M65 Green Belt & MOL March 26th

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.


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