The Campaign to Protect Rural England is a national non-partisan organization dedicated to the protection of greenspace. http://www.cpre.org.uk/ Achievements like rural planning, National Parks and Green Belts didn’t happen overnight; they took decades of campaigning, careful organisation and reasoned argument. At many stages they seemed impossible dreams, but now it is hard to imagine an England without them. CPRE’s goal is to see the countryside protected, but within the context of a healthier economy and a happier community, which they don’t consider mutually exclusive. CPRE believes that people have the right to enjoy a protected countryside, and the organisation works to make it happen.
Enfield RoadWatch has been working closely with CPRE – London, which offers support in terms of policy, campaigning and contacts. http://www.cprelondon.org.uk/ This section of the website will provide links to CPRE reports, research and consultation responses.
February 2018 – State of Brownfield – This research examines new brownfield registers, published by 320 local planning authorities in England. They demonstrate that there is sufficient suitable brownfield land currently available for more than 1 million homes.
CPRE response to the draft London Plan
How the LONDON PLAN can be strengthened to achieve the Mayor’s ‘good growth’ aspirations
Working draft February 2018
- Protecting and extending green space – making more than 50% of London Green
We welcome Policy G2 and particularly the proposal in Policy G2B that ‘de-designation’ of Green Belt will not be supported. This policy needs to be reinforced for it to be effective.
Proposed change: A presumption against the alteration of Green Belt boundaries which reduce its extent should be included in policy G2B so that it reads: ‘The extension of the Green Belt will be supported and its de-designation will not. We will enforce a presumption against the loss of Green Belt’.
Rationale: The release of Green Belt land is being proposed in numerous locations across London. There is a need for an increase in capacity to enable the GLA to follow up this commitment and to object effectively to any proposals for Green Belt release. Unless strongly resisted the loss of Green Belt will seriously affect the ability of the Mayor to realise is ambitions for protecting existing green space.
Metropolitan Open Land (MOL)
We welcome recognition that MOL should be protected from inappropriate development but this policy is undermined by Policy G3 C and the provision to allow ‘land swaps’.
Proposed changes: Policy G3 C should be deleted along with the sentence in paragraph 8.3.2 “The principle of land swaps could be applied to MOL where the resulting MOL meets at least one of the criteria set out in part D of this policy”. Policy G3B should be amended to read: ‘The extension of MOL designations should be undertaken through the Local Plan process, in consultation with the Mayor and adjoining boroughs.’
Rationale: The protection of MOL should be supported unequivocally to help realise the Mayor’s ambition to increase green space. ‘Land swaps’ undermine this because:
- The unique location and qualities of MOL are irreplaceable.
- They undermine the ‘essential characteristic’ of permanence, as set out in paragraphs 79-92 of the National Planning Policy Framework (NPPF), which as stated in paragraph 8.3.2, applies to MOL as it does to Green Belt.
- The proposed policy states the MOL resulting from a swap should meet ‘at least one of the criteria set out in Part D’, which could easily be read as ‘only one of the criteria’. This means the resulting MOL is highly likely to be qualitatively considerably less valuable.
- The principle of land swaps creates a loophole that will be exploited by developers and others in ways that reduce the contribution of MOL to quality of life in London.
The open nature and environmental qualities of MOL are constantly being eroded by damaging proposals for inappropriate development. Strong policies are therefore required to halt such speculation and opportunism, rather than policies which are likely to mean that that it is acceptable to build on this land even if lesser quality MOL is created an unspecified distance away.
Private gardens (garden ‘grabbing’)
We broadly welcome Policy G4 concerning local green and open space. We are concerned however that this contains insufficient recognition of the contribution of private gardens to the extent of green space. A policy is needed to prevent extensive ‘garden grabbing’.
Policy G4 A should be revised to include reference to private gardens to read: ‘Local green and open spaces, including public and private gardens, should be protected’.
Rationale: We welcome the Mayor’s aim to encourage the intensification of land use in London, including by promoting the use of small sites for housing. Policies need to ensure that this does not result in the loss of green space, whether public or private. Any presumption in favour of building on small or underused sites should favour adding storeys rather than building out into private gardens.
- Green space quality
Green space deficiency
We welcome support for the creation of new areas of accessible green and open space. These provisions should be strengthened by requiring measures in Policy G4 to improve the quality of green space.
- Policy G4 C – should read “Assessments should identify areas of public green and open space deficiency, including an assessment of deficiency in quality, taking account of Green Flag criteria, noise and air pollution, and using the categorisation set out in Table 8.1 as a benchmark for all the different types required.”
- Policy G4 E 1) should include at the end ‘including an assessment of, and where appropriate a plan, to improve the quality of the space’.
Rationale: We support borough assessments of local green and open space to inform policy. To increase the benefits of green space, these should include an assessment of, and where appropriate a plan to improve the quality of the space i.e. an assessment of deficiency in quality rather than just amount of green space and its accessibility. For example, CPRE London’s recent research has found that nearly 30% of London’s parks and green spaces are severely impacted by noise from traffic (and presumably associated air pollution). Much green space is poor quality in other ways. The Plan should require boroughs to enhance and manage all greenspaces to a high, specified standard referencing the Green Flag criteria.
Noise and green space
The policy on noise should make explicit reference to the need to reduce the impacts of noise on green space, and other relevant policies amended accordingly.
Proposed change: Additions should be made to Policy D13 Noise as follows:
Para B: Boroughs [etc] should identify and nominate new Quiet Areas and protect existing Quiet Areas in line with the procedure in Defra’s Noise Action Plan for Agglomerations and ensure local green space is improved in line with Policy G4 (as amended) including by:
- taking action to reduce traffic noise around parks which are severely impacted by traffic noise and pollution, using such measures as temporary/weekend street closures and/or permanent re-routing of traffic; or introducing natural or man-made noise barriers.
Policy H6 concerning the night-time economy should be amended by adding the following sentence after sub-section B 1) – ‘adopt measures to protect the peace and quiet of public green and open space within or nearby areas of night-time activity.’
Rationale: The impact of noise pollution on human health are second only to air pollution according to the World Health Organisation. The ability to experience peace and quiet is an important aspect of the quality of urban life. Green spaces should provide respite from the noisy urban environment. Our recent research shows that nearly 30% of London’s parks are severely impacted by traffic noise (i.e. between 50% and 100% of the park is noisy). Policies should encourage action to tackle this growing problem.
Funding to improve green space
The provision and improvement of green space requires funding to help deliver the Mayor’s aspirations for ‘good growth’ and increasing London’s green cover and should be addressed in Policy DF1.
Proposed change: Policy DF1 D (2) should be amended to read as follows:
‘Recognise the importance of affordable workspace and culture and leisure facilities, including public green and open space, in delivering good growth.’
Rationale: Planning obligations and a proportion of Community Infrastructure Levy should go towards improving parks and green spaces. Where there is major development, in particular close to parks or green spaces, there ought to be a contribution by developers towards improving the quality, including enhancing the tranquillity, of green space, and to help fund future management, for example via an endowment.
The ‘Urban Greening Factor’ outlined in Policy G5 does not address the human use of green space and overlooks qualitative considerations and a wealth of knowledge about how people use green spaces and how design can enhance their experience.
Policy G5 – a further sub-section should be added as follows: (C) Urban greening required and delivered in new developments will be additional to requirements to provide adequate green and open space as set out in G4. New developments must allow for provision of new green and open space in addition to meeting urban greening requirements.
Rationale: Urban greening provisions are supported in general. It should be made clear, however, that this should be in addition to green space provision and the amenity those spaces provide. Those designing new developments should be required to consider the amount and quality of green space needed to fulfil human needs, as well as the amount of green cover required as part of the Urban Greening Factor. Unless this is made explicit in the London Plan, there is a real danger that the Urban Greening Factor will be used by developers to reduce the amount and quality of green space available for public use.
The approach to biodiversity and access to nature outlined in Policy G6 needs to be strengthened to avoid the loss of valuable habitats and wildlife.
Policy G6 – The second sentence in sub-section A of this policy should be deleted, along with the whole of sub-section C. The following sentence should be added at the start of sub-section D ‘All new development should seek to enhance biodiversity.’ .
Rationale: All Sites of Importance for Nature Conservation (SINCs) are precious and deserve to receive the highest level of protection. There should be no provision in policy which would allow development to harm a SINC regardless of their supposed relative significance. It is unlikely to be possible to compensate for the loss of biodiversity through alternative ‘off-site’ provision as the value of a site is often intimately connected with its location.
Trees and hedgerows
Mature trees are a vital part of London’s green infrastructure and there should be strict controls over felling them in Policy G7, along with recognition of the importance of established hedgerows.
The value of hedgerows should be recognised in subsection B 1) of Policy 7 by amending it to ‘protect ‘veteran’ trees, mature hedgerows and ancient woodland,,,’.
The first sentence of Policy G7(C) should be amended so it reads as follows: “Development proposals should ensure that existing trees of quality, mature trees and hedgerows, and trees of value in terms of delivering eco-system services such as water or air quality management, are retained.
Rationale: Inappropriate tree felling and hedgerow removal is something CPRE London is contacted about on a regular basis. This is a growing problem and policies need to be stronger and clearer to protect London’s existing trees and hedgerows, and the benefits they provide. Planting new trees is never an adequate response to the loss of existing mature trees or hedges whose contribution to environmental quality will invariably take decades to replace.
Outdoor sport and recreation in Opportunity Areas
Policy SD1 on Opportunity Areas should require sufficient space for the amenities usually provided by parks, in particular playing fields and courts for open air sport.
Policy SD1 B(3) should be amended to read ‘plan for and provide the necessary social and other infrastructure to sustain growth, working with infrastructure providers where necessary, and ensuring open and green space is planned to accommodate informal and formal outdoor sports.
Rationale: There is a danger that major new developments are created without sufficient open and green space to accommodate the amenities usually and necessarily provided by parks. In particular, there is a need for open, flat space required for open air sports, both formal and informal, including ball courts. Explicit provision should be made for such facilities in line with sports provision strategy anticipated demand.
Outdoor sport and recreation facilities
A decline in the quality of use of sports facilities is often used as an excuse for allowing development of public open spaces which needs to be addressed in policy S5.
S5 B(4) This should be amended to read: “ensure that there is no net loss of facilities. If there is evidence that ongoing or future demand for sports means facilities are under-used measures should be taken to ensure demand is promoted through a local sports strategy or to repurpose the space for an outdoor sport for which there is demand.”
Rationale: There is a cycle of decline in sports facilities, both green fields and hard courts, where underinvestment leads to under-use and this ultimately leads to the loss of those facilities. Currently the run-down ball courts on Shoreditch Park, for example, are due to be built on despite open air ball courts being at a massive premium in this central London area. Policies need to be framed to address this problem and recognise that demand for sports is uniquely tied up with available facilities and often the presence of clubs that promote them locally.
- Transport – need for more radical measures to restrict car use
Car parking provision
The plan seeks to further restrict car parking in new development and to reframe the link to PTAL. Allowing excessive car parking in Policy T4 is inconsistent with the main transport policies which seek to reduce car trips.
- The following amendments should be made to Policy T4(C) – ‘Where appropriate’ should be deleted and Policy T4(D) should be changed to read “..planning permission may will be contingent on the provision of necessary public transport and active travel infrastructure.”
- Table 10.3 – The bottom four rows should be amended so that the maximum parking provision in a development in any area (whatever the PTAL) is 0.3 spaces per unit.
- Paragraph 10.4.4 – the word ‘Ideally’ should be deleted and the sentence reworded as follows: “Ideally New development of all sizes, but in particular that which will give rise to significant numbers of new trips, should be located in places well-connected with public transport…”
- Policy T6 H: should be amended to read “Boroughs wishing to adopt borough-wide or other area-based car-free policies will be supported. [Delete the outer London caveat sentences.] Minimum standards are not appropriate for residential or non-residential land uses in any part of London.”
Rationale: Development in Low PTAL areas (the vast majority of London) should be accompanied by improvements which increase the PTAL rather than low PTAL being a reason for allowing high car-space provision. The maximum car space per unit levels in low PTAL areas in Table 10.3 (as high as 1.5 spaces per unit – albeit this is a maximum and lower levels would be expected with small units) are too high to be consistent with the main Policy T1 (delivering 80% of trips to be made by foot, cycle or public transport by 2041). The maximum should be reduced to 0.3 for all areas whatever their current PTAL, with measures required to increase the PTAL if a development is to go ahead.
City Region planning and transport goals
The Mayor’s goals for reducing car traffic risk being undermined by car-dependent development in neighbouring authorities requiring amendment to Policy SD2.
There should be an addition to Policy SD2 E so it reads: ‘The Mayor will work with WSE partners to find solutions to shared strategic concerns such as: reducing the need for car travel, barriers to housing….etc’
Rationale: There is evidence that car use is rising within London contrary to the Mayor’s transport objectives. CPRE London has mapped 450 proposed development sites in London’s Green Belt the majority of which will be car dependent. In total they will generate upwards of 5 million trips a week within or just outside the GLA border. This underlines the pressing need for a strong connection between the London Plan and planning authorities in the Wider South East in order to tackle car use.
- Density, design and local character
More efficient land use (including road space)
We welcome the overarching policy GG2 concerning making the best use of land. This should be strengthened by reference in policy H1 to making use of excessive or redundant road space.
Policy H1 B2d) should be amended to include reference to excessive or redundant road space and other car-related infrastructure so that it reads ‘the redevelopment of surplus utilities and public sector owned sites, including excessive or redundant road space.’
Rationale: There should be a more ambitious approach to realising the benefits in terms of land use of achieving the target of 80% of journeys in London to be by active or sustainable modes. This should release a large amount of space currently devoted to private motorised traffic. There needs to be more direct reference in the Plan to the over-allocation of land for ‘grey’ or car-related infrastructure, to support for measures to reclaim redundant road/car space, and to turn into reality the opportunity to turn ‘grey to green’ thereby helping to achieve the Mayor’s target for greening London.
Housing density and design
We broadly welcome policies D1 to D6 in the draft London Plan which seek to improve the design and land use efficiency of new housing. We believe policy D6 concerning the optimisation of housing density needs to be amended to avoid a lack of associated public infrastructure, and excessive housing densities and ‘town cramming’..
The phrase ‘in exceptional circumstances’ should be deleted from the last sentence in Policy D6B 3) so that it reads ‘This may mean that development is contingent on the provision of necessary infrastructure and public transport services…’.
The density levels specified in Policy D6C should be amended to 80, 170 and 260 units per hectare respectively so that it reads: ‘ 1) 80 units per hectare in areas of PTAL 0-1; or 2) 170 units per hectare in areas of PTAL 2 to3; or 3) 260 units per hectare in areas of PTAL 4 to 6’.
Rationale: In pursuing the welcome goal of making best use of land as set out in GG2, great care should be taken to avoid overdevelopment. This requires stronger policies to ensure that major new housing development is accompanied by adequate provision of supporting infrastructure including health facilities, schools, public green space, and public transport services. This will help prevent the overloading of existing social infrastructure which is already having a significant impact on quality of life in many parts of London. There should also be stricter requirements for design review and scrutiny in order to avoid new housing development at excessively high densities which result in overcrowded neighbourhoods and reduce their ‘liveability’. These measures are particularly important to avoid fuelling land value inflation through encouraging speculation and opportunism by developers.
The draft Plan gives insufficient consideration to the protection and enhancement of London’s diverse local character. Policies D1 and and HC1 need to be amended to ensure that greater attention is given to the character map of London, and community or neighbourhood plans, in planning and designing new development.
The first sentence of Policy D1 ‘London’s form and characteristics’ should be amended to make specific reference to neighbourhood and community plans so that it reads ‘Development Plans, area-based strategies, neighbourhood and community plans. and development proposals should address the following:’ The phrase ‘reflect and enhance local character and distinctiveness’ should be added to the list after 1) in Policy D1A.
The first sentence of Policy HC1 ‘Heritage conservation and growth’ should be revised so that it reads: ‘Boroughs should, in consultation with Historic England, other relevant statutory organisations and local community and neighbourhood planning groups, develop evidence that demonstrates a clear understanding of London’s historic environment, local character and distinctiveness.’
Rationale: The diverse and distinctive local character of London’s neighbourhoods are a major component of its attractiveness and vitality. Recent and future development to accommodate the need for new housing and economic activities risks damaging the distinctive character of London resulting in homogenous ‘anywhere’ places unless greater attention is paid to the underlying character of its diverse neighbourhoods. Neighbourhood plans and other community planning initiatives are a potentially important means of identifying local character and distinctiveness and should be actively promoted in the London Plan
CPRE London, February 2018
May 2017 – CPRE Annual Newsletter – This newsletter was presented at the CPRE AGM, where Green Belt campaigners from around London and beyond were able to meet and exchange ideas. One interesting fact we learned – the membership of environmental organisations far out-numbers that of all the political parties combined! Together we can make a difference!
March 2017 – The CPRE continues to scrutinise Government policy on housing and development and to lobby and educate elected officials and the public about the many reasons for continued protection of the country’s Green Belt. For the latest information, please visit:
September 2016 – The London Green Belt Council and CPRE London have published a joint report “‘Safe Under Us?’ An investigation into widespread threats from housebuilding in the London Metropolitan Green Belt”
The report shows that government policies and sanctions appear to be forcing councils to release Green Belt land for development. Enfield is included in this well-researched and well-argued report.
The link to The London Green Belt Council website – “Safe Under Us?”
This CPRE report, published 3/12/2015, shows how the Government is applying pressure to local authorities to approve planning applications to build schools on Green Belt and Metropolitan Open Land (MOL) – land which the Government itself says should not be built on. It shows the Government’s Education Funding Agency is involved with identifying and acquiring Green Belt and MOL sites which are not identified in the local plan. The report refers to our case on pages 14-15.