Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


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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