M64 Green Infrastructure March 26


This Matter was originally programmed for two sessions on the mornings of Tuesday 26 March and Wednesday 27 March. Rather than divide the Matter into two the hearing session on Tuesday 26 March will now deal with Matter 64 and Policies G1, G4 and G5 in totality. If further time is required then the session will be extended and take place on Wednesday 27 March.

The Mayor has now published further suggested changes to Policies G1 and G4. [FSC/15]

Panel’s Opening Announcements

M64. Would the policies for green infrastructure assist in creating a healthy city in accordance with Policy GG3 and will they provide an effective strategic context for the preparation of local plans and neighbourhood plans? Are Policies G1, G4 and G5 and their detailed criteria justified and necessary and would they provide an effective basis for development management? How would they affect the implementation of Policies GG4 and GG5 on delivering the homes Londoners need and growing a good economy?

a)  Does Policy G1 provide an adequate framework for green infrastructure including the role of waterways (blue space) and the access to it?

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?

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?


Panel opens with Q on definitions. Answered by GLA (speaking too fast). Green infrastructure is an over-arching policy, policy G1 covering both publicly accessible + private ownership. Panel elaborates overlap with other parts of plan (biodiversity, sports etc)

Q: What about ‘blue’ spaces? Included in definition, but no specific policies for waterways. A: enumerates blue policies elsewhere in the Plan.

Q: :green open spaces’ is an undefined term.

Bromley LB No ref to private residential gardens in G1. There should be ref to the policies of boroughs, esp in outer London where there are fewer public open spaces.


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.