Memorandum submitted by The London Green
Belt Council (PGP 57)
PLANNING GREEN PAPERS
The London Green Belt Council, a note about
which is at the end of this submission, sent its comments to the
DTLR on 9 and 13 March, but was not aware until early this week
of the Select Committee's Press Notice 38 of 31 January. Our comments
on the questions it asks are below: we said in our submissions
to the DTLR that we thought the proposals so damaging that we
ought to comment as regards the planning system generally, not
on green belt specifically. We hope that our comments are not
too late to be considered.
Question I: The effectiveness of the present system
and the plans to replace it
2. The existing system is effective in so
far as (a) it ensures an appropriate degree of stability in the
planning scene, (b) it ensures adequate coverage of the whole
country (assuming that all structure and local plans and UDPs
are eventually submitted), and (c) it gives all interests fair
opportunities to make their points in writing or at inquiries.
Its defects seem to arise from (d) the changing relevance of counties
(see 3(d) below), and (e) the multiplicity of semi-overlapping
time scales for producing, revising, examining, and modifying
plans.
3. The Government's proposals are thoroughly
objectionable in their approach to 2(a), (b), (c) and (d). Not
only do we think that the planning Green Paper makes no adequate
case for change—it seems anxious only to pacify business
and development pressures, come what may,—but its actual
proposals fundamentally undermine what ought to be basic assumptions
for the planning system in a democratic society. Taking the four
points above separately our comments are:
(a) Stability: What people expect from a
planning system is not only a gradually improving environment
but also some stability in their expectations for its future.
In contrast the paper, if implemented, would provide for continuous
frenetic change and "renewal of vision", which would
be the despair of residents and planning authorities alike and
which would benefit only the development interests and the lawyers.
A more uncertain and potentially damaging system would be difficult
to imagine.
(b) Coverage: How can a system which would
appear to create generalisations at regional level but no detailed
coverage at either district or "local development framework"
level, but only at some sub-sub-district level possibly be effective?
It would leave huge gaps in the planning system which would be
exploited by development interests, to the destruction of public
confidence in what planning is for, and to endless argument and/or
legal test cases on what degree of planning actually applies to
what.
(c) Public Participation: The proposal to
remove the right of individuals to be heard at inquiries into
plans is fundamentally wrong. To abandon in a democratic society
what is a valued right for an individual to have his say, and
to do so on the feeble grounds offered in the paper, is simply
disgraceful, and we are astonished that it should ever have been
contemplated. Some delay and expense on this account is simply
a price that has to be paid. See also answer to Question VI.
(d) The Role of the Counties: We accept that
the ordinary progress of national and international commerce,
communications, etc, has led to a position in which some counties
may be too small to provide a sufficiently broad conspectus of
parts of the country for planning purposes. But our members feel
strongly that the answer is not to abolish the counties for those
purposes but rather to give groups of counties a broader role
without making them subordinate to regions. Counties have for
a thousand years been a focus for history, loyalties, and traditions;
and this must to a degree be reflected in planning for their areas.
By contrast regions are viewed with suspicion as unelected bodies
and as a focus only for large-scale commercial interests. so:
Question II. The Role of Regional Planning Bodies
4. If one accepts that there is a valid
case for some planning on a regional level, it does not follow
that counties must fit in with regional fiats. (We assume here
that counties are retained: the resulting position if they are
not, and if nothing precise and site-specific emerges in plans
short of sub-sub-district level, is too ludicrous to contemplate).
It does not seem to us too outrageous a proposal to suggest that
regions should present their ideas and proposals to counties,
and that they should be ideas, not commands disguised as advice;
and that counties, or groups of counties when the particular issue
seemed to make ad hoc grouping sensible, should consider
how to move forward and incorporate it into their plans. The Secretary
of State would still retain reserve powers.
5. A matter which has concerned our members
since regional considerations began to form themselves in the
planning system is the pattern of semi-overlapping bodies which
is being set up, and their relationship to each other. The RPAs
and RDAs are the prime examples. We are clear that the scale and
place of regional development must be subordinate to the overall
regional planning, just as it is at county and district levels
at present. But the RDAs seem to have different ideas and to be
jockeying for position, with the threat that development and expansion,
if they might lead to wealth creation, could occur more or less
regardless of environmental interests. The outcome would be that
RDAs' aspirations would override RPAs' planning considerations,
not vice versa. This could be disastrous for sound planning;
but needless to say Government guidance is ambiguous on the relative
weight of planning and development at regional level.
6. We therefore support a need for regional
planning so long as the regional planning bodies are democratically
accountable, and the RDAs' plans accord with regional planning
concepts, not the other way round. We ask that consideration should
be given to our suggestion in paragraph 4 that the outcome of
the process should be advice to counties, not instructions to
them.
Question III. Major Development Projects
7. Whilst accepting that it would be right
for Parliament to express a view at an early stage as to whether
a major scheme is right in principle, it is imperative that Parliament
should have enough information before it to evaluate it correctly.
By "evaluate" we do not mean the minutiae of costing
so much as a scheme's apparent desirability weighed against its
technical feasibility and proponent's financial, technical and
operational competence. The inquiries which are necessary to establish
this but which fall short of a lengthy and detailed investigation
will need careful thought, but the experience of Central Railways
has convinced us that they are necessary.
Question IV: Business Planning Zones
8. Non-planning planning zones seem to us
a contradiction in terms, and we deplore the concept. Our doubts
are reinforced by the Green Paper's references to "safeguards
that might be necessary". That really amounts to planning
restrictions by another name, so why abandon ordinary planning
rules?
Question V: Proposed Changes to Planning Obligations
etc
9. Another of the many ways in which the
papers seem determined to tear up planning safeguards is the proposal
to separate planning obligations from the application whose defects
give rise to the need for an obligation in the first place. This
means—
(a) that a general stealth tax on development
is being created;
(b) that such a tax could be used for politically-inspired
planning purposes which may or may not be supported locally;
(c) that local people will feel not only
that pressure is being put on them in this way but that developers
will be able to put pressure on local authorities and in effect
buy their way into getting approval to undesirable developments.
We therefore think that the whole idea should
be dropped.
Question VI: Certainty, Public Participation,
etc
10. We believe that the proposals will achieve
the opposite of what is claimed for them. They will generate a
sense of continuous revision unstable principles and confusion
in local authorities and public alike. Public participation will
be reduced by denying individuals the right to be heard whilst
at the same time incorporating so-called community representatives
into wide-ranging fora which are likely to be dominated by those
primarily concerned with business interests. We cannot judge whether
in the long run decisions will be faster but we have little doubt
that from the point of view of those who want some stability in
their environment they will give rise to more dissatisfaction.
The answer to the question is therefore that the proposals will
simultaneously introduce confusion and resentment in many areas
of planning.
Question VII: Urban Renaissance
11. We have no comments on this matter,
which is covered by much of what we have already said.
R W G Smith
Vice-Chairman
20 March 2002
NOTE ON
THE LONDON
GREEN BELT
COUNCIL
The LGBC was created in 1954 when the government
of the day was preparing to issue the first ever circular on green
belts: (it came out as MHLG Circular 42/55). Several national
environmental organisations, realising that green belt would be
an important and permanent feature of the planning scene, decided
that there needed to be a voluntary organisation specialising
in the subject. The LGBC is still a voluntary non-party-political
body employing no staff. Its membership, which is organisations,
not individuals, consists of national, regional and local environmental
bodies, and parish councils, within an area bounded roughly by
Leighton Buzzard, Chelmsford, Tunbridge Wells and Reading, including
members in inner London.
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