Section 1 – The London Plan Introduction
1.3 Population Growth
Population projections are notoriously unreliable. There are several components of the population projections that can be interpreted differently, and which can have a huge impact on housing need estimates and the types of homes needed. Some examples:
- Household formation rates – there are ‘concealed households’ (basically young people still living with parents or adults living in shared houses /HMOs) The Office for National Statistics [ONS] projections assume this trend will continue. However, if these people’s needs are accounted for properly, then the housing need overall and particularly the need for smaller properties for young people increases.
- International migration – this can fluctuate a lot and that impacts needs such the amount of purpose built student accommodation.
- Internal migration – there is concern that households are leaving London in part due to housing costs, and that, if this was addressed, the population would grow over the ONS projections. However, other people think that remote working is enabling flexibility regarding where to live, so people will leave London regardless.
- Birth rates – Are people not having babies because of London’s housing costs or are falling birth rates due to other changes, such as lifestyle, career choices, concern about the climate, etc.?
- Demographic changes – these are always ongoing, for instance, if the need for single person households increases, then more properties will be needed relative to the population.
- Downsizing options – are there enough smaller properties for empty-nesters to downsize to, both in the private and public sectors. Downsizing frees up family homes.
- Self-fulfilling prophecy – are you building homes for the people who are already here, who are going to come anyway or is the mere fact of additional homes drawing people to the capital?
In short, there are a lot of moving parts to consider.
1.4 Viability and Delivery
The GLA may be required to identify capacity for 880,000 but, as stated by Deputy Mayor, Jules Pipe, it is at this point an intellectual exercise, especially in light of no Government funding for the DLR and Bakerloo extensions. The target was unreachable before the Funding Review and now it’s even more so. This, combined with the uncertainty of the population projections and the conflict with other targets, such as mitigating climate change, should: a] Result in push-back against the target and b] stipulation in the London Plan that no Green Belt is released or converted to ‘grey belt’ until and unless economic and other conditions mean that the specific Green Belt site is needed there and then for development. We do not want developers sitting on swathes of newly-categorised grey belt, waiting for the market to suit them – or quickly building out new grey belt sites and ignoring brownfield and urban sites. Building should still be sequential with brownfield first and Green Belt only converted to grey belt after. There should also be recognition that building on Green Belt is not cheaper than building on brownfield because of the infrastructure investment needed, so any wording that implies that affordable housing can be delivered more quickly on Green Belt should be avoided.
1.5 This Document
The difficulties in delivering new homes are not related to the planning process, as evidenced by the number of permissions issued by each Local Authority annually. It is more a matter that housing has become a market, which permits developers to eke out delivery for maximum profit. This includes land-banking. Admittedly there have been labour and materials issues, but most of the developers concerns [and those of the Government, which has listened too much to the developers] are not real. A radical overhaul of affordable housing delivery is needed, which will free up the system.
1.9 Beyond London
It seems counter-intuitive for the Government to load so much housing delivery into the south when they are simultaneously pouring infrastructure money into the other regions and have a goal of equalising economic vitality. People will move where the houses are built so that becomes a self-fulfilling prophecy.
1.10 Good Growth
It is encouraging to see that Good Growth principles will remain in the new London Plan, even though some of those principles might fall into the Government’s ‘blockers’ column. We heartily endorse Good Growth. However, some elements of the proposed plan seem to go beyond Good Growth to Growth At All Costs, which risks decimating the city’s countryside, changing the character of long-established areas and alienating existing Londoners. If the ‘best use’ of land means only the highest density housing, that definition needs to be reconsidered and higher weighting given to natural capital.
Section 2 – Increasing London’s Housing Supply
Increasing supply is not the answer to the affordable housing crisis. It is more complicated than that involving a radical change in affordable housing delivery and a careful analysis of housing mix, but it is solvable without decimating the Green Belt. It is well-recognised that the Government’s target for London is unreachable. Therefore any plans put in place to achieve the target must be flexible and not draconian. The Green Belt survey under way may identify possible sites, but NO GREEN BELT SHOULD BE RELEASED OR DOWNGRADED TO GREY BELT UNTIL ALL BROWNFIELD SITES HAVE BEEN EXHAUSTED AND THAT PARTICULAR GREEN BELT SITE IS NEEDED AND READY FOR DEVELOPMENT. A thorough brownfield survey should go alongside the Green Belt survey. From our work in Enfield, we know that the Council’s brownfield register is never current and that many sites are ignored. If the Government does not provide the funds for infrastructure to unlock brownfield areas, then the Mayor should stand firm and refuse to release Green Belt until they do and all brownfield options have been exhausted.
2.1 A brownfield first approach
We are pleased that the brownfield first policy will continue to be emphasised. However, do not trust the boroughs to identify all their brownfield. We know from our work in Enfield that many potential large sites have been ignored. We would also like a clear definition of ‘optimised’. Does this mean maximised regardless of the character of the surrounding area? The current London Plan has mostly protected the unique character of the city’s different areas and that should remain a goal of the new London Plan.
2.6 Industrial Land
A London-wide approach would be welcome and there are definite opportunities in Enfield to intensify some industrial areas to allow release of others for housing, or to create mixed use developments. But, what is ‘London’s Grey Belt’? If this means that Green Belt that is adjacent to major roads is automatically grey belt suitable for industrial use, then we vehemently disagree.
2.7 Wider urban and suburban London
We definitely agree about low-density retail parks and car parks. Unfortunately the economic climate is making it hard to develop these sites if the landowner has to generate dividends for investors. For example. The Colosseum Retail Park site in Enfield [Black Rock] had permission for a large number of homes but economic conditions [labour, materials] prevented the development from starting and then the land was worth more for industrial – or, now, retail again. By contrast the Southbury/ A10 cinema site will move ahead because it’s owned by a Trust that can take the long view – but it will be mostly build-to-rent. These are prime sites for residential near amenities and public transport. How can their residential development be ensured?
2.8 Other sources of housing supply
Green Belt should not be released until it is needed because conditions may change. It should still be sequential with all brownfield being exhausted before any Green Belt [except for some previously-developed land – PDL] is downgraded to grey belt and developed. We would like a clear definition of ‘best use of land’. Does this just mean highest density. If so, more weight should be given to the natural capital benefits of the Green Belt. It is also debatable whether nature recovery and improved human access to nature can go hand in hand. True biodiversity is a state that develops naturally over many years and cannot be artificially created.
2.9 Beyond London’s existing urban area
The Green Belt survey should not be conducted by the local authorities, some of which are keen to capitalise on their Green Belt. A very narrow interpretation of grey belt should be used because the Government’s definition is open to abuse.
2.10 Large-scale urban extension in the Green Belt
Does access to public transport trump all other considerations ie heritage, biodiversity, rare habitats, public recreational facilities already accessible by public transport [and not numerous in London], agriculture, flood prevention, etc?
We thoroughly agree with the statement: ‘We must also be careful not to divert the investment needed for transport improvements to support brownfield development.’
We don’t believe Nature Recovery goes hand in hand with building on large areas of Green Belt, which would vastly increase human traffic. The word ‘accessible’ is thrown about a lot but does that mean by foot, by bike, by car, by wheelchair, etc? Surely not everywhere can be made accessible for everyone? Therefore, if an area of Green Belt, such as Vicarage Farm in the borough of Enfield, is already ‘accessible’ by foot and bike, isn’t that enough?
2.11 Metropolitan Open Land [MOL]
There is some confusion as to whether only parks that are MOL are protected or all parks. A response from Anesu Bwawa of Jules Pipe’s office refers to Metropolitan Open Land and other parks. Also it is stated that The Mayor remains committed to the protection of MOL and other protected open spaces. This would imply that parks that are Green Belt rather than MOL will also be protected, for example Trent Country Park, which has been proposed for high-density housing by TfL.
The campaign against golf courses is, in many cases, unjustified. They are not necessarily elite, inaccessible or ecologically irrelevant. And many other sports facilities are not open to the general public – cricket, bowls, tennis, etc. Take Crews Hill Golf Course, for instance. In their their Regulation 19 representation they state: CHGC provides an invaluable open air, countryside, sporting, mental health, health, walking and exercise facility to all of the local community. CHGC may have members who pay a fee to be part of a Club & its facilities but there are open opportunities for anyone to use the facilities as either a ‘green fee’ paying visitor or for free using the open and wide footpath that runs from one end of the course to the other. This footpath links with others and especially via King’s Plain – this is all part of the heritage of our Royal Chase lands offering broad, wide and long countryside views of these famous lands. Many come to just have a walk, a drink and maybe a meal and to meet others – this is a wonderful facility available to all.
To give an idea of the extent of the use by ‘locals’ we confirm that:
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- At April 2024 CHGC has 622 members who use the Club. Of these around 60% live in Enfield postcodes: EN1, EN2, EN3, EN4, EN6, EN8, EN9, N9, N11, N18, N21 & N22, so the split is fairly broad across the Enfield Borough. The balance 40% are in neighbouring Boroughs.
- During the year 1st January to 31st December 2023 a total of 25,200 (figure rounded) rounds of Golf were played at the Club, referenced by scorecards and green fee payment. Of this figure 8,500 rounds of Golf (again rounded) were booked and paid for by local ‘walk-in’ green fees from the public.
- So to add in member casual rounds i.e. no deposited scorecard, then the member figure is more likely to be at least 25% higher. So we are talking nearly 30,000 rounds of Golf per annum. This is a massive sporting, health, mental health and countryside facility which is used 7 days per week and more or less 52 weeks per year; and this is just on the golfing side, this equates to over 4,300 kilometres walked every week – truly amazing.
- In addition to this, we have maybe 40 to 50 people a day using the footpath through to course to walk, cycle, run etc.
We have many retired and elderly members and visitors who rely on CHGC as a multi-faceted venue for their exercise, social life and health and mental health wellbeing. Younger members are able to escape busy work lives to come and exercise their bodies and their minds, it is somewhere to bring all the family and friends. We have facilities for all including accessible facilities; we are open to all. Some may try to label a Golf Club as elitist but you can clearly see that we are not and we offer a major facility for the whole of the Borough and for those living close to Enfield.
The continuing husbandry of the SA11.2 land is provided by the Golf Club itself, giving the protection, enhancement, rewilding and restoration as is important within any SINC and as detailed by LUC. All this comes at a cost to CHGC where we spent in year 2022-23 £467,000, in year 2023-24 this is budgeted at £428,000
Crews Hill Golf Course is both accessible, non-elite and biodiverse with a SINC . Other golf courses, such as Enfield, could be made accessible with a footpath [Salmons Brook Trail] Accessibility cannot mean public transport to the door in all cases.
Section 4 – London’s capacity for growth and design quality
We are concerned that high-density growth will destroy the character of existing neighbourhoods
Section 5 – London’s infrastructure, climate change and resilience
5.5 Green and open spaces
We are concerned that proximity to public transport will trump consideration for biodiversity and climate change mitigation. Will identification in the Local Nature Recovery Strategy [LNRS] as an important habitat be more or less important than being close to a tube station?
5.6 London’s open spaces
The current London Plan glossary defines open space as ‘the broad range of types of open space within London, whether in public or private ownership, and whether public access is unrestricted, limited or restricted.’ How does this factor into deficiency? For instance, a former Enfield ward had no park but had access to private farmland via a public footpath. Was it deficient or not?
Including other green spaces is fine as long as it doesn’t become a tick-box exercise for developers to count Biodiversity Net Gain [BNG] and as long as the green spaces are taken care of, as suggested.
With regard to MOL vs Green Belt, it’s important to note that some parks are Green Belt not MOL. It was reassuring to see the response from Jules Pipe’s office [Anesu Bwawa] under the heading Metropolitan Open Land and other parks, and that The Mayor remains committed to the protection of MOL and other protected open spaces. We assume this is good news for Trent Country Park, on which TfL proposes to build several thousand homes.
See previous section on golf courses under Paragraph 2.11 MOL
We agree that policies are needed on rural London, which not only serves the many functions of the Green Belt but also has economic importance. Such policies should include the importance of horticulture, which generates jobs and income, in addition to continuing a longstanding heritage.
5.7 Green infrastructure and biodiversity
We suggest that a new requirement is developed from Biodiversity New Gain [BNG] that includes wildlife, not just habitat. BNG is too easily manipulated.