The London Green Belt Council Notes: Issue 130 June 2002
RTPI and TCPA responses to Government Planning Papers
Members should be aware of the criticisms of green belt policy which have been made by the Royal Town Planning Institute (RTPI) and the Town and Country Planning Association (TCPA) in response to the Government's recent planning consultation papers. These Notes contain extracts from their own submissions to the DTLR, followed by LGBC comments. Clearly the combined impact of the two organisations' views will carry some weight with the Minister and is too important for us to ignore. We are sending Lord Rooker - successor to Lord Falconer as Minister for State (housing and planning) a letter based on these comments even though the consultation period has expired and we submitted our comments in March. However, see below for Lord Falconer's recent comments on TV.
RTPI renewed its long-standing campaign to weaken or destroy green belts. It never actually says that that is its objective - indeed it reiterates that it 'supports the purpose of green belts", but no-one reading its comments and proposals should be fooled by that; green belt policy would be effectively destroyed by its proposals:
3. "Green belts should be protected from inappropriate development only to the same extent as rural areas generally."
LGBC Comment: This would remove any distinction between green belts and other rural areas.
LGBC Comment: It seems likely that regional planning agencies and, more particularly, regional
development agencies will be more dominated than central government by commercial interests. Regional assemblies, when created, may well be the same. This is no doubt behind the RTPI's aspirations. Green Belts must remain a national policy with national standards, not subject to regional manipulation, though regional input is reasonable.
5. "Boundaries should be, settled within a local context ..... so that they make sense on the ground as well as on the map".
LGBC Comment: The latter part is existing policy so far as initial delineation of green belts is concerned. The first part depends on what is meant by "settled within a local context".
6. "Green belt designations need to he combined with positive action for the environmental management of the included land, together with explicit strategies for farming and forestry."
LGBC Comment: This is part of the RTPI desire to link green belt designation with the quality of the landscape, a reversal of long-established policy which would open the floodgates to manipulation.
7. "There needs to he sufficient development value in green belts to fund environmental enhancements."
LGBC Comment: Another aspect of the same ambition and opening another floodgate.
8. Green belt policy should "adopt a lighter touch, allowing different approaches in different areas."
LGBC Comment: This would allow planners to plan, and developers to build on, such areas of green belt as had survived the other RTPI-designed loopholes.
Apart from wanting to loosen controls to the verge of elimination, the RTPI persistently envisages green belts from the point of view of town planning. This may be fair enough in view of its title but it is a blinkered view. Our members in towns and villages in the green belt view it very much as a policy protecting them from being swallowed by spreading towns. So, despite the RTPI's assertion that green belts "are an element of urban policy and not [their italics] created for countryside protection", the reality is that they are needed for both purposes. That is one reason why the Government, in splitting up the former DETR, was silly to place environment and rural affairs in a different department from planning. But, given that ill-advised split, the Department that includes planning is the right place for green belt policy. Meanwhile it is encouraging to know that the planning Minister, Lord Falconer, answered as follows to questions by Jon Snow in a Channel 4 news interview on 5th May:
"I think it [i.e. a change in green belt policy] is to be resisted. The solution is not to build on green belt. The solution is not to change planning policies in terms of substance as these have evolved. It is to have policies to build on brownfield or developed land feast and greenfield only second. The best course is to speed up the planning system so as to deliver sites more quickly without infringing green belt'
Asked to confirm beyond all doubt that green belt policies are not to be altered one iota, he answered: "We are not going to alter green belt policy; that is not our plan at all".
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TCPA comments are more moderate and balanced than the RTPI's but nevertheless there are aspects which could lead to quite unjustified weakening of green belt Policy. The main points are:
1. Policy should treat green belt as "an essential complement to a strategic package of policies. They should be aimed at the containment of large urban areas to encourage their regeneration in a way that would create good living and working environments. It should support in appropriate locations new towns and town extensions and conserving countryside in the urban flange for recreation and agricultural purposes"
LGBC Comment: This may he fair enough where new green belts are concerned but it offers huge opportunities for carving into or nibbling away at existing ones. And though the TCPA wants a review of green belt policy (see below), it is not entirely clear how far that relates to existing green belts.
2. Containment policies are still required but with a flexible approach which "should not, however, be applied on an ad hoe basis. Regional and structure planning policies should make provision for this flexibility on a basis of a better appreciation of what is the appropriate urban form in any particular case. They should have regard to the environmental or ecological quality of the surrounding countryside, the scope, for the development of brownfield land within the urban area itself, the capacity of the existing transport structure and any local affordable housing or economic development needs"
LGBC Comment: The snag about 'having regard to... the existing transport infrastructure', is that it could lead to a reversion to the infamous ribbon development of the late 1930s, with narrow strips of housing stretching along main routes because the transport was there or could he encouraged to come there. Combined with the notion of green wedges rather than green belts (see below) this could he a seriously retrograde step.
3. Changes to present boundaries should be based on local consultation including "an appraisal of alternative options (including new settlements) and on firm land-use proposals for the affected land - for example development along transport corridors. This especially applies to any planned extensions of an urban area into an existing green belt'.
LGBC Comment: The emphasis on development options assumes that there must be development. Green belt policy is one of no development, or extremely limited development. This is anathema to the planning institutions as it limits their opportunities in many ways. It is the green belt policy that people really want.
4. "The positive land-use role for green belts envisaged in PPG2 should be reinforced. In return for green belt status, local planning policies should make specific provision for countryside access; sport and outdoor recreation; landscape protection and enhancement; the reparation of damaged and derelict land; nature conservation, and farming, forestry and related uses. Policies to promote sustainable land management with mixed organic farming and community woodlands should allow, where appropriate, small-scale, low-impact, live-work units for those engaging in local food production, woodland crafts and other land-based activities".
LGBC Comment: At least the TCPA seems more aware thatn RTPI of the needs of green belt countryside rather than as just an inconvenient barrier round towns and is not so blatantly trying to link green belt with landscape quality.
5. The TCPA calls for four courses of action 'without delay'. (1) Initiate a review of green belt policy to assess how far it is relevant to present and future needs and how it can contribute to the achievement of sustainable development objectives. (2) Encourage the introduction by planning authorities of more limited strategic gap and green wedge policies in substitution for broad swathes of green belt no longer considered to be appropriate. (3) Jointly with the Countryside Agency, make an appraisal of how far development control in green belts hinders the agricultural sector and the strengthening of rural economies and how far the rules applying to development should be revised. (4) Encourage and promote through all the appropriate agencies more effective programmes in green belts to achieve the land-use objectives set out in PPG2.
LGBC Comment: On (1) we believe green belt policy is extremely relevant to present and future needs and that it is only the planners and developers who persist in trying to weaken its relevance. Its fault in their eyes is that it works; that is the best reason for keeping it, not changing it. On (2) we must oppose creating green wedges or strategic gaps in existing green belt but we must not overlook the fact that there have always been extremely valuable green wedges inward from the green belt, e.g. down Epping Forest and Hackney Marshes towards London's East End. We must preserve these green wedges as strongly as we must the 'circular' green belt. The trouble is that when the planners talk of green wedges they do not mean green wedges of countryside pointing inwards so much as grey wedges of bricks and mortar pointing outwards into the green belt.
'Environmental Planning': the 23rd report of the Royal Commission on Environmental Pollution.
The above report came out in March just after the Government had issued its four consultation papers about delivering a fundamental change to the planning system. It concerns itself mainly with how well our planning system for the natural and built environments meshes in with wider factors like pollution, contaminated land, etc., which ought to be included in national planning. The answer evidently is 'not very well'.
If you are interested in the broader canvas which a planning system should cover, and can get hold of a copy of the recent report without paying £25 for it, it makes interesting reading. It is highly critical of the present system, not only from the more limited Government viewpoint of whether it is nice or nasty to business or will provide enough affordable housing, but whether the system is anything like comprehensive enough. The following are some of the points made:
• Although there is a widespread view that the Town and Country Planning system needs reform there is less clarity about what objective reform should be designed to achieve. Business wants quick, predictable decisions. The Government has accepted that and therefore focused on development control to the neglect of the other essential dimension, planning for the future, even though the future of the environment is one of the major messages of sustainable development.
• Central Government's priorities ~ repeatedly and those operating the system are no longer sure what they are expected to achieve. There is no clear statutory statement of the purpose of the planning system. The Government's green paper of 2001 fails to acknowledge fundamental Issues and is too narrow.
• The Government's sustainable development strategy published in 1999 is too facile. 'In many interpretations of sustainable development, environmental considerations have been far too readily subordinated to economic and social interests ...... The goal of protecting and enhancing the environment must be fundamental"'
Our overall conclusion is that the UK does have an integrated or coherent system for identifying and promoting the actions needed at regional or local level to safeguard environmental sustainability".
The report examines the arguments for rights of appeal by third parties against certain planning decisions and comes out strongly in favour.
"We strongly commend the Government's attempt to encourage a change in direction [from policies which implied suburbanisation] and to focus the bulk of new development within existing towns and cities".
There must continue to be open bearing at which local people and others can express views about the local impacts of a proposed major infrastructure project and challenge claims by the developer".
There are 73 recommendations in all. Coming out when it has, the report cannot make very comfortable reading for the Government. We must wait and see whether any notice, is taken of the recommendations but in any case it might help our members to know of the report and be able to quote from it.
Select Committee Inquiry into DEFRA (Department for the Environment, Food and Rural Affairs)
The Journal 'Planning' reports that a Parliamentary Select Committee will inquire into the role of DEFRA and how it has fared since it was created when the former DETR was split up. "It will also look at the impact of the transfer of the environment protection group and the Wildlife and Countryside Directorate from the former DETR and will investigate what objectives DEFRA has set in pursuing its rural affairs agenda .... Many commentators voiced concern over the separation of planning from environmental matters after the departmental overhaul last year"
LGBC must contribute to this if it possibly can because saving the life of towns by preventing sprawl (i.e. DTLR) and saving the life of the country communities by preserving them from being swamped by towns (i.e. DEFRA) are two sides of the same coin. Green Belt straddles both policies and can either influence both or be lost down a departmental crack between the two. DTLR seems to he aware of its role but is DEFRA? Members who have evidence that DEFRA had failed to wade in when it ought to have done (or when members think it ought to have done) should pass the evidence on to Mr Smith. One recent planning case shows where both Departments were involved when a statutory undertaker was concerned but what about its involvement in the more general sense of defence of the countryside?
Right to Roam provisions of the Countryside and Rights of Way Act 2000
Cedric Hoptroft, who writes LGBC minutes and reproduces and distributes its papers, is now also acting as LGBC representative on meetings organised by the Forestry Commission to consider matters affecting the impact of the rights-of-way provisions on privately owned land (not just woodland). Discussion has included such matters as possible incentives for private landowners to dedicate their land for public access in perpetuity.
Green belt land seems unlikely to be in a stronger or weaker position than other land so far as the CROW Act is concerned but any member who wants to discuss the matter can contact Cedric (phone number available from Mr Smith.
Note - planning decisions included in the circulated notes are already included in the appeals section of this web site.