Text of letter from CPRE London to the deputy mayor of London
Jules Pipe
Deputy Mayor of London for Planning,
Regeneration and Skills
City Hall, Kamal Chunchie Way
London E16 1ZE
By email to: jules.pipe@london.gov.uk
27 February 2025
Dear Jules,
We wanted to get in touch to seek clarity about several recent announcements by the Mayor which we are concerned indicate a change in his position on protecting London’s Green Belt.
Pan-London Green Belt Review
We were extremely disappointed to learn there will be a Green Belt Review. We and would like to understand more about the rationale, in particular:
1. We understand the focus will be on identifying ‘grey belt’ land ‘in areas where local targets cannot otherwise be met’ – where ‘grey belt’ would be defined as land already been built on or which does not strongly meet Green Belt purposes. This is a huge concern: the term ‘does not strongly meet’ is subjective. How does the GLA propose to ensure this review does not undermine London’s Green Belt? And how will the GLA undertake this review in such a way that absolutely ensures the brownfield first principle applies?
2. There is a pipeline of 286,000 potential new homes already granted planning permission in London and waiting to be built. That is an 8 year supply, assuming a realistic build rate of 38,000 per year , based on the average achievement of the last ten years. Added to this, there is a vast amount of brownfield land in London which has been, and is due to be, allocated in borough Local Plans to accommodate a great deal more than this 286,000, like to be upwards of a 15 year supply. Do you agree that releasing Green Belt for housing, in these circumstances, is unnecessary?
3. According to Table 122 Net Additional Dwellings have averaged 38,000 per year over the past 10 years. Do you agree that a build target of 88,000 is therefore manifestly unrealistic?
4. Do you agree that, if land is allocated on the basis of a target of 88,000 dwellings to be built per year but that only, say, 50,000 new homes are actually built (a very ambitious build rate based on the past 10 years average), that a large amount of land allocated for homes will simply lie idle? And do you fear, as we do, that Green Belt will be released, and built on, while brownfield land lies idle?
5. At CPRE London, we have stressed for a long time that just building houses cannot solve the housing crisis in London, which is primarily about affordability. While we support housebuilding, we do not believe that simply adding to housing stock, even at 88,000 per year, will reduce house prices or rents to an affordable level. We believe urgent action is now needed to stablise and even reduce prices, including by dramatically increasing the supply of homes for social rent; introducing measures to put downward pressure on rents; and tackling under occupancy and empty homes. Would you agree that conducting a Green Belt Review is something of a distraction from focusing on the real solutions to London’s spiraling housing crisis?
6. London is facing a huge threat from global warming and flooding and Thames Water has said that we already need to manage rainfall run-off from 7,000 hectares of built and paved surface. We need to increase, not reduce, the ‘sponginess’ of our city. Nature is in decline and London needs to deliver major expansion and restoration of good quality habitat as detailed in the Mayor’s Environment Strategy. Land is needed for agriculture close to the city. Do you agree that, to manage nature and climate risks, and ensure food security, we cannot afford to pave over any more green fields?
7. We very much hope that Metropolitan Open Land (MOL) will not be included in this review. Do you agree that London’s MOL is critically important to the future of the city in so many ways and that we simply cannot afford to lose any of it? And can you confirm that MOL will not be part of the review?
Enfield’s Green Belt
We were concerned to hear Lisa Fairmaner (speaking at the current Enfield Local Plan Enquiry under delegated authority from the Mayor) suggest a change to the GLA’s position on the Green Belt: “In principle, the need for some Green Belt release to contribute towards London’s housing need, to tackle the housing crisis, appears unavoidable, given the changes to national policy about needing to release Green Belt where housing and other development needs cannot otherwise be met, and the significant increase in London’s mandatory housing need figure.”
We have appreciated the strong line taken by the Mayor on protecting Enfield’s Green Belt previously but these recent comments signal a weakening of this position. This is extremely worrying given the vast quantity of brownfield land available for housing in Enfield in general, and the stalled development of 10,000 new homes at Meridian Water in particular.
8. Has the GLA changed its position before the London-wide Green Belt Review has even started? And do you agree that the priority should be to build the homes at Meridian Water, as well as sites like the A10 retail park in Enfield, which collectively easily provide enough land to meet ambitious annual housebuilding targets in Enfield for 15 years, before there is any consideration at all of Green Belt release? Do you agree that releasing Green Belt in Enfield risks green fields being used before these many brownfield sites?
London Growth Strategy
We were surprised to see a reference to ‘NIMBYs’ in the recent press release for the Mayor’s London Growth Strategy. The Mayor is quoted as saying “While our planning system isn’t the biggest obstacle to new development, it’s more important than ever that we take on the NIMBYs who stand in the way of delivering the homes and jobs we need. At City Hall, we’ve recently approved a series of new developments in the face of some opposition, showing that we’re willing to put the needs of our city – and country – above the vocal minority”.
Our experience is that it is, in reality, virtually impossible for local people to block development. And in any event, the statistics do not support the position that ‘NIMBYs’ are the cause of London’s problems: London Councils point out that “Boroughs grant planning permission for over 57,000 new homes each year (on average, based on annual approvals between 2020 and 2023)”. We find this language deeply unhelpful.
9. Do you agree that ‘nimbyism’ is not a cause of London’s housing crisis? And do you agree that it is in fact essential for local people to be able to have their say and challenge developments affecting their local area particularly when green space, with all of its environmental and public health benefits, is at risk of being lost?
In light of these recent comments and the announcement of a London-wide Green Belt Review, we hope you’ll be able to reassure us that the Mayor’s longstanding commitment to protect the capital’s vital green spaces and Green Belt remains undiminished.
We look forward to hearing from you.
With kind regards,
Alice Roberts
Head of Campaigns, CPRE London
Links
Mayor’s Green Belt review ‘distraction’ from tackling London housing crisis (CPRE London 27 February 2025)
Khan set to support new housing on London’s Green Belt for first time, inquiry hears (Enfield Dispatch 22 January 2025)
Sadiq Khan announces review of London Green Belt as he restates ‘brownfield first’ stance (On London 16 January 2025)
Information about the Enfield Local Plan on the Enfield Society website
Enfield RoadWatch reporting on the Enfield Local Plan
Letter from the Planning Inspector to Enfield Council dated 14 February 2025 (A list of tasks for the council to complete by 31st March)