By Mike Bruton
The Government is proposing to allow unaffordable starter homes and commuter hubs in London’s Green Belt despite there being enough Brownfield sites to provide over 300,000 homes in London alone. We have drafted a short response to this important consultation which you could use (see below or follow this link). You will need to send your response tomailto:email@example.com by 22 February 2016.
Invitation to launch of new report
We are launching our important new report on the recent increase in threats to London’s protected green spaces at City Hall on Weds 9 March at 9am (for 9:30 start) to 11am.
The report details the extensive threats to Green Belt and Metropolitan Open Land in London and the real story about why threats are increasing.
We will be asking whether the land really has the ‘strongest protection’, with presentations and comments from Members and Candidates for the London Assembly and local campaigners.
Speakers include: Greens – Jenny Jones; Liberal Democrats – Stephen Knight; Local campaigners
Please allow time to clear security upon your arrival.
The event opens at 9am, with presentations starting at 930.
This will be followed by a chance to ask your questions and refreshments.
Draft response to Government Consultation on the NPPF
Q1 – I strongly object to the proposal to widen the definition of affordable housing to include models which are not subject to ‘in perpetuity’ or subsidy recycling restrictions. Including them as affordable housing would be extremely detrimental to both rural and urban communities.
Q3/4/5 – I do not support a definition of commuter hubs which enables the development of settlements within the Green Belt. This undermines national policy and is at odds with the Conservative party’s pre-election pledge to protect the Green Belt.
Q6 – No. I do not believe that the NPPF needs changing to support new settlements to a greater degree than is already provided in paragraph 52 of the current NPPF.
Q7 – Yes, the government should amend the NPPF to support the prioritisation of suitable brownfield sites within existing towns and cities over protected green sites including those in the Green Belt. Such brownfield sites should be the first priority for any public funding to reduce pressure on designated green spaces. Brownfield sites of high environmental value should be excluded.
Q8 / 9/ 10 – No, I do not support a presumption in favour of development on small sites immediately adjacent to settlement boundaries or on local green spaces. This will remove the power of local communities to decide on the development in their area and will allow towns and villages to sprawl into the countryside.
Q11 / 12 – Any delivery test should not focus on land availability or unrealistic housing targets (evidence shows this will drive development onto greenfield sites which are more profitable for developers), but on completion of housing developments. The Government should impose a delivery test on housebuilders and developers should be expected to complete within 5 years of receiving planning permission, or face losing permission or financial penalties. Housebuilding targets should be based on realistic assessments of what is likely to be delivered.
Q14, 15, 16 – Any national policy to encourage Starter Homes should not override local decision making about what type of development is appropriate. The proposals are unnecessarily narrow and would remove power from local people to make important decisions about their area. The mix of starter homes within mixed use developments must be based on locally assessed needs.
Q17 – I strongly object to exception sites for starter homes within the Green Belt: this is at odds with the government’s pre-election pledge to protect the Green Belt and starter homes are not affordable in ‘perpetuity’ and therefore will not help meet affordable housing needs.
Q18/19 – I strongly object to the proposal to allocates sites for small scale developments in the Green Belt through neighbourhood plans. Housing developments allocated through Local Plans are already threatening London’s Green Belt and this is at odds with pledges to protect the Green Belt.
Q20 – I strongly object to the proposal to encourage a more flexible approach for redevelopment of Brownfield sites within the Green Belt for starter homes. I do not support the relaxing of Green Belt controls over housebuilding, whether in relation to openness or otherwise. It is important to strengthen policy regarding brownfield sites within the Green Belt to ensure that surrounding open land is retained and remains open. Proposals should provide clearer, more detailed guidance on the ‘exceptional circumstances’ for development within the Green Belt and other protected green space.