THE LONDON GREEN BELT COUNCIL

Notice of Postponed AGM and Supplementary Note

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1. The postponed AGM will now be held on Wednesday 17th December (venue notified to members). The same agenda applies except that Item IV, New Government Consultation Papers, should now read as follows.

2. In recent weeks, we have received an unprecedented flood of 14 consultation and other papers, mostly related to the revamped planning system which is expected to be brought into being by the Planning and Compulsory Purchase Act 2004, and mostly requiring comment by 16th January, 2004. The new system is intended to simplify things and be more positive in that, the proposed designation of land (whether for development or conservation) having been adopted, local authorities will be encouraged to bring that into effect, rather than just reacting to applications for development. But the proposals are extremely complicated and it may be doubted whether they will really help anyone.

3. It is best first to outline the main concept. 'Regional Spatial Strategies' will outline strategies for the scale and distribution of new housing, and priorities for environment, transport, agriculture, infrastructure, etc. for a moving fifteen-year period ahead.. They will not identify specific sites, and they must have regard to national policies.

4. Local authorities must produce their own plans (now called Local Development Frameworks) which must conform with the regional strategies. There seems to be no place for counties except as regards minerals and waste. Each Local Development Framework must consist of (a) a 'statement of core strategy', (b) site-specific allocations of land, (c) detailed area action plans, (d) proposals maps, and (e) a statement setting out the authority's 'vision and strategy for community involvement', identifying 'the community groups that need to be involved and the techniques required to involve them efficiently' [?e.g. thumbscrews]. It should 'build a consensus through continuous community involvement'.

5. There are adequate provisions for notification and public objection at various stages, but the aim seems to be that, rather than having authorities change their proposals (or not) as the result of objections, they should explain their reaction to each one for the benefit of an independent inspector's inquiry later. 'Changes', says the paper with breath-taking naivety 'are not likely to be required if the process of continuous community involvement has been effective.' The inspector will report to the Secretary of State and, unless the latter intervenes, the inspector's conclusions will be binding on the authority.

6. Against that background we must try to ensure that green belt protection will not suffer, and that the consultation arrangements will not make us or our member organisations less effective. My assessment of the individual papers is below, but members can get their own copies of most of them from the address given in the original agenda.

A. Consultation Paper on new Planning Policy Statement PPS11 - Regional Planning; and draft Town and Country Planning (Regional Planning) (England) Regulations 2004. See paragraph 3 above. There are two points: (1) the text says that the national policies which regional ones must follow are set out in an appendix - but the appendix is blank, stating that the list 'will be available in the final version'. We must ensure that it includes PPG2. (2) The Regional Planning Bodies which produce the regional strategies must also consult widely. The regulations set out the detail. We could be covered under the heading 'Voluntary bodies some or all of whose activities benefit any part of the region'. If members think we should try to get on regional bodies (the LGBC covers parts of three regions) we shall need volunteers to do it.

B. The proposed new local system. 5 documents: (1) draft PPS12 on Local Development Frameworks, (2) Draft Regulations and (3) Draft Transitional Arrangements Regulations plus (4) a consultation draft on the process of preparing the frameworks and (5) a draft guide on procedures and code of practice for the frameworks. All need comments by 16.1.04 Paragraphs 3, 4 and 5 above relate mainly to (1). Though we may doubt the workability of such complex schemes, green belt does not seem to be more at risk than anything else. Indeed, paragraph 2.2.15(i), discussing the content of the proposals maps, says that they should 'identify areas of protection such as.... green belt land...'. As regards consultation, members should try to find out what their own authorities are doing to bring about the continuous and all-successful process envisaged by the paper. 'Environmental groups at national, regional and local level' are among the categories of consultees envisaged. Document (4), however, gives concern for a different reason. It is written in abbreviation-itis gone mad, so that it creates an extra strain in trying to work out what it means as one goes along. For instance, one page contains the following abbreviations; LPA 12 times, CS once, LPD 3 times, RSS twice, LDF 9 times, LTP twice, and SCI twice. Another page contains AMR 3 times, LDS 4 times, LDD 10 times, LDF twice, LPA 3 times, and RSS once. But the content, in so far as it is intelligible, does not seem to concern us except to query the implications of a statement that spatial planning 'seeks to achieve the most efficient use of land between competing land uses in line with sustainable development principles'. How does one evaluate countryside in these equations? Admittedly, the same paragraph says that more guidance is set out in PPS1 - but the Deputy Prime Minister's Office tell me that that has been delayed and will not be out for at least another fortnight.

C. Draft General Development Procedure (Amendment)( England) Order, 2004 and Major Infrastructure Project Inquiries Procedure (England) Rules, 2004. No comment.

D. Draft amendments to PPG 3 (Housing), and draft new PPS7 (Sustainable Development in Rural Areas). See note on original AGM agenda.

E. Dept. of Transport consultation exercise on improving the Transport and Works Act process, and proposed changes to the Applications Rules and Inquiry Procedure Rules. Comments by 2.12.03. No comments.

F. Consultation Paper on new PPS22 (Renewable Energy). Comments by 30.1.04. A paragraph on green belts is strictly correct but says that the wider environmental benefits from increased production of energy from renewable resources in green belt might constitute the very special circumstances that clearly outweigh the harm to green belt policy. Taken with Item V(i)(b) in the agenda (Welham Green) this suggests that Ministers might be going to use this argument regularly to sanction development in green belt.

G. European Community Strategic Environmental Assessment Directive, Guidance to Planning Authorities. No comment.

R.W.G.Smith
28.11.03