Royal Commission on Environmental Pollution

I am writing to you at the suggestion of the secretary to the UK Round Table on Sustainable Development, with which The London Green belt Council has had correspondence from time to time. A note about the LGBC is in Appendix B. My reason for writing is to explain our interest in various points mentioned in your circular letter of 21st July about the Royal Commission's study of environmental planning, and to ask that we should be put on your consultation list and kept in touch with the progress of the study.

Appendix B shows that the LGBC keeps under review the problems and prospects of London's green belt as a whole; makes representations on developing policy issues at Ministerial or official levels; and advises its member organisations on what may or may not be legitimate points to make in their own representations about local issues, etc. This means that we are well used to responding to the constant efforts by the development industry, some local authorities, and parts of the planning profession, to undermine green belt policy and assert that the policy relating to it should be changed. Nevertheless as Governments of both persuasions are well aware it is an extremely popular policy which has rarely been the subject of dispute on party lines since the first circular on green belts was issued nearly 50 years ago. We want that situation to continue, and see no reason why it should not.

Our main present concerns are not so much with grumblings from the traditional sources as with threats from two unexpected directions -

1. The attitude of the former Countryside Commission to green belt. We hope that it will be changed by the new Countryside Agency;

2. The widespread use of the expression 'sustainable development', which is utterly ambiguous in that it can be, and is, invoked to sanctify completely opposing concepts.

I assume that the Royal Commission will not wish to concern itself with the minutiae of (1) and (2) above so much as with the results of the woolly thinking in the way the policies are described and handled. If there is anything further we can do to help, you have only to contact me.

Copies of the minutes of our last two meetings are enclosed.

Major matters of concern to the LGBC and which seem relevant to the Royal Commission's study of environmental planning

This note relates only to two broad issues. It does not include consideration of DETR policy papers or of specific cases, some of which do in themselves have wide implications.

The former Countryside Commission's attitude to the Green Belt
1. The LGBC had for some time had the impression from Countryside Commission publications that it wished green belts did not exist because they did not fit in with its idealised concept of a quality countryside for all. We complained to the chairman of the Commission in 1998 and early 1999 about the Commission's failure to recognise that some important land-use categories are deliberately not related to scenic quality; that the implication in its publication 'Linking Town and Country' (1999), that where green belt causes pressure on high-quality land beyond the green belt, the green belt should give way; and that great damage would be done by its almost unbelievably naive advice that a consideration in considering some planning applications should be whether the green belt in question is 'the final space between two settlements'. Anyone with any practical experience of the planning appeal system would know that that would be a recipe for whittling green belt away to almost nothing as successive Counsel argue in different appeals about how 'final' is 'final'.

2. The Chairman referred us to the Commission's successor, the Countryside Agency. We welcome the demise of the Commission, which seems to us completely up in the clouds where broad policy is concerned; and hope that the Agency will have a more common-sense approach, as it has to reconcile a different combination of practical rural issues. We have approached its Chairman., and believe that the Agency will debate its policy on green belts in due course. In the meantime, the snag from our point of view is that some sort of policy has to be carried forward, and that is the existing Countryside Commission policy, applied by the same ex-Commission staff, who have changed one initial letter in their Department's title but very little else. This impression was confirmed by discussion with the Agency's Chief Planning Officer. (See items 296(1)(a) in the LGBC minutes enclosed).

3. A subsequent publication by the Agency acknowledges that some area-based policies will often need to be retained - 'perhaps where a green belt is defined' -, but still urges that 'lines on maps' should not protect some areas whilst making others vulnerable.

4. The above experience may seem relevant to you in the context of items (c) and (d) of the list in your letter of 21st July. As regards (c), is it right, for instance, that a body with special status as the Government's advisor on the countryside should produce a document embodying a highly idealised concept of the countryside of the future, without including any analysis of the practical consequences of its vision. Needless to say, the vague ideal is being seized upon with glee by development interests with different agendas of their own. But in the real world the consequences of abandoning 'lines on maps' to designate planning areas, in favour of policies setting out planning criteria, would be indefiniteness in planning; a vast increase in the scope for legal argument at appeals; and costs, delays and frustration all round. As regards (d) from your list, the ability to operate statutory procedures, and public confidence in the appeal system, would be weakened by the proposals, with a blurring of the distinction between town and country.

   The Meaning of 'Sustainable Development'.

5. We are very relieved to note that the words are in inverted commas in your letter of 21st July. The expression is popular world-wide because it means whatever the speaker wants it to mean. Taking the green belt land-use context alone, does it mean 'go on developing so long as there is some undeveloped land left', or does it mean 'uphold and protect what there is'?. Developers quote it to justify the former; we believe that in green belt it should mean the latter. A concept with two such diametrically opposed meanings is quite useless as a plank of policy. Yet the phrase appears with increasing frequency in planning documents, planning journals, justifications for development, appeals, etc, seemingly just because it is a vogue word and therefore must mean something important.

6. This is relevant to item (e) of your list. The Royal Commission's consideration of that item surely cannot start without its considering what, if anything, the term means. We hope that the Royal Commission will consider criticising strongly the cult which has grown up round the word, and will recommend dropping it and substituting something less ambiguous, at any rate in the land-use context. Any alternative would be less pithy, but should be more meaningful, embodying as separate ideas the need to uphold protectionist policies in some land-use categories, and permitting development which will not harm future resources or quality of life where other categories apply.

   October, 1999

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   Appendix B

   The London Green Belt Council

   The London Green Belt Council (LGBC) was created in 1954 when the Government of the day was preparing to issue the first ever circular on Green belts (it became Ministry of Housing and Local Government Circular 42/1955). A number of the principal environmental organisations of the time, realising that green belt would be a permanent and important feature of the planning scene, decided that there needed to be a new organisation specialising in the subject, rather than leaving it as just one more item on the agendas of the existing organisations which were already busy with many other matters.

   The LGBC is still a voluntary body employing no staff. Its membership still consists of organisations, not individuals. It includes the national bodies that founded it (Open Spaces Society, CPRE, YHA and. Ramblers' Association); regional bodies like the River Thames Society; local amenity societies and Residents' Associations from an area bounded roughly by Leighton Buzzard, Chelmsford, Tunbridge Wells and Reading (including inner London organisations with no green belt in their areas); and parish councils. A few planning authorities pay to receive LGBC papers without becoming formal members.

   The LGBC meets quarterly in central London. It is on the DETR consultation list for policy papers with implications for green belt,, and makes representations as necessary, including directly to Ministers; advises members on points that can and can not be made in objections and at inquiries; issues guidance notes to members on such matters and appeal decisions, etc, about five times a. year; and takes part in some inquiries directly. Its aims are to keep the value and popularity of green belt before Ministers' eyes, and to help its members fight local causes more effectively. It is entirely non-party.

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