New Green Belt Study - Billericay Under the Cosh!
Introduction
In March 2022, the then emerging Basildon Local Plan was withdrawn with one of the reasons being that it was too harmful to the Green Belt. The implication being that the Green Belt should serve as a valid constraint and that boundaries should not be changed simply to meet a housing target; a target that was deemed too high for the true local housing need due to the Government’s ‘one size fits all’ algorithm.
Work started right away on the new Local Plan and one of the first actions was to commission a new Green Belt Study or review. The Council had no need to do this. It was not mandated as part of the planning making process, however, Basildon Council commissioned independent consultants to produce a new Green Belt Study to replace its internal Green Belt Review from late 2017.
In this brief report we look at that new Study and consider its implications.
The new Green Belt Study and the previous Review can be viewed by clicking on the following images. They will open in a new tab.
Work started right away on the new Local Plan and one of the first actions was to commission a new Green Belt Study or review. The Council had no need to do this. It was not mandated as part of the planning making process, however, Basildon Council commissioned independent consultants to produce a new Green Belt Study to replace its internal Green Belt Review from late 2017.
In this brief report we look at that new Study and consider its implications.
The new Green Belt Study and the previous Review can be viewed by clicking on the following images. They will open in a new tab.
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Overview of the 2017 Review and New Study
There is no set way to carry out a Green Belt Study. Local Authorities and their consultants (where they use them) have great leeway. The Studies are intended to inform Council decision making on reviewing or even changing Green Belt boundaries when allocating sites in a Local Plan, or when considering planning applications. A Local Plan is where the local extents of the Green Belt are defined and only a new or updated Local Plan should change the boundaries.
The new Study is less thorough in its approach than the last Review from 2017, and ‘scores’ the Green Belt lower. Regrettably, both are generally sound in their approach despite the differing outcomes.
We think that having spent money on a new Study the Council will use it to inform the new emerging Local Plan decision making, but should the Council want to preserve more of the Green Belt then it might choose to draw on the earlier Review from 2017, which did have good support.
In December 2021, a Council Committee was advised by its officers that the 2017 Green Belt Review had been assessed by the Government’s Planning Advisory Service (PAS), as well as an independent consultant, and was considered to be robust.
No Green Belt Study or Review is perfect, but the Basildon Review from 2017 values Green Belt land more highly and is objectively superior. That earlier Review was carried out by a team of Basildon Council planning staff who worked, and some of whom presumably lived, in the borough. They would have had a very solid local knowledge as a foundation, and then carried out detailed work, visiting, photographing and describing every site in detail before the parcel was graded against the Green Belt purposes.
Note: As described in the case study further on, the Potash Road Inspector ruled that the 2017 Review undervalued that location (and presumably others). It could therefore be considered that the 2017 Review was fairly aggressive in its outlook.
Note: a single consultancy called LUC (Land Use Consultants) responded to the Invitation to Tender and in November 2022 they were appointed. Every consultant has its own methodology for Green Belt Studies, so the fate of the borough’s Green Belt has, to a large extent, been determined by the terms of the Invitation to Tender.
The new Study appeared to have been completed with a first draft by August 2023, and finalised in December 2023, but not released until August 2024 when it was published as part of the evidence base for the emerging Local Plan. In contrast to the 2017 Review, the new Study was desk based suggesting that there were no, or few, visits to the locations. We see this a major failing, but it is recognised approach, no doubt being quicker and less costly.
The new Study is less thorough in its approach than the last Review from 2017, and ‘scores’ the Green Belt lower. Regrettably, both are generally sound in their approach despite the differing outcomes.
We think that having spent money on a new Study the Council will use it to inform the new emerging Local Plan decision making, but should the Council want to preserve more of the Green Belt then it might choose to draw on the earlier Review from 2017, which did have good support.
In December 2021, a Council Committee was advised by its officers that the 2017 Green Belt Review had been assessed by the Government’s Planning Advisory Service (PAS), as well as an independent consultant, and was considered to be robust.
No Green Belt Study or Review is perfect, but the Basildon Review from 2017 values Green Belt land more highly and is objectively superior. That earlier Review was carried out by a team of Basildon Council planning staff who worked, and some of whom presumably lived, in the borough. They would have had a very solid local knowledge as a foundation, and then carried out detailed work, visiting, photographing and describing every site in detail before the parcel was graded against the Green Belt purposes.
Note: As described in the case study further on, the Potash Road Inspector ruled that the 2017 Review undervalued that location (and presumably others). It could therefore be considered that the 2017 Review was fairly aggressive in its outlook.
Note: a single consultancy called LUC (Land Use Consultants) responded to the Invitation to Tender and in November 2022 they were appointed. Every consultant has its own methodology for Green Belt Studies, so the fate of the borough’s Green Belt has, to a large extent, been determined by the terms of the Invitation to Tender.
The new Study appeared to have been completed with a first draft by August 2023, and finalised in December 2023, but not released until August 2024 when it was published as part of the evidence base for the emerging Local Plan. In contrast to the 2017 Review, the new Study was desk based suggesting that there were no, or few, visits to the locations. We see this a major failing, but it is recognised approach, no doubt being quicker and less costly.
Figure 1. The borough from the new Green Belt Study showing harm ratings for each parcel of land
New Green Belt Study - Parcels and Scoring
All Green Belt Studies divide the Green Belt into parcels or defined areas and then score these parcels against the five ‘Green Belt purposes’ as described below.
The new Study divides the Green Belt into illogical parcels. In contrast, the previous Green Belt Review divided the Green Belt into logical parcels based on natural and human boundaries such as roads, railways, field extents, watercourses, and the borough and existing Green Belt boundaries.
This was done with a regard to the National Planning Policy Framework (NPPF) requirement to secure or create robust and permanent Green Belt boundaries. Peter Brett, carrying out the recent Thurrock Green Belt Study, appears to use that approach. Arup used the same approach in the withdrawn Hertsmere Plan. Such an approach is above suspicion of gerrymandering.
The 2017 Review uses a three-tier scoring method, which is simple and intuitive, being similar in approach to a traffic light rating (red, amber, green) used in so many walks of life.
The new Study uses a four-tier scoring approach. The way this is implemented with little Green Belt (especially Billericay Green Belt) meeting the higher bands makes this another tool by which the value of Green Belt is devalued in this Study.
The new Study divides the Green Belt into illogical parcels. In contrast, the previous Green Belt Review divided the Green Belt into logical parcels based on natural and human boundaries such as roads, railways, field extents, watercourses, and the borough and existing Green Belt boundaries.
This was done with a regard to the National Planning Policy Framework (NPPF) requirement to secure or create robust and permanent Green Belt boundaries. Peter Brett, carrying out the recent Thurrock Green Belt Study, appears to use that approach. Arup used the same approach in the withdrawn Hertsmere Plan. Such an approach is above suspicion of gerrymandering.
The 2017 Review uses a three-tier scoring method, which is simple and intuitive, being similar in approach to a traffic light rating (red, amber, green) used in so many walks of life.
The new Study uses a four-tier scoring approach. The way this is implemented with little Green Belt (especially Billericay Green Belt) meeting the higher bands makes this another tool by which the value of Green Belt is devalued in this Study.
Green Belt Purposes and typical approaches to Green Belt Studies
After dividing the Green Belt into parcels, reviewers then score parcels against Green Belt purposes.
The Green Belt has five official purposes:
a) to check the unrestricted sprawl of large built-up areas.
b) to prevent neighbouring towns merging into one another.
c) to assist in safeguarding the countryside from encroachment.
d) to preserve the setting and special character of historic towns.
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All the Studies or Reviews we have seen disregard the last of these, as all Green Belt land equally fulfills this vital purpose.
One challenge the reviewers have is that these purposes were not established in order to facilitate Green Belt Studies; the Green Belt is intended to be ‘permanently open’.
Indeed, the first three of these purposes are broadly similar, so some reviewers engage in clever word play to redefine these purposes in order that they’re better distinguished from each other for the purposes of the Green Belt Study process. LUC is particularly culpable of putting the cart before the horse in this way.
The Green Belt has five official purposes:
a) to check the unrestricted sprawl of large built-up areas.
b) to prevent neighbouring towns merging into one another.
c) to assist in safeguarding the countryside from encroachment.
d) to preserve the setting and special character of historic towns.
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
All the Studies or Reviews we have seen disregard the last of these, as all Green Belt land equally fulfills this vital purpose.
One challenge the reviewers have is that these purposes were not established in order to facilitate Green Belt Studies; the Green Belt is intended to be ‘permanently open’.
Indeed, the first three of these purposes are broadly similar, so some reviewers engage in clever word play to redefine these purposes in order that they’re better distinguished from each other for the purposes of the Green Belt Study process. LUC is particularly culpable of putting the cart before the horse in this way.
Purpose A: to check the unrestricted sprawl of large built-up areas
It has been decided that Basildon counts as a ‘large built-up area’ but Billericay and Wickford do not, meaning that Billericay and Wickford Green Belt will be harder to defend than Basildon Green Belt.
Brentwood’s Green Belt Study (produced by Crestwood international) included even very small villages as ‘built-up areas’ for this purpose, e.g. Herongate and Wyatt’s Green, though there were some exclusions.
Even LUC’s Green Belt Studies for other borough’s include towns such as Tonbridge and Strood as ‘built up areas’, despite being roughly the same size as Billericay. It begs the question, was the exclusion of Billericay and Wickford as large built-up areas a unilateral decision by LUC?
Brentwood’s Green Belt Study (produced by Crestwood international) included even very small villages as ‘built-up areas’ for this purpose, e.g. Herongate and Wyatt’s Green, though there were some exclusions.
Even LUC’s Green Belt Studies for other borough’s include towns such as Tonbridge and Strood as ‘built up areas’, despite being roughly the same size as Billericay. It begs the question, was the exclusion of Billericay and Wickford as large built-up areas a unilateral decision by LUC?
Purpose B: to prevent neighbouring towns merging into one another
Billericay and Wickford count for this purpose, but smaller settlements such as Little Burstead do not. This is a similar approach to the last Study, though the new scoring for this purpose is much lower than in the last Study.
The new Study scores edge of town sites (already the most at risk) as contributing less to this purpose.
The new Study scores edge of town sites (already the most at risk) as contributing less to this purpose.
Purpose C: to assist in safeguarding the countryside from encroachment
The approach is broadly similar to the 2017 Review, but with some differences aside from the generally lower scoring.
For instance, the new Study argues that parks and sporting uses do not constitute ‘countryside’ This means the Hannakins Farm Playing Fields scores nothing, because there are cricket and football fields there, although it is Green Belt.
We think this misrepresents the meaning of the word ‘countryside’. Furthermore, we understand outdoor sports fields are considered an appropriate use of Green Belt.
Like for Purpose B, the Study scores edge of town sites as contributing less to this purpose. It is hard to understand the rationale for this.
For instance, the new Study argues that parks and sporting uses do not constitute ‘countryside’ This means the Hannakins Farm Playing Fields scores nothing, because there are cricket and football fields there, although it is Green Belt.
We think this misrepresents the meaning of the word ‘countryside’. Furthermore, we understand outdoor sports fields are considered an appropriate use of Green Belt.
Like for Purpose B, the Study scores edge of town sites as contributing less to this purpose. It is hard to understand the rationale for this.
Purpose D: to preserve the setting and special character of historic towns
The 2017 Review considered beneficial interaction between the Billericay High Street, Great and Little Burstead (architectural) Conservation Areas, and adjacent areas of Green Belt. It also considered the contribution that Ancient Woodlands made to this purpose of the Green Belt. The new Study does none of this, instead asserting that this purpose applied nowhere in the borough.
With regard to Billericay, it rather strangely asserts:
With regard to Billericay, it rather strangely asserts:
Figure 2. LUC Green Belt Study on Billericay and Purpose 4. Reference 17 DOES NOT support the statement
This is poor. Firstly, it is geographically dubious, Billericay High Street is positioned on the watershed of the Wid (a sub-tributary of the Blackwater) and Crouch catchments. The Thames catchment is miles away. The comments about housing developments and detrimental mature trees are waffle.
Secondly, “Reference 17”, relates to a Basildon Council document produced in 2011 for a different purpose that holds some throwaway remarks about the Thames and Crouch valley, but in other ways does not support the assertions made.
Billericay’s High Street Conservation Area and its adjacent Green Belt is central to the character of the town. We are fortunate and very unusual in having two Green Belt ‘green wedges’ that reach the High Street Conservation Area (Laindon Road/Frithwood Lane and Mill Meadows) plus a third (Norsey Wood) which comes close.
The earlier Green Belt Review implicitly recognised this, the failure of the new Study to do so is a serious oversight.
Secondly, “Reference 17”, relates to a Basildon Council document produced in 2011 for a different purpose that holds some throwaway remarks about the Thames and Crouch valley, but in other ways does not support the assertions made.
Billericay’s High Street Conservation Area and its adjacent Green Belt is central to the character of the town. We are fortunate and very unusual in having two Green Belt ‘green wedges’ that reach the High Street Conservation Area (Laindon Road/Frithwood Lane and Mill Meadows) plus a third (Norsey Wood) which comes close.
The earlier Green Belt Review implicitly recognised this, the failure of the new Study to do so is a serious oversight.
2024 Planning Reforms & ‘grey belt’
In July 2024 the new Government proposed the introduction of the grey belt. Whilst the definition is somewhat hazy and open to subjective interpretation, it is in essence land that sits within the Green Belt that has been previously developed. The suggestion is that after brownfield, grey belt would be the next category of land to be used for development, followed by prime Green Belt in need to make mandated housing targets.
The new Basildon Council Green Belt Study predates the concept of grey belt and does not take it into consideration. It simply looks at the current Green Belt in terms of its contribution to the 5 purposes described above.
Should grey belt be approved and become part of the planning hierarchy we would expect Basildon Council to reconsider the new Green Belt Survey accordingly to properly identify the pre-developed areas and create that tier of land. Whilst we do not support the grey belt concept, if it does become part of legislation then it must be correctly and transparently applied.
Our concern is that significant areas of pre-developed land within the Green Belt has been rated highly as contributing to the 5 purposes and as such will not be allocated for development. Conversely, we are seeing areas of prime Green Belt that has never been developed, and is largely active farmland, rated very lowly against the 5 purposes.
This is an area that we need to watch very carefully as the legislation progresses and the new Basildon Local Plan firms up.
The new Basildon Council Green Belt Study predates the concept of grey belt and does not take it into consideration. It simply looks at the current Green Belt in terms of its contribution to the 5 purposes described above.
Should grey belt be approved and become part of the planning hierarchy we would expect Basildon Council to reconsider the new Green Belt Survey accordingly to properly identify the pre-developed areas and create that tier of land. Whilst we do not support the grey belt concept, if it does become part of legislation then it must be correctly and transparently applied.
Our concern is that significant areas of pre-developed land within the Green Belt has been rated highly as contributing to the 5 purposes and as such will not be allocated for development. Conversely, we are seeing areas of prime Green Belt that has never been developed, and is largely active farmland, rated very lowly against the 5 purposes.
This is an area that we need to watch very carefully as the legislation progresses and the new Basildon Local Plan firms up.
Conclusions
As we said before, Basildon Council did not need to conduct another Green Belt Study, but we are where we are, and the signs are worrying.
If the original intent was to strengthen the Green Belt such that a new Study could be used to justify a new Local Plan with a below target housing number, then the opposite is now the case.
Considering that the new Government has put house building at the top of its agenda, coupled with higher housing targets and expecting the Green Belt to be used where necessary, this new Green Belt Study comes at a very unfortunate time. Bluntly, it supports the Government’s aims, and it is inevitable that Basildon Council will follow that national agenda. In fact, the Council has already stated that it plans to meet the new higher housing target in full (over 27,000 over 20 years) and that will require considerable areas of the Green Belt to be released for in excess of 16,000 houses.
We now need to wait for the first draft of the new Basildon Local Plan, due in October/November 2024, to see exactly where sites will be allocated. We will have the chance to comment on that plan, and the Green Belt Study, through the formal public consultation that will run to the end of this year.
If the original intent was to strengthen the Green Belt such that a new Study could be used to justify a new Local Plan with a below target housing number, then the opposite is now the case.
Considering that the new Government has put house building at the top of its agenda, coupled with higher housing targets and expecting the Green Belt to be used where necessary, this new Green Belt Study comes at a very unfortunate time. Bluntly, it supports the Government’s aims, and it is inevitable that Basildon Council will follow that national agenda. In fact, the Council has already stated that it plans to meet the new higher housing target in full (over 27,000 over 20 years) and that will require considerable areas of the Green Belt to be released for in excess of 16,000 houses.
We now need to wait for the first draft of the new Basildon Local Plan, due in October/November 2024, to see exactly where sites will be allocated. We will have the chance to comment on that plan, and the Green Belt Study, through the formal public consultation that will run to the end of this year.
Case Studies
Unfortunately, we do not have the resources to analyse every parcel of land in the new Green Belt Study, however, we have considered two sites in Billericay that highlight the differences in approach and outcome over the 2017 Review. Our findings are on the following pages.
We will attempt to look at more locations in due course.
We will attempt to look at more locations in due course.
Case Study 1 – Laindon Road/Frithwood Lane Green Wedge
This area of accessible Green Belt which reaches the High Street Conservation Area is one of Billericay’s and the borough’s most important areas of Green Belt. Very few areas of the borough scored as well in the 2017 Green Belt Review.
Figure 3. The Green Wedge, Area 12 of the of 2017 Review, based on logical boundaries
Figure 4. Parcel 12 scored very well in the 2017 Review, despite the methodology not accounting for the risk of coalescence with Little Burstead
Unfortunately, the new Study subdivides this area into several parts, bundling two of them up with very dissimilar areas east of Laindon Road.
The area at the head of the ‘green wedge’, adjacent to the High Street Conservation Area, is bundled up with the upper (northern) part of the Billericay School Field (the other part of the school field is in another parcel!) and east of the A176, with Bell Hill Close (an area of Green Belt developed in 2011).
From being part of an extremely high performing parcel, the head of the ‘green wedge’, now placed in an unnatural parcel (BI23) which includes an urban street, now scores the minimum possible.
The area at the head of the ‘green wedge’, adjacent to the High Street Conservation Area, is bundled up with the upper (northern) part of the Billericay School Field (the other part of the school field is in another parcel!) and east of the A176, with Bell Hill Close (an area of Green Belt developed in 2011).
From being part of an extremely high performing parcel, the head of the ‘green wedge’, now placed in an unnatural parcel (BI23) which includes an urban street, now scores the minimum possible.
Figure 5. Area BI23 from new Green Belt Study
Another part of the green wedge is now known as BI24 and again straddles two roads to take in very dissimilar areas: the lower part of Billericay School field and the Kennel Lane development site. It scores relatively weakly, especially compared with the 2017 Green Belt Study.
Figure 6. Area BI24 from new Green Belt Stud
Case Study 2 – Potash Road
An application for a development at Potash Road went to appeal in 2023.
The developer pointed out that the 2017 Green Belt Review gave the parcel a fairly low score.
The developer pointed out that the 2017 Green Belt Review gave the parcel a fairly low score.
After Appeal Hearings, the Inspector gave the view that the 2017 Study undervalued the area against purposes 1 and 3 as shown in the following extract from the appeal judgement.
Figure 8. Extract from Potash Road appeal judgement
For purpose 1 the new Green Belt Study scores the area lower than the previous Review and therefore conflicts with the Inspector’s findings – indeed the Inspectors findings are at odds with the consultant’s view that Billericay and Wickford Green Belt should not contribute to Purpose 1 at all as they are not considered to be large towns.
For Purpose 3, the new Study scores higher than the 2017 Review and is in rough accord with the Inspectors findings.
For Purpose 3, the new Study scores higher than the 2017 Review and is in rough accord with the Inspectors findings.
Figure 9. Area BI15 from new Green Belt Study
