The current local plan examination is being conducted under the 2023 version of the National Planning Policy Framework [NPPF] which is probably advantageous for us. However, as you are no doubt aware, the new Labour government is proposing significant changes to the planning laws and, if we are successful this time, given the goals of our council, the Green Belt will come under immediate attack again should the proposed planning changes take effect. You can have an impact on this. A consultation is currently taking place and the deadline is very near – September 24, 2004. You will find instructions and comments you can make below.
The consultation can be found at;
https://www.gov.uk/government/consultations/proposed-reforms-to-the-national-planning-policy-framework-and-other-changes-to-the-planning-system
The particular chapter is 5 – Brownfield, grey belt and the Green Belt
It is important that there are as many submissions as possible to ensure that the Government is aware of the strength of feeling and concerns. Although the paper on the website above has questions, you do not necessarily have to follow them – a statement setting out your views is likely to get greater attention and can be emailed to : PlanningPolicyConsultation@communities.gov.uk
In your email, please use the subject heading: ‘Response to Chapter 5 – Brownfield, grey belt and the Green Belt’.
Plese confirm whether you are replying as an individual or submitting an official response on behalf of an organisation and include:
- your name
- your position (if applicable)
- the name of organisation (if applicable)
Then copy your statement into the email.
Please copy your MP into your submission:
- If you are in Enfield – North your MP is feryal.clark.mp@parliament.uk
- If you are in Enfield – Edmonton and Winchmore Hill your MP is kate.osamor.mp@parliament.
- And if you are in Enfield – Wood Green and Southgate your MP is bambos.charalambous.mp@parliament.uk
Below you will find a list of comments [courtesy of London Green Belt Council] that you can use to respond to Question 5 – Brownfield, grey belt and the Green Belt. The government policies are in red and your possible responses are in black. This will give you an opportunity to use your own phrasing.
NPPF Consultation – September 2024
Question 5 – Brownfield, grey belt and the Green BeltBrownfield
• Welcome the priority of “brownfield first” – Does this mean that there will be little or no greenfield allowed until brownfield is nearly exhausted?
• There is the assumption that brownfield development will not be enough to solve the housing crisis but what is this based on?
– most brownfield registers are not up to date
– most show little or no work being done on research and analysis of brownfield
– CPRE believes that there is, on the present less than accurate registers, enough land for over 1.2 million homes (CPRE State of Brownfield Repot 12/2022).
• The argument is being made that brownfield development is more expensive that greenfield development but this needs to be balanced against the cost of infrastructure on greenfield sites to make them sustainable
• To encourage brownfield development, the government needs to consider subsidising the clearance and decontamination issues
• There needs to be consideration about brownfield sites in the GB which are not sustainably located.
• Much of the land in the London Green Belt on the edge of urban development is either owned by or optioned to large developersGrey belt
• The definition of grey belt is still unclear – what exactly is – it is not clearly defined.
– is it PDL [previously developed land] such as petrol stations and car parks which Ministers quote as the only examples
– is it “poor performing” Green Belt? [What constitutes ‘poor performing’ and who makes that judgement?]
– consultants are already assuming ‘poor performing’ sites including AONB [Areas of Outstanding Natural Beauty]
– this could be thousands of hectares of GReen Belt chosen geographically haphazardly resulting in the decimation of Green Belts
• It is stated that any new development must not undermine the function of the Green Belt as a whole. Again, what does this mean? There is no mention of cumulative development just single applications
• When these ideas are tested at planning inquiries and court cases these restricted definitions could be greatly increased to include neglected and unused agricultural land which could become very important when food security is affected.
• Much of the area of Green Belt land adjoining urban land is being deliberately allowed to deteriorate in order that it will be reclassified as “grey belt” . This is possibly due to developers either buying or taking options on this land in order to increase their considerable profit when the land is designated for development.
• Support for more affordable housing is important and welcomed but is the “golden rules” concept (50% of housing to be affordable on Green Belt sites, realistic. Developers are already saying it is “baffling and will wreck the government’s building plans”. Doubtless the large developers will pressurise central government or submit a flood of variation requests. It is also unclear how 50% will be achieved when having to pay the full cost of land.
Any such percentage of affordable in a housing application should be mandatory and not negotiable by a variation agreement either at the planning stage or later in the process
• As far a commercial and non-residential development, such applications do need to be subject to the equivalent of the “golden rules” but government needs to outline how the rules the ways in which they would work.
• There appears to be a deliberate muddying of the water of what is meant by grey belt and brownfield which needs exposing. This ambiguity will cause conflict and confusion in the short term further slowing down the local plan process.
• Government should make clear that any Green Belt released to “grey belt” should result in greater protection for the remaining Green Belt, since the intention is to maintain existing designations. At present such commitment is lacking and gives further concern for Green Belt loss in the future.
• If there is no guidance from government on assessing which areas of land make a limited contribution to the GB then there will be a likelihood of little consistency between districts and further controversy leading to further delay. This could mean that LPAs that have much brownfield and densification potential compared with neighbours could end up with less development.Green Belt
• In chapter 2 of the suggested revised NPPF, it mentions the three overarching objectives (para 8). Economic, social and environmental objective – the three legs to a stool, all of which should be the same in order to have stability. Much is made of the economic objective which appears to have more importance than either of the other two objectives when put together. The least considered objective appears to be the environment. Nothing appears to guarantee the future of the important environmental roles of the Green Belt. Nothing appears to give any guarantee to important Green Belt either now or in the future. Without a clear vision for London’s Green Belt it will continue to be concreted over at an even more alarming rate.
• Rather than a piecemeal loss of London’s Green Belt over its districts and London Boroughs with little or no consistency, there needs to be a full review and analysis of the whole area ensuring that if land were to be sacrificed, it is properly classified. What has happened in recent years because of lack of a clearly defined policy which from this consultation, is likely to continue. This could lead to a large loss of Green Belt land and a loss of its important economic contribution.
• There is nothing proposed in this consultation that appears to protect high quality Green Belt if it appears to support growth. In other words, growth at any price!
• There is little or no mention of the important role played by Green Belt other than for development. There is a view that government only seems to believe that Green Belt has an economic vale once it is developed.
• The importance of “good performing” is not mentioned and not defined.
• There is no mention on the importance of Green Belt for:
– health and welfare including “green prescriptions” which can result in reducing the cost of the NHS and therefore has an economic value
– climate emergency – carbon sequestration which has an economic value
– flood prevention which has an economic value
– facilities for access and recreation which has an economic value
– local fresh food and food security which has an economic value
– tourism which also has an economic value
– pollution relief
– relief from heat
– landscape
– biodiversity and nature regeneration
Please take the time to submit a response to the consultation by September 24. Thank you.