I am writing to respond to Hounslow Council's West of Borough Local Plan consultation. 

I strongly object to proposals to allocate 110 hectares (1,100,000sqm) of green space the majority of which (101 hectares) is Green Belt, for development, in direct contradiction to London Plan policy, because these parcels of land all continue to fulfil Green Belt purposes.

I also strongly object to proposals to re-designate large sections of Green Belt to Metropolitan Open Land because these parcels of land continue to perform key Green Belt functions in holding back urban sprawl and stopping towns from merging. These sites should not be re-designated and should remain as Green Belt.

The council's 2017 Green Belt review is significantly flawed and reaches erroneous conclusions:

• Completely different conclusions were reached in the 2013 and 2017 Green Belt Reviews 
• The council gives inappropriate reasons for conducting Green Belt review
• The 2017 Green Belt Review and the council’s assessments repeatedly ignore the function of separating the distinct towns of e.g. Feltham and Ashford
• The council appears, inappropriately, to be questioning NPPF Green Belt policy in its 2017 Green Belt Review, rather than seeking to apply it to its Local Plan

There is no evidence that the council has adequately assessed the amount of ‘derelict and other urban land’ which could be ‘recycled’ (i.e. in relation to Green Belt Purpose 5). There are clear alternatives to building on Green Belt including intensifying nearby industrial and retail sites, redeveloping huge surface car parks, and regenerating town centres further away from the airport noise and pollution.

Site allocations appear to be for very low density development and well in excess of the stated requirement for commercial/industrial space, particularly if a higher density is assumed.

Sustainable Development has not been adequately assessed: any assessment must weigh benefits against the signficant harm caused by building on Green Belt.

Arguments and evidence for ‘exceptional circumstances’ are very weak and exceptional circumstances do not exist.

Site allocations and Green Belt Review sites are not cross referenced making for a lack of transparency.

Green Belt sites should not be allocated for housing when double the amount of land is being allocated for housing than is likely realistically to be used in the plan period.