Matthew Kirby – Written Evidence (LUE0042)
1 Personal Introduction
1.1 I am submitting evidence to the House of Lords Select Committee of Land Use in England in an individual capacity. I am a PhD researcher at Northumbria University, funded by the Natural Environment Research Council (NERC) ONE Planet Doctoral Training Partnership [funding number NE/S007512/1] which also funded the research which forms the basis for my evidence submitted. I have an interdisciplinary background professionally and academically in both the built and natural environment sectors including, as a local authority planner and private sector natural capital consultant. My PhD is researching how green belt policy can promote multifunctional land-use by quantifying benefits and integrating environmental concepts to rethink green belt policy. Therefore, I believe my area of research will be of direct interest to the committee, given the legacy of green belt policy in England and effects it has on land around many of our towns and cities. Whereas my response to the call for evidence does not cover all the questions raised, it contributes directly to questions 2 & 10 of the call for evidence in relation to multifunctional land use strategies and how the existing English planning systems could better promote policy integration and multifunctional land-use.
2 Context and relevance to the committee
2.1 Land-use in England is controlled through multiple silos including; (1) local authority planning policy or spatial planning, which seeks to control development of land in accordance with local plans and national government policy set out in the National Planning Policy Framework (MHCLG, 2021), and (2) through environmental and agricultural policies which seek to balance needs of food production with enhancing and protecting the natural environment as set out in the government’s 25 Year Environment Plan (Defra, 2018). These two approaches are often viewed in isolation resulting in policy disintegration between built and natural environment agendas (Scott et al., 2013). Perhaps no land use policy in England is more well-known by the public than green belts. In England, green belt is a planning policy first introduced nationally in 1955 ( Ministry of Housing and Local Government, 1955) which seeks to prevent urban sprawl by restricting development. In England green belt policy now covers 12.5% of England and is a place where built and natural environment agendas meet and sometimes clash (Gallent, 2006).
2.2 However, the proximity of a large urban populations to large swaths of green belt makes them ideal opportunity spaces to integrate built and natural environment policy to help tackle challenges of climate change biodiversity loss and access to green space. The latter has been shown to be of great importance to physical and mental health during the pandemic (Labib et al., 2022). When viewed through a natural capital lens this significant amount of England’s landscapes around towns and cities have the potential to provide benefits from nature including carbon sequestration, flood management, and recreation. Indeed, multiple researchers and practitioners have called for the mainstreaming of nature in green belts to deliver multifunctional land-use (Amati & Taylor, 2010; Bishop et al., 2020; Campaign to Protect Rural England, 2016; Helm, 2015; Mace, 2018; Taylor, 2019; Thomas & Littlewood, 2010). However, there is a shortage of studies assessing green belts in England and internationally from the policy perspective of nature and multifunctionality. Internationally green belts such as the Ontario Greater Golden Horseshoe green belt have multiple policy goals including: growth management; agricultural land protection; and natural environment protection showing how green belt policy can integrate agendas through a joined up approach (Taylor, 2019).
In England key policy hooks do exist in the national planning policy framework itself for promoting nature, and a wider multifunctionality as shown in Box 1. Yet, it is uncertain as to how this policy is implemented and accounted for in local authority planning policy, and the strength of any such policies which may exist. Even with policy hooks to encourage their beneficial use many green belts act as blanket policies to prevent sprawl (Amati & Taylor, 2010). The evidence outlined is a result of research which explored how green belt policies in England implement this national policy to enhance green belts beneficial use. Thereby, showing what barriers and gaps exist in current green belt policy to promote beneficial use, and identify best practise local authorities which can be a model for others. By rethinking and broadening green belt policy as a space for multifunctionality, the opportunity lies in bringing social and environmental agendas together through dedicated and joined up green belt policy which seek to integrate built and natural environment agendas, through important cross-cutting policy bridges such as green infrastructure and the natural capital approach. Therefore, green belt policy can not only protect the land around towns and cities but also enhance it for nature and people.
3 Research approach
3.1 A content-based policy assessment was undertaken for a sample of 66 English local and combined planning authorities with green belts, including a mix of authority types and governance structure, as shown in Figure 1. Those in red have removed land allocated as green belt after the NPPF was published in 2012. Due to the large period of time needed to produce local plan documents in England, and time for them to be adopted following examination (Planning Inspectorate, 2021) many policy documents assessed were in draft, publication or adopted stages. This was to allow where possible policy documents to be assessed based on current national planning policy relating to green belts (MHCLG, 2021). In many instances if only adopted policy document were assessed, they would be based on outdated planning policy. Conversely, if only adopted plans had been included in the assessment this would have significantly reduced the scope of the assessment, therefore both plans under production and adopted were assessed.
3.2 The policy assessment was adapted from a approach by Hislop et al. (2019) and scored the policies based on a developed set of criteria. These criteria were developed from an extensive academic literature review and industry guidance. The assessment considers green belt from the perspective of nature, multifunctionality and the potential benefits they can provide to people, shown in Figure 2. Policies were scored on coverage and strength between 0-3 as shown in Figure 3. Policy coverage relates the degree to which the assessment criteria is covered in the policy, and is scored as 0= none, 1=some, 2=most and 3=full. Policy strength implies the required degree of compliance with a policy. Common words used include: 'may', 'should', “encouraged’, 'must', 'avoid' , ‘shall not be permitted’. Words such as “encourage” and “should” hold less strength, than words like “must” for example, which denotes a non-optional requirement. Strength of policy wording is ranked 0=none, 1=weak, 2=medium and 3=strong.
Figure 2: Policy assessment criteria produced from extensive review of the literature
4 Key findings
4.1 Green belts in England are largely underutilised in planning policy to promote beneficial land-use for people and nature creating a currently neglected opportunity space for joined up multifunctional land-use. As shown in Figures 5 & 6 there was broad range in coverage of the assessment criteria and strength of policy wording between the planning authorities. Overall coverage scores ranged from 9% to 60%, with a median coverage score of 33%, showing inconsistent policy approach for beneficial use of green belt in England. Importantly, the difference between coverage and strength scores where higher for ambitious planning authorities which scored high in coverage than those authorities closer to the median showing that ambitious policy wording to promote the positive use of green belts often was not matched with strong policy wording. Figure 4 shows the average coverage and strength score per sub-criteria (figure 2) (ranging from 0-3 as explained in paragraph 3.2) for all English planning authority assessed. As shown in Figure 4, the degree of coverage and strength scores differed both within, across and between the assessment criteria groupings.
Figure 4: Average coverage (mean) and strength scores per sub-criteria for all 66 planning authorities green belt policy assessed. Score range from 0-3.
4.2 On average several of the sub-criteria were covered less, highlighting gaps in green belt policy relating to these issues. These key policy gaps found include:
Figure 6: Geographical overview of green belt policy assessment coverage score
4.3 In addition, several elements of the criteria had consistently more coverage in the green belt policies, specifically:
4.4 One key policy bridge to promote the beneficial use of green belts was “green infrastructure” which was used my multiple local authorities to promote the multifunctional potential of green belts, including as part of the wider strategic green infrastructure network.
Example high scoring policies assessed are shown in Box 2. Policy G2 of the London Plan was one of the highest scored plans with 60% coverage. Policy G2 for example includes explicit reference to supporting the multifunctional benefits of London’s green belt, and additionally the supporting text recognises several wider benefits beyond growth management, including the mention of regulating services which were rarely associated with green belt in other policies assessed in England. However, the policy scored 44% on strength illustrating now ambitious coverage is often not supported by equal strength wording. Here words like “should” is medium strength, it encourages compliance but doesn’t hold the same strength as “most” which requires compliance. Enfield’s strategic policy SP BG1 is a good example of the cross-sector use of green belts to address issues which are not a core function of them. Firstly, green belt is cited as part of a green infrastructure policy, therefore being treated as a strategic natural asset. Secondly, the policy recognises the issues of greenspace deficiencies and directly seeks to promote the enhancement of green belt as a way to contribute to reducing this deficiency.
5 Discussion & recommendations
5.1 The results of this work shows important considerations for land-use around our towns and cities especially with respect to joined up policy agendas and promoting a more multifunctional vision for these landscapes to benefit people and nature. Whereas green belt covers a significant amount of land in England (12.5%) policies to improve its beneficial and multifunctional use are lacking. Central to this is the disconnect between planning policy which is responsible for green belt and the range of emerging policies which seek to improve the benefits we get from nature as outlined in the 25 Year Environment Plan including many which are now in law through the Environment Bill. Those planning authorities that scored high in the assessment explicitly recognised green belt as an underutilised opportunity space for environmental improvement. One such example was Greater Manchester Combined Authority which commissioned a study on how green belt may be enhance and linked to other environmental policy agendas to support compensatory improvement (Land Use Consultants, 2020). Opportunities may lie in the development of supplementary planning guidance for the enhancement of green belts through a place-based approach, especially given many of the planning authorities assessed are planning on removing green belt designation from selected land parcels.
There is a strong need for a joined up approach across green belt at a landscape scale. In order to promote the opportunities green belt could provide for nature and people through multifunctional land-use, better integration is needed between DEFRA policies and DLUCH planning policy. Currently only one scheme is mentioned in the NPPF to promote the beneficial use of green belt: The National Forest and Community Forests (paragraph 14). However, there is strong opportunity to incorporate many emerging environmental policies as bridges to both the wider multifunctional use of the green belt, but also compensatory enhancement as currently required in the NPPF (Box 1). Policies and potential links are shown in Box 3. The joining up of policies are the national level therefore has the potential to catalyse a joined-up approach to green belt land-use at the local level. Additionally, by joining up policy agendas in green belt, financial resources can be pooled to create more ambitious and multifunctional interventions. For example, delivering biodiversity net gain, alongside compensatory improvement could create access to experience natural areas created.
5.3 Green belt policy needs strategic planning at are landscape scale with local implemented. Part of the barrier to this is that many green belts are administer at the local authority level, but were created as strategic resources to be planned at regional administrative areas. This is important given that ecosystems do not conform to administrative boundaries, often operating at greater scales (Montgomery, 2011). Some have argued that regional planning can offer the greatest potential for joining agendas such as green infrastructure with green belt to create strategic networks for people and nature (Thomas & Littlewood, 2010).
5.4 It is important to note that green belt is just one of many landscape scale policies, several other landscape and nature conservation designations exist which aim to protect and enhance the natural environment without being planning policies, such as Areas of Outstanding Natural Beauty (Powell et al., 2002). It could be argued that by putting nature in a more prominent place in green belt it has the potential to dilute the primary function of green belt in preventing sprawl. However, such designations are often stacked with green belt, working separately in their respective silos, and furthering disintegration (Scott et al., 2021). Instead, by rethinking and broadening green belt in England as a space for multifunctionality, the opportunity lies in bringing social and environmental agendas together through dedicated and joined up planning policies, thereby creating a potentially important role in breaking these silos.
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