Category: Climate and Environment

Green Belt and Metropolitan Open Land
Panel questions: M65. Would Policies G2 and G3 provide an effective strategic context for the preparation of local plans and neighbourhood plans? Are the policies and detailed criteria justified and necessary and would they provide an effective basis for development management? In particular:
a)  Is Policy G2 on London’s Green Belt consistent with national policy and, if not, is this justified?
b)  Is the ‘swapping’ of Metropolitan Open Land (MOL) referred to in paragraph 8.3.2 and allowed for by Policy G3 AC justified? Do the other detailed criteria provide sufficient clarity about inappropriate development and how any boundary alterations should proceed? Should parts of the River Thames be designated as MOL?

[This is one of the few Matters on which Just Space has not been invited as a participant.]

Focus on Policies G2 and G3. We have already heard about spatial development strategy, relations with the rest of the south east and with housing targets. Please don’t say it all again, says Panel.

Panel asks Mayor: if G2 is consistent with national policy, do you need it? GLA: policy provides a clear spatial guide, so yes.  Panel: policy that developments should be refused IS inconsistent with NPPF which provides for ‘exceptional circumstances’. GLA: we don’t consider it is inconsistent. Panel: what do you mean by “appropriate multi-functional uses”? GLA: recreation and so on. Panel: isn’t this enhancement? GLA: our aim here is to ensure more people can use GB.

HBF: Mayor is over-reaching himself in dictating green belt policy, in conflict with NPPF. Powers lie with Boroughs and perhaps Neighbourhood Forums.

Crown Estate: if we are right sand housing tragets are not going to be met, the GB would permit it. Development round CR2 stations: (My clients own a lot of land round one of the stations, and development there as an “exceptional circumstances” could be much better than more intensification elsewhere.

Alan Mace (LSE London) There is a delivery question since most GB is private land.

London Green Belt Council: where does it say in NPPF that an LA must do a green belt review? Not there. Mayor had this in his manifesto. London Green Belt Council put in a paper on Monday – 202,000 dwellings threatened in Metro GB. LAs are releasing GB land in pref to the brown field land identified by CPRE. Cites divergent views on Enfield capacity.

Eversden (London Forum) we support protection because lack of infrastructure and because the housing that would be built is not the kind we need.

CPRE  Entirely OK for Mayor to defend the parts of the MetGB which lie within GL. It is NOT a local issue. It’s national as well as regional and London importance.

S E Authorities. Very pro-GB. Favour a Mayor’s review for consistency and looking for opportunities to change boundaries in some cases.

Enfield opposes the prohibition of any review of its green belt. LP has refused to grapple with a key strategic issue. One of our strategic options in our planning process includes green belt and that must remain possible. Mayor hasn’t even contemplated this choice. GLA policy is NOT just an emphasis on national policy!

Kingston: 1/3 of target for Kingston is undeliverable and green belt could be needed. We have infrastructure in our GB. We have Chessington theme park which will need to develop. Removing “exceptional circumstances” is dangerous.

GLA: Some boroughs seek to use GB on grounds that they can’t otherwise meet their targets. But if we had included green belt in the SHLAA these boroughs would have got bigger targets!

Gavron: Assembly strongly supports mayor’s protection of GB. Exceptional circumstances should perhaps be mentioned in the text but should not undermine the protection.  We attach special importance of fostering the intensification of London. We do know there is degraded GB, much of it run down by owners (including some councils) looking for hope value.  Keen on enhancement of GB (which contains so much of the the protected areas on England). Refers to an Assembly meeting which found so many ways in which GB could be strongly enhanced. (Reads out suggested new policy section.) Favours inclusion in Plan of Natural Capital Accounting.

Stevens: I do see it’s a strategic issue. But duty to cooperate applies and he might have to cooperate in a coordinated review of GB if his Plan A fails. Alternative strategies must be provided for in LP or at least not prevented. But  there has to be some flexibility.

London Chamber LCCI: Concerned about affordable housing (esp for emergency service workers – and thus hazards for emergencies). We have found some GB degraded land which could be developed to the benefit of emergency services.

LSE Mace: GB review should have been part of developing the plan. The approach is a kind of greenwash, and poses issue as all or nothing. The GB is huge and various. Some bits good for forest, some for access, some for food… and closing down the analysis and debate in the Plan is a mistake. GB benefits and impacts very unevenly distributed. Refers to IIA too.

Telegraph Hill Assn: plan needs to contain flexibility, since ever more density in inner/.central London may not be acceptable.

London GB Council: I have never heard of a single affordable home built on green belt. Developers won’t forego the expensive markets.  What about emergency services workers. What about Ebbsfleet?  PP was given in 2006 and only 1000 homes have been build there (and he looked as though he was going to say none of them were affordable, but he left it unsaid or implied).

CPRE Sinden: we support Assembly proposals for enhancements. Our research shows that GB development add massively to car traffic.

London First favours a GB review and also land swaps.

GLA comment on emergency services workers: other policies in the plan address this.

Panel: we asked Mayor to consider how a review might be done. We asked Q65. Too slow to do it as part of this plan. Must be part of a later review.  How do you know it should be sacrosanct without serious study? GLA: our emphasis is on role of a strong GB in focusing development pressure on brownfield with in the city.

What do people think about mechanics of a review?

Borough of Kingston: we’d favour a quick review (option 4) and expect an increase in housing targets in some boroughs, falls elsewhere. Should look at whole GB.

Redbridge: also support GB review. We have recently released 2 areas and it has enabled us to meet targets which we otherwise could not have done. GLA should lead review.

Enfield: the review might help but too late. We need the flexibility NOW.

SE Leaders: welcome a review.

CPRE: assumption behind the question: we question the fundamental starting point. First ned a debate on whether London’s Objectively Assessed Housing Need can be met within admin boundary. Mechanisms: must look at the WHOLE MGB (of which GLA Part is only 7%). Many such reviews have failed adequately to consult, and full engagement / transparency CRUCIAL. Must include scope for expansion of GB. Very hostile to land swaps.

London Forum: our members would be concerned if development halted while developers wait for hope value on MGB.

FoE: review not necessary.  Close to public transport not enough. Need to ensure that no more car-dependent development.

Lon Green Belt Council. A review would have to be requested by GLA but I see no sign of it. Deal with derelict land by forcing owners to deal with it.

LSE: need pro-active Mayoral approach to ensure we don’t get piecemeal development; how to ensure we get affordable homes; wrong to suggest a review would stall development within London.

LCCI: supports review. Option 2 probably best.

Crown Estate: we do regard GB as a strategic matter and GLA should set out criteria; CR2 crucial. Scope for more affordable housing because land cheaper.

Prologis (Rory Brooke)  GB could be released for industry and often good for that: road access and poor public transport, releasing more industrial land in London for housing use.

Lousada:   we believe that the review should be jointly instructed by boroughs and “the development industry” as well as the public.

Stephens: This whole review proposal has arisen because the boroughs find they can’t meet the targets of the draft Plan, derived through such “novel modelling”. Must therefore contain flexibility and the Mayor is in effect defying the Sec of State to find it unsound.  HBF wouldn’t be too concerned if the current draft was stalled. Old one not bad. But if you wan’t recommend declaring the plan, you must give boroughs flexibility of GB and set the review in train.

Gavron: If there is a review to be done, there will also be new demographic, economic and post-brexit changes.  What we need is for criteria to be set out in this plan. Criteria established in 1940s need a re-think including ownership etc.

GLA: GB flexibility on the current targets would not work. // Not surprised HBF willing to carry on with current plan – because its affordable housing requirements were weaker.

BREAK – now Metropolitan Open Land (MOL)

Panel questions b)  Is the ‘swapping’ of Metropolitan Open Land (MOL) referred to in paragraph 8.3.2 and allowed for by Policy G3 AC justified? Do the other detailed criteria provide sufficient clarity about inappropriate development and how any boundary alterations should proceed? Should parts of the River Thames be designated as MOL?

Panel: what does “where appropriate” mean? Please SAY what would constitute…. GLA: we aren’t seeking change. We just need to accept that there may be exceptional cases.

QPR supports general review of MOL (most be a story behind this – ed)

FoE: strongly support amendment which would help protect MOL.

Friends of green space: support amendments; but opposed to the review advocated by developers. It would lead to social unrest if any of those spaces were lost.

Eversden: many threats to MOL come from boroughs who want to put schools on it because they have not planned ahead. Need new policy stressing boroughs must plan ahead for schools and social infrastructure to avoid claims on MOL. // Use of MOL for commercial events is becoming a big problem. 1967 GL parks and OS Act should prevent this. Supposed to limit to 1/10 of a space. Being ignored or overwhelmed by a later law which enables boroughs to do anything in the interests of entertainment. GLA invited to set limits and to empower the 1967 Act.

Neil Sinden CPRE agrees. GiGL research stresses huge disparaities across London. Crucial in inner London, lowest in Islington; Camden 17.4% and some have more.   Policy should try to reduce the disparities between parts of London. Erosion needs turning round to become enhancement. MOL introduced 1969 GLDP. Took until 1989 to get full protection. Danger in the list of hardstandings, courts, etc which adds up to attrition of GREEN space.

London First disappointed by deletion of land swap. Swaps can be flexible and valuable and FoE wrong to view it as erosion.

London Assembly Planning Committee: Caution on criteria…  Very concerned by amount of recent losses.

Panel: what about the Acts Peter Eversden refers to? A: we’ll respond direct to PE.

Back to EiP Narrative page

Agenda:

CPRE (Neil Sinden) : Policy welcome and welcome the minor changes. Important to exclude green roofs and walls from definition which should be for ground-level.  Need also to ensure it is real green cover – not paving and astroturf.  Needs also to be a ref in G1 to “London Green Grid”.

Just Space (Del Brenner) new footnote on waterways should refer to the blue ribbon network as that includes the docks, lakes etc as well as just the canals and rivers. // Importance of heath.. but is it working? Is it a losing  battle with development? Who pays for the open space? (Inspector curtails wider reflections).

London Forum (Peter Eversden): unhappy that changes have removed ref to need for boroughs to plan for biodiversity and flooding. We suggest inserting “…to support biodiversity…”…  2. Removal of flood management is bad; must be reinstated or cross-referenced; 3. Area-based strategies (?) should say “and site allocations” to have more effective bite.  … 4. Private Open Spaces often very hard – e.g. More London – and welcome powers to influence them.

London Friends of Green Spaces (Dave Morris). Green spaces should be expanding and improving, not deteriorating and shrinking. Essential and we welcome their inclusion. But we don’t yet have strong enough policies to protect them. In particular LAs are tempted by developer offers to build on them. Add word “expanded” into policy. IN G1D green space expansion targets should be set in borough plans, and monitored. Need green space opportunity zones where expansion needed.

Telegraph Hill Society. No distinct policy in G1 on private gardens. Agree with Bromley but stress dependence of Inner London on private garden space, esp on pollution and heat island effect. Combined with the small sites policy this will be very damaging.

Savills on behalf of Gwyneth Howing Trust:   Danger that all this inhibits some sites from coming forward for development. Should instead focus on need to consider sites on a case-by-case basis. Not a blanket policy. EG a site in Barnet mentioned in our written development. Policy should instead focus on areas of greatest need.

Sport England: what about skate parks, synthetic pitches etc etc are included? Important that they are included, along with their renewal and improvement.

Natural England likes it. Welcomes inclusion of ‘expansion”

Assembly Green Group (Caroline Russell). welcomed refs to heat island and also the educational purposes. Policy G18.13 aiming at 50% of London to be green: need a better measured baseline as we may already have achieved the 50%. Must be stronger on climate change.

Assembly planning committee: Need to strengthen generally, add synthesising introduction and reinstate the passage on multi-functional role of green infra. Add ref to “green grid” in to policy wording; ditto refs to blue networks. Blue Ribbon Network was a good and effective policy in the previous Plan.

Just Space: Robin Brown welcomes the more integrated approach but blue elements need their own comprehensive policy, but footnote is not enough.

FoE Kate Gordon calls for gardens to be included, especially with the added threat of Small Sites.

HBF: No. You can’t protect gardens without totally invalidating the Plan which depends on garden developments to meet its small sites housing targets.

GLA: latest analysis is that 48-51% green. Aspiration should now be to beyond 50%.// GLA can’t give clear answer on hard sport facilities. Case by case. Rather inconclusive discussion of tennis courts etc etc… // Waterways? Private Gardens? We DO have a new note which mentions the Blue Ribbon Network.

National Park: Precise % measure useful but quality as important as quantity.

CPRE: essential to extend the protections for green space by expanding MOL.  alarmed by recent re-definition of some MOL as “previously developed” because it had some hard-standing.

FOE: on gardens: alarmed by the bit in housing policy which says that the character of some areas will have to change…  and fears it could be a loophole.

Bromley: 4% of tree canopy in in private gardens; 14% of green cover is private gardens; SUDS benefits of private gardens.  Disagree with HBF on clash with small sites targets.

Stephens HBF: Prohibition of back garden developments would make the LP unsound. Probably halve the small sites housing yield from 25 to 12 thousand dwellings per year.  Needs a joined up approach by public bodies and NGOs.

POLICY G4 b)  Does Policy G4 provide sufficient protection for the amount and quality of all green and open space including private gardens and on housing estates? Is the categorisation in Table 8.1 justified? Should the policy refer to the improvement of existing spaces?

Clarifying the table: GLA agrees intensity of use important and ?? (not clear). G4 AA 1b is about areas facing change: panel asks why only here? recognising opportunity for new open space is low outside OAs.  Panel asks why policy for needs assessment applies only to “protected” spaces? A: boroughs should identify space for growth.

Assembly planning committee: urge revert to previous title. // Losses of open space outside areas of deficiency must stress that the replacement MUST be in same immediate locality —mainly with groups in mind who have limited mobility.  Micro and local spaces need much stronger protection. // Must retain emphasis on ground level green – walls and roofs only substitute a limited range of benefits.

Green group: adds strong opposition to change to “green and local space”.//

Natural England:  what about the green spaces on estates?  Very important in London. Should include in protections.

Telegraph Hill Society strongly defending allotments & gardens; attacks roofs and walls as substitutes. Refers to Create Streets work finding private gardens good for supervision and safety of children.

Green spaces network: 50% of Londoners are in deficiency areas. More housing will increase need. Must strengthen policy wording, retain the table, defend quality as well as quantity. Need presumption against change of use from open space. Encourage boroughs to upgrade spaces and upgrade designation to MOL.  Need strong text to prevent dilution of the definition (as for example Haringey’s inclusion of road verges to escape their obligations).

Waterloo CDG (Michael Ball) policies very bad: where there is no open space there is a deficiency, but no protected land; where there is ‘enough’ there are no protections. Cites Shell centre getting away with extinguishing open space on the grounds of adjacent Jubilee Gardens (MOL).  Should remove word ‘protected’ from policy preculding developments where open space is lost. //  Adds that analysis relative to residents is inadequate in London: Jubilee Gardens has 50,000 workers; 250,000 people walking along river…, more users than any other UK open space. //  Danger of allowing quality improvement to compensate for quantity loss. // In Waterloo we have lost 1 ha of OS, none of which was protected. The plan does NOT help.

TCPA good on mental health benefits of greenery, whether accessible or not.

London Forum wants front gardens protected from concreting. Concerned about congestion on tow path. Seeks much more precise specification of the type of deficiency. Concerned also by Network Rail’s recent removal of vegetation beside its tracks.

Just Space Robin Brown. Green space only protected if it has been identified explicitly in needs assessment. But the table appears to exclude many types of green and open spaces which are not designated POS. Needs re-wording. NPPF requirement is for OS, recreation and sports facilities (all). Table 8.1 omits some blue spaces; housing estate green space also (cf CPRE).

CPRE (Neil Sinden) support added ref to access; otherwise the changes are bad, undermining it. Lift AB to the top. Delete “protected” and make the intention much clearer. Should be no mention of losses.  Perhaps something on no net loss. Table 8.1 needs to add green areas on housing estates which are valuable to general public as well as residents of the estates. Quotes Abercrombie’s 1943 plan on the connectedness of spaces.

FoE:  adds importance of non-protected open space. //  need to emplify and complete table 8.1

Bromley: reiterates value of private gardens

Stephens: Local deficiency A matter for local plans and neighbourhood plans – thus the change of title.//  private residential gardens can’t be treated as local green space, because not accessible.  Some bad faith from NDPBs which would like to protect private gardens but don’t want to say so clearly, and they should. //  Won’t always be able to replace lost open space if the local authority considers other factors should take priority.

Panel Q on housing estate GLA fudges: not excluded, but not directly mentioned. Boroughs could include estate greenspace….

Panel asks for a clean copy of the policy.

GLA: (mostly too fast to record) Only 60% of garden areas are green, much is paving, decking, parking…

Friends of green spaces: Table 8.1 title is PUBLIC and DEFICIENCY and BENCHMARK…  The key to this table is access.  GLA response that boroughs could add greenspace on housing estates is WRONG:  that space is not POS, it’s private to the residents on the estate. Crucial that the table is protected so it isn’t used to justify inadequate open space in new development.

Waterloo CDG: crucial to stress the reinstatement of quant and qual of estate green space in any development.

End of G4 debate.

Now G5.

c)  Is the expectation that Boroughs develop an Urban Greening Factor based on Policy G5 and Table 8.2 justified with particular regard to viability and practicality?

deferred to wednesday morning. except people who can’t come tomorrow

Telegraph Hill Society: UGF factors work well on brownfield sites but bad on greenfield sites (examples in their submission).  Does it cover extensions in “new development”?

Landlords Association: seeks flexibility and freedom to trade off against other policy objectives.

Landscape Institute: dangers of loss of accessibility insofar as walls and roof replace green ground.

Greens (Caroline) supports green factor, and it should be at 0.8, not 0.4, says Assembly Envir Cttee.

Adjourned until wednesday morning at 0930.

7 Nov. These are live notes taken during the second of 2 “technical seminars”  on the London Plan. Caution: there may be mistakes and later we’ll check among those of us, making corrections as necessary. There is a webcast athttps://www.london.gov.uk/media-centre/mayoral”> 

Context for zero carbon

On carbon reduction the presentation seems to focus strongly on new buildings & the reduction of emissions. Starts with Part L of the building regulations. The presentation is at https://www.london.gov.uk/sites/default/files/zero_carbon.pdf

Efficiency in the use of energy comes from windows, insulation, improved heating, cooling, lighting.  Draft London Plan sets targets of 10% and 15% improvement relative to Building regs (residential / non-residential).  Based on studies by Bureau Hapold of referable (to Mayor) schemes; another by AECOM.

Clean & Green parts of strategy SI2 and SI3 which prioritise cleaner energy sources. summary in the presentation and supporting documents.

Monitoring required because the designed performance of a building is usually not achieved in actual operation.

Payments to planning authority for offset is required now for residential and new plan extends it to non-residential. Money ring-fenced for carbon reduction in that borough – often work on the standing stock. These payments require to cover the gap between a development’s achieved reduction and a zero level.

Q from London First: can the 15% be achieved? Answer, broadly yes, though it varies between uses.

Q from M Edwards on standing stock of  buildings. A: this presentation focus on new building, just because the London Plan has powers only for development. There is some link via offset payments which can be used to retrofit old stock.

Q from Kate Gordon (FoE) Offsetting should be a last resort. Answer ??

Energy Masterplans & heat networks

An aim is reducing waste of heat, and making local use of it; managing local networks to make more use of decarbonised energy sources.

Some questions on the details of all this. Nothing crucial.

What about when energy from network is billed at higher price than conventional boiler? A: we have published survey data on this and there are instances of higher and of lower prices. We shall be monitoring it and very concerned if prices can’t be lower than conventional.

Overheating

There is a whole section on heat island effects, overheating etc.

Whole lifecycle emissions analysis DOES include mineral excavation, demolition, etc etc. Seeking nationally-recognised methodology.

Q: whole life assessment hard to produce at planning application stage. Can it be done at stage 4. A: discuss it at EiP

Q Waugh Thiselton: on a 17-year analysis embodied carbon is 90% of lifetime carbon & how on earth are we going to implement this?  A: ??

Jump in carbon emissions risk: air-source heat pumps are just AC machines. If we flood the city with them to generate low-carbon heat, isn’t there a risk that people switch them all on in summer to keep cool and we loose all the emission-reduction.

Sian Berry: have we ensured that the embodied carbon in buildings being demolished and in the choices with alternatives between refurbishment and demolition. Answer: garbled and hard to follow but seems to be saying that’s not a planning matter. Audience member interjects to say RICS standard energy assessment scheme DOES include energy embodied in demolished buildings – and offers a bonus for retention of previous elements.

[ Very skilled chairing by Rachael Rooney. ]