There has been frustration that successive Mayors of London have not entertained the scope to review and amend Green Belt boundaries around London – the latest example being policy G2B of the emerging London Plan stating that “The extension of the Green Belt will be supported, where appropriate. Its de-designation will not be supported”. This is notwithstanding that their Plans have consistently failed to deliver the homes that we need, that planning authorities bounding London have recognised that this is an unpopular, but necessary, policy approach to assist in delivering the homes we need, and that a number of outer London Boroughs are seeking the freedom to review the boundaries in their local areas in line with national guidance.
Furthermore, the Secretary of State for Housing, Communities and Local Government is clearly losing his patience. In his letter to Sadiq Khan he notes that ‘London faces the most severe housing pressures in the country’ and ‘the Government is clear that we need a London Plan in place that plans to meet London’s housing needs in full’. As such, he has concluded - ‘I have listened carefully to yours, and others, representations, and I am clear that the public interest lies with ensuring you deliver the homes London needs, including in the short term, as quickly as possible’.
The Ghost of Christmas Past - As we all know, the current policy approach on Green Belt boundaries in the emerging London Plan is not in line with national policy guidance, clearly set out in the NPPF. So, is now the time to undertake a full review of the land around London and to look to loosen the Green Belt that has been buckled so tightly for 60 years?
The Ghost of Christmas Present - The London Plan Examination in Public Panel (EiP Panel) has asked the preliminary question: ‘Given the legal requirement for the Mayor to have regard to the need to ensure that the London Plan is consistent with national policies, what is the justification for each of the policies deviating from national policy guidance?’ (PQ6, Panel Note No.2).
On Green Belt policy, the GLA has given a preliminary answer: ‘The strong emphasis on the protection of Green Belt land is justified as the spatial strategy prioritises brownfield land for London to meet its growth in a sustainable way […]’ (Paragraph 22, Mayor’s responses to the Panel’s Preliminary Questions)
From sitting in EiPs across the land, this ‘justification’ is just not good enough, without clear testing and analysis of the exceptional circumstances that might apply – the key ones being the requirement to meet the housing need in full and to review the functions of the land in detail. What is most striking in this case is that, from our review of representations submitted on the draft Plan, the majority of the outer London Boroughs see a clear need to review the Green Belt boundaries and that they are requesting to be allowed to appraise the boundaries in their local areas. Some inner Boroughs have also objected to the Policy.
After a hearty Christmas break, full of food and wine, I am looking forward to coming back to listen to the EiP debate on matter M11 (and M65): ‘Is the strategic approach to accommodating development needs within London justified and consistent with national policy? in particular […] should some of London’s development needs be met through reviewing Green Belt and Metropolitan Open Land in London?’.
Is now the time for the Panel to recommend to the Mayor that he should support a review the Green Belt and to allow for Boroughs to loosen ‘The Belt’ if they see fit, by amending the wording of the emerging London Plan Green Belt policy to reflect NPPF policy? The housing need in London is ‘exceptional’ and local Boroughs would like the opportunity to review their Green Belt boundaries to check whether these are still fit for purpose, and to release land that does not meet the Green Belt functions.
The Ghost of Christmas Future – and if the EiP Panel decides the time is not nigh, there is always the potential future alternative set out by the Secretary of State in his letter – ‘I would remind you that I have powers to intervene before the Plan is published, by giving a direction to avoid any inconsistencies with current national policy or to avoid detriment to the interests of an area outside of Greater London and I will be carefully considering whether it is appropriate to exercise any of my statutory powers.’. Green Belt is not specifically mentioned, but maybe …
If there is no such intervention, there is always another Christmas… with the start of the next ‘London Plan Review’. We have heard that one before.
Recommended viewing for 2019: ‘The London Plan EiP Hearing Sessions’ January-May.
Coming soon: The London Plan Review…
