453.There have been a number of calls for a review of the Green Belt in London to
be carried out. This matter needs to be considered in the light of our earlier
findings that capacity within London is insufficient to meet the identified
annual need for housing and the potential shortfall of industrial land in the
medium to longer term. We take a review to mean examining all land within
the Green Belt to ascertain whether and to what extent it meets the Green
Belt purposes defined in the NPPF and also to take into account any potential
to promote sustainable patterns of development in line with the 2019 NPPF.
This, in turn, might identify possible locations for growth and so lead to an
assessment of whether exceptional circumstances might exist to justify the
release of Green Belt land.
454.Different approaches to doing a Green Belt review have been canvassed
ranging from requiring boroughs to undertake them based on assessment
criteria devised by the Mayor, to the Mayor undertaking that work himself and
to the identification of specific growth areas or corridors. Whilst the Green
Belt occupies 22% of the land area of the capital it is only some 7% of the
entire Metropolitan Green Belt which stretches across the wider South East.
Any exercise should consequently take account of cross-boundary issues
relating to the coherence and durability of the Green Belt on the periphery of
the capital as well as across London itself. Therefore, a key part of an
effective review in London is likely to involve joint working and positive
engagement with adjoining authorities and boroughs.
455.Conflicting evidence has been provided about the extent of urban brownfield
land and brownfield or other land within the Green Belt that might be suitable
for sustainable development. The Plan itself observes that some Green Belt
land is derelict and unsightly and does not provide significant benefits. In any
event it is implausible to insist that the Green Belt is entirely sacrosanct
without having considered what it comprises and the impact that it has on
wider strategic objectives. Furthermore, the NPPF does not entirely rule out
changes to Green Belt boundaries although exceptional circumstances are
required to justify this.
456.The Mayor argues that however it is done such a review would take some time
to complete. A commitment to undertake one could nevertheless be contained
within the Plan. Indeed, from our perspective it would be a logical step to do
this as part of on-going future plan preparation and to assess, as an option,
whether it would be reasonable to release Green Belt land in order to close the
London Plan Examination in Public: Panel Report October 2019
gap between housing need and supply in London. This is especially given the
difficulty of accommodating growth in the wider South East. There is also a
need to consider medium to longer term industrial needs.
457.Therefore from the evidence we heard the inescapable conclusion is that if
London’s development needs are to be met in future then a review of the
Green Belt should be undertaken to at least establish any potential for
sustainable development. Therefore we recommend that this Plan include a
commitment to a Green Belt review [PR35]. This would best be done as part
of the next London Plan. Given its strategic nature and to ensure consistency
the review should be led by the Mayor and should involve joint working with
authorities around the administrative boundary as well as the boroughs. This
would form the basis for the Mayor to consider Green Belt release as a means
to deliver housing and industrial development that cannot be accommodated
in the existing built up area or in adjoining areas.
458.Policy G2 is not consistent with national policy. In particular, it states that
development proposals that would cause harm to the Green Belt should be
refused and makes no reference to very special circumstances. Similarly, the
extension of the Green Belt should only be undertaken in exceptional
circumstances as set out at paragraph 83 of the NPPF. Finally, the blanket
provision that de-designation will not be supported also ignores the NPPF
reference to altering boundaries in exceptional circumstances through the
preparation or review of local plans.
459.The Mayor maintains that the policy would not preclude limited Green Belt
release in exceptional circumstances but that is not what the policy says.
Moreover, any borough proposing this would be likely to encounter general
conformity issues. The wholescale opposition to the loss of Green Belt land is
advocated on the basis that it should be unnecessary as development needs
can be met on brownfield land without recourse to the Green Belt. But that is
not the case and national policy is not couched in this way. London’s Green
Belt is not obviously different to that encircling other major cities. Any
borough proposing Green Belt release would have to justify this at
examination taking account of the provisions of paragraph 137 of the 2019
NPPF. This expects all other reasonable options to have been examined
including discussions with neighbouring authorities.
460.Furthermore, given our conclusions about the ability to deliver housing and
industrial development within London it would be wrong to unilaterally rule out
changes to the Green Belt. That is not to say that they should be supported
as a matter of course because the national policy provisions outlined above
should apply. As well as the five purposes in national policy there are also
other beneficial functions that Green Belt land serves as highlighted in
paragraph 8.2.1. But it should be left as an option to provide boroughs some
flexibility in deciding how best to meet their development needs, including
those specifically identified in the Plan.
461.The policy also fails to clarify that support for multi-functional uses does not
override the presumption against inappropriate development and this should
be remedied. We therefore recommend that policy G2 be adjusted so that it is
consistent with national policy [PR36].
PR35 Policy G2 –
Add text to refer to the Mayor leading a strategic and comprehensive review of the Green Belt in London as part of the next review of the London Plan and to indicate the means by which this is to be undertaken.
PR36 Policy G2 Modify policy G2 as follows:
“A The Green Belt should be protected from inappropriate development:
1) development proposals that would harm the Green Belt should be refused except where very special circumstances exist;
2) subject to national planning policy tests the enhancement of the Green Belt to provide appropriate multi-functional beneficial uses for Londoners should be supported.
B Exceptional circumstances are required to justify either the extension or de-designation of the Green Belt through the preparation or review of a local plan.