Enfield RoadWatch Action Group

Hounslow’s Green Belt needs your help too! Please object by the Sept 24 deadline!

Please object to Hounslow’s Draft Local Plan release of Green Belt – Hounslow’s draft plan proposes to release 125 hectares of Green Belt for development. This is unnecessary and the Council needs to receive a mountain of objections.  The easiest way to object is by email to LDF@hounslow.gov.ukThe deadline is September 24.  CPRE-London has provided a very thorough objection template [below] which you can adapt or copy and paste.  Remember to add your name and address.

The consultation documents can be found here (including the Site Allocations). https://haveyoursay.hounslow.gov.uk/planning-policy/local-plan-regulation-19-consultation/

If Hounslow is able to make the case for de-designation of Green Belt, Enfield can be expected to try as well!

Here is the suggested email wording.

Subject:  Regulation 19 consultation response – Objection to the proposed release of Green Belt.

Green Belt is a strategic asset for all Londoners and should be protected in all boroughs.

The proposed Green Belt release of 125 hectares in Hounslow is unjustified, unnecessary and in breach of both London Plan and national planning policy and we therefore strongly oppose the proposed extensive damage to Green Belt which we estimate amounts to loss to development of 10% of Hounslow’s Green Belt.

  1. No Green Belt sites should be even considered for development until and unless all brownfield sites in the borough have been developed. One of the important purposes of Green Belt is to promote the regeneration of land within the existing urban footprint and there is a great deal of land within Hounslow in need of redevelopment. The council has rightly identified a large amount of Previously Developed Land (PDL) in the borough which currently presents very poor use of space, including a great many sites, including large sites, which can be developed to deliver additional commercial and residential space. These sites should be brought forward at appropriately high density alongside policies which ensure that people are able to use sustainable modes of transport, as per the Draft London Plan, so that space is not unnecessarily allocated to car parking,
  2. The council has failed to properly consider alternatives to allocating Green Belt for development as required by the NPPF and, specifically, it has failed to demonstrate why it does not consider (a) intensification of existing industrial estates nearby to Heathrow or (b) higher density housing, as more sustainable alternatives to releasing Green Belt.
  3. We do not accept the conclusions of the Green Belt Review that Green Belt land does not meet the purposes. The conclusions of the review are highly subjective and contradict even the council’s own previous review which concluded that all Green Belt sites in Hounslow met Green Belt purposes. The review has been explicitly conducted to identify land for development.
  4. No clear assessment has been weighing up the impact of the substantial proposed damage to Green Belt against potential gain so it is not possible to make a judgement about whether the loss of Green Belt demonstrates ‘sustainable development’ as required by the NPPF. The council’s assessment of the ‘value’ of the Green Belt land in particular is invalid. The borough has sought to present the large pieces of Green Belt land which it wishes to release for development as low value. However it has failed to make clear or take account of the important current value not only in terms of containing urban sprawl and stopping towns from merging, but also in terms of water and temperature management for London as a whole, as well as its potential future use in a more densely populated area as vital open green space and/or sports pitches. Additionally many of the sites are SSSIs (Sites of Special Scientific Interest).
  5. The council has not attempted to assess the potential positive gain that Green Belt sites proposed for release can bring to the borough. NPPF states “ …local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land” but there is no evidence that Hounslow has taken this approach.
  6. We do not accept the justification for change of designation from Green Belt to MOL for the sites proposed: they serve important Green Belt purposes including separation of towns and are clearly countryside in character. The Council has sought to present Green Belt as being only outside the outer boundaries of London’s built footprint but the Metropolitan Green Belt was never just an outer boundary and it is a clear breach of national policy to characterise it in this way.
  7. The argument that there are Exceptional Circumstances to justify Green Belt release, based as it is upon the need for housing and commercial space, it flawed. These cannot be argued to be exceptional when they apply to all London boroughs and when the Secretary of State has clarified that housing need cannot justify exceptional circumstances needed to release Green Belt. Second, the borough has based its argument for Exceptional Circumstances on the fact that it disagrees with the Draft New London Plan (DNLP) [Extract from ‘exceptional circumstances’ paper pp14/15 “Hounslow Council… considers that the proposed approach to Green Belt land should allow for flexibility in recognising that land which no longer meets the purposes of the Green Belt can contribute to good growth”] and that it believes they should be able to take into account ‘the increasingly likely scenario’ of a third runway at Heathrow. Neither of these are current planning policy and cannot therefore form the basis of an argument.
  8. Hounslow has accepted exceptionally high housing targets without appropriate justification except to state that the borough is ‘pro growth’. This fails to assess the reality of what can be achieved; that the borough would be adopting very challenging and ambitious targets even without the proposed Green Belt release; and despite the very real possibility that the very large number of brownfield sites which it has itself identified will sit idle while Green belt sites are brought forward simply because they are regarded as ‘easier’. The whole point of Green Belt is to stop the ‘easy’ push into countryside and force the redevelopment of the urban footprint so this would be entirely counter to Green Belt purposes.
  9. Where boroughs are constrained by Green Belt this can be cited as a reason for reducing housing targets however the borough has chosen not to consider Green Belt a constraint nor to make clear to consultees that this was an option, nor why it was ruled out.
  10. The Consultation is misleading. It states that the borough’s aim is to preserve Green Belt (p30) and that a ‘small number’ of green belt releases are justified but fails to make clear that 125 hectares are proposed for release and does not make clear which sites are proposed for release. This renders the consultation invalid. Page 31 states that the Borough’s strategic objective 10 is “To protect and enhance the borough’s Green Belt, Metropolitan Open Land, open green spaces and create more accessible MOL and open spaces” and yet it is proposing to release 125 hectares or 10% of its Green Belt. It states also that “The Council considers that exceptional circumstances are demonstrated justifying a small number of Green Belt releases..” (p60) but this cannot be regarded as ‘small’ by any comparison.

 

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