CPRE London’s response to London Councils’ housing paper

London Councils have proposed ten ideas to tackle London’s housing challenge. CPRE London welcomes many of their proposals however has raised concerns about the need for a clear vision and people-centred ethos to house building in the capital. CPRE London's response highlights why the Green Belt and other green spaces such as ‘metropolitan open spaces’ are important and have been given legislative protection. The NPPF recognises the need for ‘permanence’ in the Green Belt because it is of real value and it is finite. Once green belt land is developed on it will not be recovered, we’ll not get it back (See Anne Powers speach).

Between 2009 and 2012 building on open spaces in London has continued steadily. Over that time we’ve lost 216 hectares of open space land to development, particularly from housing and mixed-use sites. The majority of the land that has been lost has been in Metropolitan Open Spaces and the Green Belt (London’s green spaces need us!). This is inspite of the London Plan's Policy 7.17 on Metropolitan Open Land which states;

"The strongest protection should be given to London's Metropolitan Open Land and inappropriate development refused, except in very special circumstances, giving the same level of protection as in the Green Belt".

Once we relax restrictions on building on Green Belt land and open spaces, developers will use precedents to demand more "special circumstances". Granting planning permission for development on Green Belt and open land should only be very rare, to meet unusual public interest, and only when all other routes have been exhausted.We need to recongise the considerable value such land carries (Swap NIMBY for QUIMBY). For example, DEFRA has released a report (DEFRA 2013) indicating the Green Belt and green infrastructure contributes directly local economic growth:

• Attracting business: Attracting both businesses and customers to an area due to improved views and air and water quality
• Attracting workforce: Attracting creative and innovative individuals who find high environmental quality and a sustainable urban environment appealing;
• Cutting flood risk: Reducing flooding risk for both businesses and residents;
• Reduced energy cost: Reducing fluctuating energy cost risk for businesses and investors;
• Health benefits: Reduced health treatment costs and improved work productivity due to associated physical and mental health benefits;
• Education: Improved education outcomes and interest in STEM subjects for students able to access learning in outdoor environments, leading to a higher skilled labour force
• Ecosystem services: London's green spaces can make cities less costly to run through building up ecosystem assets, lowering costs due to reduced risks and improved air and water quality, and reducing urban heat island effects, and thereby allowing investment in other areas to stimulate economies and attracting further investment (See also CPRE London's Living London paper).

CPRE London does welcome some of London Council’s financial ideas and recommends the use of financial incentives, such as S106 and Community Infrastructure Levy (CIL), to prioritise the redevelopment of brownfield sites and new measures, such as Tax Increment Financing, to cover the upfront costs of regenerating brownfield sites. CPRE London supports improving the market for smaller builders, including the need to bring greater flexibility for small builders. This might have the additional benefit of helping to increase opportunities for neighbourhood-led initiatives, including community land trusts and self-build. We also welcome the need to address land banking and bringing public land back on stream. In addition to the proposal of a Land Value Tax London should also look into the supporting greater use of Compulsory Purchase Orders.

CPRE London is not opposed to development. We would like to see the right kinds of development, in the right places and in the right way – involving local actors. A compact community model for housing developments relies on what CPRE calls the ‘proximity principle’. When we put people at the centre of urban developments, and focus on an urban village or high street hub, with good access to amenities (schools, health care, parks etc) we find greater efficiencies of provision, sense of community and wellbeing. The Brownfield First principle also still holds; Anne Powers comments that "even in inner London...there are enough micro-sites to supply all new homes for 25 years".

Our Campaign for a Liveable London is examining compact developments from across London: from Master plan developer-led projects; local government–led infill; through to community led initiatives. We will be unpacking what makes them work and what challenges they face, as well as how community groups can be put at the centre of the process. We will share good practice lessons as soon as our findings are available in early 2014.

Click below for a full copy of our response.