Our objection to new threats to our green open space

The London Mayor is consulting on plans to build over the Green Belt, though we know this is unnecessary and will not solve the housing crisis. Metropolitan Land is also under threat without justification. CPRE London are requesting objections are sent before 22 June.

• It will just take a few minutes of your time. Please email your objections to londonplan@london.gov.uk  by the end of Sunday 22 June.
• Below are some suggestions based on our concerns.
• If you wish you can also read and use CPRE London draft response to London Plan consultation June 2025

Here is the objection we sent to the Mayor of London, Sadiq Khan.

1. You state, ‘My preference will always be for us to secure as many new homes as we can on brownfield sites – both large and small – and ensuring that delivery is accelerated wherever possible.’

Many brownfield sites are Metropolitan Open Land (MOL) and rich in habitat. Simply wanting to build on these sites fails to take into account the variety of such sites. Brownfield sites may also be located in areas which are already green and to build on them will be disruptive to the wider parkland.

2. You say ‘I want to ensure that any release of the green belt to help address the housing crisis makes the best use of land and meets strict requirements. This includes maximising the level of affordable housing; ensuring high-quality housing design and good transport connectivity; and increasing biodiversity and access to good-quality green spaces as part of any developments. The truth is that some land designated ‘green belt’ in London is low quality, poorly maintained and rarely enjoyed by Londoners.’

Of course you will say you want to ensure there are strict requirements. This is meaningless. There already are strict requirements. This is why this land is designated as Green Belt or MOL. You then go on to rubbish these requirements by saying some of the existing Green Belt is low quality, poorly maintained and rarely enjoyed. Of course, the response to that is to maintain it better and ensure it is enjoyed. These arguments about poor maintenance, etc. are already used to allow special requirements to prevail over Green Belt restrictions. Green Belt and MOL are already poorly protected. This is simply an invitation for those holding MOL or Green Belt to stop maintaining it. Green Belt exists for a purpose. Getting rid of it only increases the stress on people who need more open space, not less.

You then go on to say you wish to maximise the level of affordable housing. Most ‘affordable housing’ is not really affordable. We need more social housing. However, that requires public investment. The present developer-led model of house building does not even provide adequate ‘affordable’ housing let alone social housing. Housing is built to make a profit. None of the existing proposals alter this so however much you wish to increase ‘affordable’ housing this will make little dent in the housing needs of Londoners. However, your intention to build some of this housing on Green Belt or MOL will harm the health of Londoners. A lose-lose result.

Referring to high quality design is another meaningless qualification. There is no way you can ensure this as you are not in control of building. All building should be to a high quality. The reality, again, under the present system, is that housing is not built to a high quality. Indeed, planning authorities do not ensure quality in the housing they approve. Until recently they failed, for example, to ensure proper fire safety. It is unclear that this is going to change.

You then go on to state that this housing should be near to good quality green space. Of course it should! However, you plan to reduce the amount of green space rather than ensuring the existing green space is properly maintained and improved. Instead you plan to build on it.

You also state that new housing should have good transport connections. If the transport connections do not already exist then it is hard to see how this requirement can be met. More bus routes will help but some bus routes are now being closed. However, the key transport connections are rail. In so far as these take time to develop this essentially means development should occur near to existing transport connections. This is desirable. However, many of the places you refer to, such as poorly, little used Green Belt, will be precisely the kind of locations which are not well connected.

For all these reasons these statements simply don’t add up. If you are going to build near good transport connections then you are going to continue to build in areas which are, for the most part, already well developed. If you are going to build on green spaces, however poor you may consider these are, you are reducing the stock of green spaces making it impossible to provide the necessary green spaces for these new populations. Your plans rely on a failed building model which doesn’t deliver at the best of times. Developers will simply take advantage of your ‘policies’ to degrade existing Green Belt or MOL to find cheap land to make a higher profit.

The present government wishes to blame the planning system for the failure to build sufficient homes. This is nonsense. For example, in London there are boroughs like Waltham Forest which actually exceed the housing development requirements of the London Plan. Even though they do this building does not always proceed for reasons entirely unconnected to the planning system so even though they exceed the requirements in terms of plans and permissions even this does not result in sufficient development. In giving these permissions Waltham Forest ignores the requirement to protect green space and even argues, ridiculously, that building tower blocks next to green spaces enhances the green spaces!

This set of ‘policies’ will not result in the house building you expect. It will harm green spaces and the health of Londoners, particularly poor Londoners. It will not provide ‘affordable’ housing but it will be an opportunity for house builders to increase their profits.

It would make more sense to concentrate on acting on the number of empty homes than on building lots more houses, which, in any case, are unlikely to be built and will certainly not be affordable.

3. You say you want to ‘improve biodiversity’. However, instead of looking at improving existing poorly maintained green spaces you intend to build on these spaces. Your aspiration is simplistic. London has a problem with its existing green spaces. As with most other benefits they are concentrated in the more prosperous parts of London see https://www.goparks.london/articles/london-desperately-needs-more-greenspace/ So for many Londoners they actually lack green space. Perhaps you could reduce the amount of green space in these prosperous areas? Plainly that is not going to happen! So the reality is building is going to happen in poorer areas where land is cheaper and also in areas which are lacking green spaces. In addition, your description of poor quality Green Belt or MOL is likely to apply to land in these poor areas, just the kind of area where land is cheaper and where developers will look to make purchases. Hence the likelihood that this poorly maintained land will continue to be poorly maintained and then handed over to housing development. So the cycle of building in areas with inadequate green spaces will continue and accelerate.

Your desire to build more homes may be worthwhile. However, the circumstances to achieve this do not exist. The circle cannot be squared. Your prescription will make things worse without achieving the intended goal.

4. It is interesting to note that one of the few areas where Habitat Regulations apply in London, the map on page 12, is in a section of the Lea Valley. Yet Waltham Forest Council considers the Lea Valley is a prime site for building tower blocks right up against the marshes. Other boroughs like Enfield and Haringey are also building close to or in the Lea Valley.
   
5. It is also interesting to note how much of the indicated areas for building are in already built up areas in central parts of London, see map on page 15, and in areas along the Thames which will be very vulnerable to flooding.

The risks of flooding do not seem to feature in your assessment of future building capacity. Far from being safe for building on river valleys are not safe. The great increase in development in the Lea Valley has increased the risks of flooding in this sector of London. The same applies to the stretch of the Thames running through the whole of East London. Both of these river valleys feature in your map of corridors of development. Building on these flood plains is reckless.

6. As above, your map of opportunity areas on page 22, where you consider the most suitable housing sites can be found, focuses on two areas, the Lea Valley and the Thames Valley in East London, both high-risk flood plains.

7. A further problem arises with your desire to encourage industrial growth. Once again, much of this is located in poorer areas and, as you note, industrial land has declined by 18% since 2001, which you say is unsustainable, yet you think it is possible to take more industrial land for housing. You consider that there may be ‘grey’ land which is not suitable for housing which can be handed over to industry. However, this simply means redefining green land as grey and losing green spaces. Even allowing for some rejigging of designations this is hardly likely to make up for the lack of housing and the lack of industry but will certainly result in a loss of green (redesignated grey) spaces, most likely in poorer areas, already deficient in green space.

8. You suggest all these circles can be squared in your statement:
   The green belt’s original purpose was to prevent urban sprawl [starts on page 26]. This is still reflected in national policy today. However, our approach now must be allied with a clear focus on supporting nature and the environment and improving access to good-quality green spaces for Londoners. Large-scale urban extensions could enable us to deliver a programme to enhance, expand or establish regionally protected parks (Metropolitan Open Land) and other open spaces accessible for Londoners (as part of an overall infrastructure package with available funding), boost biodiversity outcomes and improve nature in other ways.

How?

When discussing the various options for the future your ‘plan’ is, unsurprisingly, short on specifics. The problems of homes being sold to foreign investors, the high rents being charged in the private sector, the lack of new social homes, etc, are all known. You note that, in reality, there is very little available Green Belt or MOL available within the Greater London Authority area. You focus on a few golf courses!

This is not a circle that can be squared and instead of trying to invent a fantasy plan to overcome the failures of national government London should simply state that the demands being made on the city are unreasonable and unachievable. London should state clearly that it has important issues to address, notably the need to improve the quality of life of its existing population, to protect and enhance its existing green spaces and to protect the city against the risk of severe flooding. London needs to state clearly that the housing shortage, which is really a lack of genuinely affordable housing, cannot be solved by continuing with present failed developer-led policies. Government needs to think of other routes to provide homes as, for example, by taking control of empty homes.

We suggest that, rather than trying to achieve the unachievable, you concentrate on what can be achieved. Nature, contrary to what the present government seems to think, really is important. Protecting nature is integral to combatting climate change and its impacts, such as city heat, flash flooding, pollution. Green spaces are vital for our health and well-being. They are also important as part of a strategy to combat air pollution and flooding. Building more, taking green spaces to do this and doing this to poor communities in vulnerable areas like river valleys is foolish, harmful and, given the existing housing ‘delivery’ system, unachievable. Protecting and enhancing green spaces can be achieved. Meeting absurd housing targets cannot. A different strategy for meeting housing need has to be devised to ensure housing
is affordable. If national government cannot devise sensible plans then London has to find ways, and lobby for them, to make use of existing resources. Making use of empty homes is an obvious starting point. Reducing dependence on the private developer model is critical. It is time to stop plucking fantasy plans out of the air.