Background
On 30 July the Ministry of Housing, Communities & Local Government (‘MHCLG’) published a consultation on reforms to the National Planning Policy Framework (‘NPPF’) and other changes to the planning system. This consultation seeks views on MHCLG’s proposed approach to revising the National Planning Policy Framework in order to achieve sustainable growth in our planning system.
September 2024: our responses
On 19th September 2024, EFHT submitted its responses to the proposed changes to NPPF, on follow basis:
- Welcome priority on developing brownfield sites but have concerns about the likely increases in housing in the north of the Forest and with the proposed changes to the NPPF on development of the Green Belt and on the definition of “grey belt”.
- The changes to the revised standard method formula will mean more dwellings being built close to the Forest in the north of the Forest [lower housing targets in London]. Increased numbers of dwellings will create more damage to the SAC from visitor footfall and air pollution from residents’ vehicles.
- Grey Belt. There are many areas immediately adjacent to, or close to, the northern part of the Forest which might qualify as “grey belt” under the wide definition proposed. Development of these would have an adverse effect directly upon the Forest through increased footfall, air pollution and, in those sites very close to the Forest, on the visual amenity and landscape character, the “natural aspect” of the Forest. For these reasons, land close to, or adjacent to the Forest should not be classed as “grey belt” but should continue to have the same protections as the Green Belt – see below re planning “Buffer Zones”
- Buffer zones. Consideration needs to be given to whether specific policies are required to limit the damage which will be caused to the Forest SAC/SSSI if land is classified as grey belt immediately adjacent to it. Historically the City of London Corporation had the foresight and funds to buy land adjacent to the area of Forest protected by the 1878 Act (Buffer Lands), in order to physically protect it from potentially damaging development. Based on this idea, one potential way to stop grey belt development damaging the Forest might be planning policy “buffer zones” around the Forest, in which no medium or large-scale developments are permitted. This would reduce the direct impact of footfall, pollution and ensure no deterioration of the landscape character of the Forest. Such a policy could possibly work to protect other SSSIs/SACs in other areas of the country
- Glasshouses. There are substantial areas of glasshouses relatively close to the northern part of the Forest. Many of these are now disused or coming to the end of their lives and we are seeing an increasing number of applications seeking to demolish these and to rebuild with large houses. This can have a detrimental impact on the visual amenity of the Green Belt adjacent to, or close to, the Forest SAC, as well as more vehicle movements and pollution. We would not wish to see any change which encourages the re-development of these areas into housing rather than their maintenance for horticultural or other sustainable and essential uses such as for solar farms. Again, policy “Buffer zones” around the Forest might prevent development of glasshouses into housing which would damage the Forest
- Previously Developed Land (PDL) and Infilling. We are opposed to the relaxation of the restrictions that are currently applied to PDL and limited infilling in the Green Belt in paragraph 154g of the current NPPF. We see many applications around the Forest which change the landscape character and visual amenity of villages and hamlets adjacent to the Forest through unsympathetic infill developments and removal of the openness of the Green Belt. It should be noted that rural gardens are defined as PDL and the proposed changes could result in more gardens being developed.