The NPPF states that the Government attaches great importance to the Green Belt and its fundamental aim is to prevent urban sprawl by keeping land permanently open. Whilst the Green Belt is not an environmental designation, it is a strategic planning tool which was introduced to manage the growth of urban areas. It is therefore wholly appropriate to revisit Green Belt boundaries when development requirements justify this.
Richborough do not consider it necessary for an authority such as Medway, with only 5% of its land as Green Belt, to propose the removal of Breen Belt parcels for residential development as exceptional circumstances are unlikely to be demonstrated. While Medway is also constrained by ecological designations, the Green Belt in Medway plays an important role in maintaining the strategic gap between local settlements, including Strood and Higham, Cuxton and Meopham and Snodland and Rochester.
The possible cross authority development sites and emerging allocations on the boundary of Medway are coming forward in the context of Gravesham, Maidstone and Tonbridge and Malling being heavily constrained by Green Belt. The Green Belt sites in Medway, as referenced in the Consultation Document, also include significant swathes of the Kent Downs AONB. These designations are afforded national policy protection, and the loss of these sites are to be avoided wherever possible. Paragraph 176 of the NPPF states “Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty which have the highest status of protection in relation to these issues…”
There is sufficient land outside the Green Belt in Medway, brownfield and greenfield land, to meet housing needs. Richborough do not consider the possibility of providing a cross authority development an exceptional circumstance to justify Green Belt loss when suitable sites, such as Site SR17, are available. Paragraph 141 of the NPPF confirms before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development.