APPENDIX 23
Memorandum submitted by The London Green
Belt Council (G27)
1. This is a submission on behalf of The
London Green Belt Council, a note about which is at the end of
this paper. I enclose a separate note apologising for the lateness
of the submission and explaining the circumstances. The submission
explains our view on what ought to be the status of green belt
in relation to the urban areas it surrounds and to the character
of the countryside of which it consists; and the consequences
for the green belt of the present split of Ministerial responsibility
between DTLR (now the Office of the Deputy Prime Minister), and
DEFRA.
2. There is still much debate in planning
circles and the professional press as to whether green belt should
be an urban planning tool or a rural protection tool. Recent submissions
by the RTPI and TOPA claim that it is the former, which means
that in their view green belts should be reviewed frequently and
in the context of urban planning. They claim to support the principle
of green belts, though their proposals would have the effect of
destroying them as specially protected areas. The Country Landowners'
Association, whilst also supporting green belts, naturally looks
at them more in the context of rural development and improvement,
and suggests a 20 year time span for reviewing the need for change
in green belt policies; but it is not clear how the present relates
to that 20 year cycle.
3. The green belt idea undoubtedly started
as a means of preventing the expansion of towns, but it has progressed
well beyond that, as is clearly recognised in paragraph 1.5 of
PPG2. To view it now as a mainly urban planning tool, as the RTPI
does is an extremely blinkered view which we emphatically reject.
Our membership (see note at the end of this submission) consists
of organisations (not individuals) spread over an area extending
from Leighton Buzzard to Tunbridge Wells, and from near Reading
to Chelmsford. The rural organisations among our membership certainly
regard the green belt as protection for the countryside against
expanding towns, and would be horrified if green belts were to
be officially regarded as simply tools for urban planning, to
be reviewed at frequent intervals by those whose interest is in
urban development.
4. The fact, of course, is that for many
years green belt has been both an urban protection and a rural
protection measure. We believe that it must be seen from both
points of view and that Ministerial responsibilities must be so
arranged as to ensure this. We return to this point below.
5. Other consequences flow from this. The
first is, what sort of countryside should green belt countryside
be? There is no denying that it varies from superb to tatty, but
it has always been a fundamental principle that the quality of
the scenery should not be a consideration in designating land
as green belt or in continuing to protect it thereafter. We strongly
support this, and our experience has shown that poorer quality
green belt is as highly valued by people living in the perhaps
modest estates bordering it as fine quality green belt is by those
living in more affluent areas. What both value is that the green
belt is what prevents them from being swamped by yet more development.
We are sure that strict adherence to the policy that green belt
is not a designation of countryside quality is right.
6. That is not to say that suitable opportunities
for raising the quality of the landscape should not be followed
up, but that it should be considered in countryside terms, not
in terms of residential development with a few trees and a "village
green" to countrify them, or of the creation of sports or
entertainment complexes. And though increased access to green
belt countryside seems sometimes to be advocated as a basic requirement,
we regard it as something which is desirable where it can be achieved
but as secondary to securing sound rural communities within the
limitations of green belt constraints.
7. So in our view there is no case for changing
green belt policy: it is popular, it is needed, and it works.
There is every reason for maintaining it, with encouragement for
the rural sector in ways that do not breach the policy, the belief
being that a vibrant rural economy up to the edge of London and
the towns within the green belt is as much in the interests of
the towns as it is of the countryside.
8. We turn now to what we are sure will
be a matter of concern to the Select Committee: how well does
the present split between Ministerial responsibility for planning
on the one hand and for the environment and rural affairs on the
other serve the needs of green belt policy? We believe that it
cannot be as satisfactory as it was when all came under one Minister.
The present split, which implies that the environment has nothing
much to do with planning, is just ludicrous. But if there is no
prospect of reuniting the two we agree that green belt policy
is best in the Department responsible for planning. The question
thus becomes what are the best arrangements for ensuring that
both planning and environmental considerations are properly brought
into the decision-making process without making green belt primarily
a tool for urban planning.
9. We do not know how close detailed consultation
has been between DTLR/ODPM and DEFRA. It should be very close
indeed, not only on such broad matters as the Government's recent
consultation papers on the planning system, but also in planning
appeals and the like. We have noted only one recent report of
a planning appeal which was jointly decided by both Secretaries
of State because it impinged on the statutory responsibilities
of both of them[11].
But there must be scores of appeals each year which are for the
ODPM to decide but which should have an input from DEFRA on environmental
considerations. No doubt the Committee will wish to find out on
what scale such DEFRA input has taken place, and consider on what
principles it has been based, whether they were the right ones,
and what guidance is needed for the scale and content of such
guidance in future. The Committee might also think it desirable
to find out to what extent DEFRA exercises initiative in letting
its views be known and to what extent it waits to be asked first.
Put another way, is DEFRA something akin to a statutory consultee
in relation to green belt appeals in rural areas, and if not should
it be?
10. We understand that these matters give
rise to difficult questions of interdepartmental demarcation,
but these have been brought on itself by the Government's unwise
splitting of responsibilities, and the aim now, we suggest, should
be (a) getting as close as possible to the situation before the
split was made, whilst (b) recognising that more attention needs
to be given to helping rural prosperity to flourish in its own
right (ie not just as adjuncts to towns), and (c) applying this
in green belt areas without breaching the principle that scenic
quality is not a material consideration in protecting green belt.
11. To sum up, we believe:
(a) green belts are a highly valued way of
ensuring both that the urban areas enclosed by them and the rural
areas that make them up get the best out of their respective situations
and needs;
(b) green belt policy is neither predominantly
a tool of urban planning nor of rural planning but a measure of
great potential (which it has demonstrated for nearly 50 years)
to help both;
(c) there is no case for changing the policy;
(d) the recent split in Ministerial responsibility
for planning on the one hand and environmental and rural affairs
on the other was a mistake which should be rectified if possible;
(e) if that is not possible, arrangements
should ensure that DEFRA's opportunities to make its views known
to the Department responsible for planning policy and the determination
of appeals should be very widely defined so as to ensure that
the environmental/rural affairs input is fed into all relevant
planning policies and appeals, without detracting from the ultimate
responsibility of the planning Minister to determine issues in
the light of established policy.
14 June 2002
11 Water pumping station. North-east Derbyshire DC.
18 April 2002. Back
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