was not significant development potential on land to the south of Royd Lane given the extent of development constraints (existing development, green space and AQMA) and the existence of Royd Lane gave the opportunity for a strongly defensible boundary. In addition, it was determined that given the extent of the safeguarded land needs established beyond the plan period in order to be confident that the new Green Belt boundary would endure beyond the plan period, there were exceptional circumstances to justify safeguarding only one of the resultant parcels. The other resultant parcel (UB3b) was not considered suitable for development or safeguarded land given its sustainability credentials and because the Council cannot demonstrate exceptional circumstances to justify release of the larger area of land for development, now or in the future, especially given the extent of development already planned for this part of the borough.”

The adjoining parcel UB3b was rejected on sustainability grounds, putting some doubt on sustainability of UB3a.

There is plenty of development planned for this part of the borough, such that it is difficult to justify further release.

SAF7 HN4

score of 15

“One of the resultant parcels (HN4A) has been designated as safeguarded land (SAF7). This reflects assessment that the site has potential to be suitable for development beyond the plan period, but that uncertainties arising from the originally (2013) planned route of HS2 indicate that delivery of the site in the plan period could not be reliably asserted. As



East of Sheffield Road, Hoyland Common

second resultant parcel (HN4B) has been allocated in part for employment (HOY1) but a portion has been retained as Green Belt, reflecting the extend of the objectively assessed need that would appropriately be met in Hoyland, and the existence of mature woodland which could form in part a strong Green Belt boundary. A third resultant parcel (HN4C) has been allocated for residential development (AC31) as it is a sustainably located site in a Principal Town.

AC33

Land north of Rockingham, Birdwell

HN6

score of 15

“The resultant parcel (HN6a) has been taken out of the Green Belt and much of the parcel has been allocated for employment development (HOY3) but the major part has been allocated as Safeguarded Land, reflecting the assessment that a substantial quantum of land on more preferable sites has already been identified in the Hoyland area. The site is allocated as safeguarded land, recognising in particular the employment development potential of the land.”

More preferable sites are available in Hoyland.

H79 Land north of Wood Walk, Hemingfield

HN8

score of 15

“One resultant parcel (HN8A) has been taken out of the Green Belt and allocated in part as safeguarded land (H79), reflecting the existence of sequentially preferable sites within Hoyland to meet the objectively assessed housing need. The remainder of the parcel has been designated as Greenspace, recognising its existing function and lack of development potential. The second resultant parcel (HN8b) was not considered suitable for development because it provides a gap between Hoyland Common and Jump which is essential to maintaining the distinctive character of these settlements and preventing them from merging.”

H85

Land NE of Hemingfield

WOM5

score of 15

“This parcel (WOM5a) has been taken out of the Green Belt. It was not allocated for housing as there are sequentially preferable sites within Hoyland to meet the objectively assessed housing need. It was concluded that the site has potential to be suitable for housing beyond the plan period and accordingly the site was allocated as Safeguarded Land (H85).”

More preferable sites are available in Hoyland.

AC42

Land south of Pit Lane & West of Windmill Rd, Wombwell

WOM2

score of 15

“The parcel WOM2a was not allocated for housing due to access issues that are unresolvable within the plan period but it was concluded that the site has potential to be suitable for housing beyond the plan period and accordingly the site was allocated as safeguarded land (AC42).”

We strongly dispute the Council’s opinion, which is not supported by evidence. Solutions to the access issues are identified in the attached Appendix 1.

AC41Pit Street, Low Valley

DAR3

score of 15

“Part of the resultant parcel is proposed for residential development (AC39) in the Local Plan. The remainder is proposed as Safeguarded Land due to highway capacity issues that are unresolvable within the Plan period.”

The western part of this site is partially in flood zone 2 along the ordinary watercourse.



Policy GB6

4.1. In the event that Barnsley Metropolitan Borough Council is unable to demonstrate a five year

supply of housing land, decisions will have to be taken as to whether policy GB6 is ‘out-of-

date’. It is more honest, fair and transparent to make it clear within the policy that the

development of safeguarded land may occur in the event of a shortfall of housing land supply.

The purpose of safeguarded land is, after all, to safeguard land for the purposes of meeting

future housing and employment needs.

4.2. It is necessary to amend policy GB6 not only to provide clarity and avoid unnecessary appeals,

but in the interests of making the Plan effective in delivering its housing requirements.

5 Conclusions

5.1. While we support the Council’s removal of land from the Green Belt as necessary, positively

prepared and consistent with national policy, we consider that decisions regarding which

Green Belt sites are to be allocated for development in the plan period and which are to be

safeguarded for later periods has not been adequately justified. In particular:

• The assessment of the contribution of residual parcels to the purposes of the Green

Belt is disputed, in particular we consider site WOM2a (site AC42) merits a score

against Arup’s criteria of 9 out of 25;

• The Council’s assessment of the developability of Green Belt residual parcels is

flawed in relation to some sites, particularly site WOM2a (site AC42) where the site

is incorrectly discounted due to access issues which are entirely resolvable.

Furthermore policy T4 would require developer contributions and/or highway

upgrades to the local highway network to resolve any difficulties.

• Inadequate justification is given as to why some key towns do not have enough

allocations to meet their requirement – for example Wombwell has allocations for

1,248 dwellings (excluding those with planning permission), some 250 dwellings less

than its total remaining requirement of 1,498 dwellings over the plan period. The

decision to safeguard land for longer term development beyond the plan period, rather

than allocate it to come forward to meet this identified need, is not justified.

5.2. In summary, some of the land proposed to be safeguarded is more suitable than some of the

proposed allocations. The more sustainable sites should be allocated, including site AC42

(residual parcel WOM2a) while the less sustainable sites and those with less defensible Green

Belt boundaries should be reserved as ‘safeguarded land’ for future use.

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