Metropolitan Green Belt Local Plan Survey
The government repeatedly pledged to protect the green belt but all around the country, local authorities are planning to release huge areas of green belt for development in their local plans. For more details see the CPRE/LGBC report "Safe Under Us?" This site provides updates and notes on the status of Local Plans for planning authorities that include the London metropolitan green belt. For information on individual threats to the London green belt please see the London Green Belt Councils interactive Threat Map
The London plan produced by the Mayor of London lays out the spatial development strategy for the Greater London Area. Individual London Boroughs form their own Local Plans that comply with the London Plan. The current London Plan dated March 2016 was published and amended in January 2017.
The Greater London Authority covered by the London Plan includes 32 London Boroughs and the central City of London. About half of these which are situated around the outer ring include some green belt and these are covered individually below.
The plan includes details of planned housing growth in the 25 year period from 2011 to 2036. The overall assessed need is for 62,000 new homes per year in 2015 to 2026 and 49,000 per year over the longer period 2015 to 2036. This means that the need for growth is halved in the final decade. The plan sets minimum targets for each borough amounting to 42,389 homes per year leaving a shortfall of nearly 7,000. These figures include assumptions of continued outgoing migration mainly to boroughs and districts in the metropolitan green belt outside the GLA. If the shortfall cannot be made up and population growth cannot be reduced through tighter immigration controls, then other boroughs will be asked to meet this unmet need.
The distribution of expected growth across the GLA is very uneven. The highest targets for the decade 2015-2025 are 39,314 in Tower Hamlets, 27,362 in Southwark, 26,850 in Greenwich, 23,489 in Barnet, and 19,945 in Newham. These are huge numbers that justify some scepticism. At the other end of the scale only 1,408 homes are planned for the City of London in the same decade and 3,150 in Richmond upon Thames. As a general rule new development is being targeted for East London North of the Thames with many London boroughs to the West being allowed to avoid meeting their assessed needs.
Most of the growth will have to be achieved through regeneration of central residential areas where Victorian terraces will be demolished and replaced with modern high-rise developments. There are numerous challenges faced by this plan. Existing residents are being displaced, often to commuter towns outside of London. The new housing in London is unaffordable and sometimes bought up by foreign investors who leave it empty. New jobs are not always provided to match the number of new homes. After the Grenfell fire there are concerns about the safety of high rise developments. Improvements to infrastructure and services that rely on low-paid key workers may not be able to match the population growth. The regeneration is only feasible if there is massive investment, much of which has not yet been secured. The financial viability is highly sensitive to interest rates, immigration-led demand and political change. Economic and political uncertainty could prevent projects from getting off the ground. The construction industries capacity for development is finite and if land is released from the green belt further out from the centre of London, the major developers will focus on the easier opportunities for quick profit that are handed to them. The London Mayor aims to protect the green belt within the capital but seems to have no care for its preservation beyond his boundary.
Forecasts predict the 46,500 homes will be completed in London during 2017. This is more than the 42,000 average target over the longer plan period but much less than the 62,000 per year wanted in the shorter term. Unfortunately the number of homes started in 2017 will be only 21,500 indicating a sharp slowdown due to falling demand from buyers.
Given these dramatic failures to meet the London Plan targets it hardly seems worth mentioning that they are based on outdated household growth projections when the 2014-based projections from the ONS are taken into account, as is happening in Boroughs outside London, the targets will rise even further and the shortfall will be even greater. Perhaps it would be more reasonable to question the objectivity of the growth projections and methodologies that are used to set the targets than to complain about the failure to meet them.
A 2017 consultation has been looking at radical options for dealing with transport infrastructure problems in London as density increases. A "green" approach based on public transport rather than cars is being heavily promoted by the London Mayor.
Dartford Market Area
Borough of Dartford
Dartford is the scene for one of the most congested sections of road in the country. Cars and lorries queue every day on the M25 waiting to enter the Dartford tunnels which have long since outgrown their intended capacity. The area by the banks of the Thames in built up while the other half of the borough to the South is green belt and also partly in the Kent Downs AONB
The council adopted a Local Plan in 2011 and have updated some parts since then. However, it has not made much progress towards a revised plan and has been criticised for not having a five year land supply.
The Kent extension of Crossrail is proposed to pass through Dartford and is expected to unlock the potential for 200,000 homes along its route.
Gravesham Market Area
Borough of Gravesham
Gravesham lies on the south side of the Thames Estuary. Its rural areas make up three quarters of its area and are entirely within green belt. In 2017 Highways England announced that the Southern end of a new Lower Thames Crossing would be in Gravesham with new connecting roads passing through the green belt. The government says that this will "unlock" housing development in the area.
Gravesham adopted a Core Strategy in 2014 with a target of 6170 homes over 17 years. The council claimed that this met the assessed needs from 2012 but some estimates put it at 22% less and updated numbers would undoubtedly be much higher. Delivery has been lower than the target. The council is now gathering evidence for a revised plan but this is in early stages.
The Kent extension of Crossrail is proposed to end in Gravesend and is expected to unlock the potential for 200,000 homes along its route.
In october 2017 the council announced a consultation to add more green belt sites into the plan. They said that the target had to rise to 7.905 homes due to the new figure for LHN. This came just after the new 2016 ONS housing projecions showed that numbers had previously been overestimated.
North Kent Market Area
Medway is situated on the South side of the Thames Estuary. A large part of it is a conurbation of Chatham, Gillingham and Rochester. About 6% of its area is green belt and part of the Kent Downs AONB. That leaves the Northern half that sticks out into the Thames Estuary. At least half of this area is liable to flooding and is therefore unsuitable for housing development.
The North Kent SHMA gave the Local Authority a high assessed need of 1,281 dwellings per year. There has also been some historical under-delivery. In early 2017 the council held a consultation to look at options for accommodating 30,000 new homes over the 20-year period to 2035. In adition to expanding existing communities the council proposed a new town of 5,000 homes at Lodge Hill - a disused MOD site. This has been vigorously opposed due to its environmental impact in a sensitive area. In August 2017 the MOD withdrew its planning application citing opposition from the RSPB who said that the site is important for rare nightingales.
Borough of Tonbridge and Malling
Tonbrige and Malling Borough is in the South West London green belt. Anout 70% is designated as green belt but much of the remaining is either in the Kent Downs AONB or is already built up. This leaves just a small area of countryside south of Malling that is unprotected. The M20 and M26 run through the borough.
The council is in the early stages of preparing a Local Plan. The SHMA assessed the need at 696 homes per annum or 13,920 over the 20-year plan period. In an options consultation the council argued that another 6000 homes should be added to this target because of existing planning applications. This is despite a historic delivery rate that matches the assessed need, a rare achievement.
Specific sites have not yet been determined but there have been proposals for an 3,500 homes development around Borough Green to convert it into a garden city. This site would be in the green belt as would most of the other options proposed by the council. A draft Local Plan consultation is now in preparation.
Borough of Maidstone
Maidstone is on the puter edge of the South East London green belt with just a small token of green belt within its boundaries. The M20 passes through the borough with two thirds of its area lying to the South West of the motorway. The third on the other side is mostly inside the Kent Downs AONB and is therefore protected from development.
Maidstone Borough Council has submitted a Local Plan that meets its assessed need for housing of 19,600 homes. Residents criticised the projections to argue that a much lower figure would be more appropriate but the planning inspector countered this in his summing up saying that the numbers are correct because international migration may not fall as hoped. He also suggested that the number may have to go up when reviewed if London or other boroughs asked Maidstone to take some of their unmet need.
In September 2017, just as the council was preparing to adopt the Local Plan that had been found sound, local MPs managed to get a posponment of the council vote because of a DCLG consultation which proposed a higher assessed need for the borough. The change from Objectively Assessed Need to Local Housing Need would raise the figure from 883 dpa to 1,236 dpa. The new number is based on an ad hoc formula whose only benefit is its simplicty. It is not due to come into force until Spring 2018 and then only if it passes public consultation.
Sevenoaks and Tunbridge Wells Market Area
Borough of Tunbridge Wells
The Borough of Tunbridge Wells runs out from the South East corner of the London Green belt. Only about 30% is within the green belt but about 80% is within the High Weald AONB which should be spared from development. Royal Tunbridge Wells its the only large town and is entirely surrounded by green belt and AONB making it hard to extend without violating constraints. The area is also not well served with major roads.
In April 2017 the council held an Issues and Options consultation with the aim of finding sites to build 13,000 homes over 15 years. This is based on the 2015 SHMA which gave a figure for 20 year growth about 34% more than the calculated OAN. It is far from clear how this was justified. The council is not treating the AONB or green belt as a barrier to development with many of the areas considered for development being within these areas. At least one large garden village or town within the AONB is one option being considered.
Sevenoaks is the district with the largest green belt area in the London green belt. The remaining 7% of land is urban. In addition about two thirds of the local authority is part of the Kent Downs AONB or the High Weald AONB.
In August 2017 an issues and options consultation presented different possibilities for future housing development. This included a significant number of green belt sites but the council says that all options are open and no decision has yet been taken.
South-East London Market Area
London Borough of Bexley
Bexley lies at the Eastern edge of the GLA on the South side of the Thames. About 20% of its area is green belt.
The council currently have a core strategy that was adopted in 2012. This should be compliant with present legislation but assessed needs have increased enormously since that time.
Bexley is preparing new 20-year Local Plan. They say that 31,500 homes can be accommodated in the long term. They intend to consult on preferred options at the end of 2017. This means they could aim for a high housing target to meet the full assessed need although it is not clear if this would require green belt release. Their current delivery rate is nevertheless much lower.
The Kent extension of Crossrail is proposed to pass through Bexley and is expected to unlock the potential for 200,000 homes along its route.
London Borough of Bromley
Bromley lies in the South Eastern corner of the GLA and is the largest of the London Boroughs. About half its area is green belt and the rest is the urban edge of London.
The council has set a target of 641 homes per year. This is the minimum amount as specified in the London Plan, but it is only about half the figure given in the SHMA. The Bromley Local Plan aims to achieve this target with only small adjustments to the green belt for schools traveller sites, but an addition area of about 30 hectares will be released from the green belt near Biggin Hill.
The council held its pre-submission consultation in November 2016 and has now submitted the Draft Local Plan to the Secretary of State for examination. Elizabeth Hill has been assigned as the planning inspector.
Tandridge Market Area
Tandridge District which straddles the Southern leg of the M25 is 94% green belt with a few small towns such as Oxted. Small areas are also in the Surrey Hills AONB and the High Weald AONB.
Considering the low amount of urban area the assessed need of 700 homes per year for the district is high. The council have decided not to use green belt as a constraint. In a sites consultation held in early 2017 they proposed to build 9000 homes on the green belt. In addition they have expressed an interest in creating a garden village of 4,500 homes in one of several named locations in the green belt. These plans have met with opposition from residents.
Croydon Market Area
London Borough of Croydon
Croydon is a heavily urbanised London Borough south of the city, A quarter of its land area is designated as green belt. It has the highest population of all the London Boroughs
In 2000 the Local Authority began work on an ambitious regeneration scheme known as Croydon Vision 2020. The plan was to build up the town of croydon with high-rise offices and appartments. The project has accelerated over the last few years with housing delivery rising to over 2000 in 2015. This included the impressive Saffron Square 40-storey tower which was completed with 739 homes in addition to offices and retail space.
One of the anomalies of the system for calculating OAN is that if you build fast this will affect the calculation of migration into the region and land you with a high assessed need. In 2015 Croydon was landed with an eye-watering OAN of 2,437 homes per year. This means that they are punished for high delivery with a requirement to keep building even faster for the next 15 to 20 years.
The Croydon 20-year plan for 2016-2036 sets a target of 32,880 homes. This is higher than the London Plan minimum, but less than the latest OAN. Examination hearings have been completed and a post examination consultation on changes is underway as of August 2017.
Sutton Market Area
London Borough of Sutton
Sutton is a London Borough in the South of the GLA. It is mostly urban but with about 15% in green belt.
The draft local plan sets a housing target of 427 homes per year. This is greater than the minimum from the London Plan of 383 but much less than the latest assessed need of 1,100 homes per year. Some green belt is marked for development.
The Local Plan was submitted for examination in 2017 and planning inspector David Smith was assigned. Hearings are now in progress.
Reigate and Banstead Market Area
Reigate and Banstead District
Reigate and Banstead District stretches South from the edge of London across the M25 to just North of Gatwick Airport. It includes isolated urban areas surrounded by green belt making up 70% of its land area. The M23 runs near its Eastern boundary. A narrow strip of the Surrey Hills AONB runs across the district near the route of the M25. Other constraints include Conservation areas and areas at risk of flooding.
A revised 15-year Core Strategy was adopted in 2014 with a provision for 6,900 homes to meet the assessed needs of the time. 1600 of these homes would need to be on the green belt. The plan was first submitted in 2012 with a sub-OAN target justified by the green belt constraint. During the examination the inspector instructed the council to recognise that some loss of green belt would be necessary to meet housing need. The examination was suspended and resumed later when a new verions of the plan included some green belt development but not enough to meet OAN.
This Local Plan represents one of the few cases where the planning inspector forced the Local Authority to build on green belt. his legal arguments were very shaky and it is a great pity that the council did not ask for a judicial review to challenge the outcome.
The council is now preparing a Development Management Plan and a new Policies Map which they expect to adopt in early 2018. There does not appear to have been any update to the assessed need for housing since 2012.
Kingston Upon Thames and North East Surrey Market Area
Borough of Epsom and Ewell
Epsom and Ewell is a borough inside the M25 South of London. Nearly half is green belt and the remainder is built up with towns connected into the urban areas of London
The council has no compliant local plan and has done very little to prepare one. They do not even have a compliant Local Development Scheme for a new Local Plan but there is a programme for a partial review of the Core Strategy which dates to 2007. Their program schedules an Issues and Options consultation for early 2017 but this has not yet taken place. It also details further consultations to take place in rapid succession with adoption of the partially revised Core Strategy in April 2018. Housing delivery rates in recent years have been less than half the assessed need in 2016. The council has dismissed criticisms and warnings as scaremongering.
A green belt review published in May 2017 identified 9 areas of green belt on which 1000 homes could be built.
In 2017 the planning inspectorate launched a review of council planning decisions after 4 refused planning applications were overturned on appeal. The council now risks loss of its planning powers which would be taken over by the inspectorate.
In October 2017 the council finally announced an options consultation. They set the assessed need at 8685 homes for a 15 year plan based on the governments proposed LHN figure in policy still under consultation. the council says that there is only space for 3000 homes unless they consider options such as high density multi-story housing or development of the green belt. Four options along these lines were offered for residents to comment on.
Royal Borough of Kingston Upon Thames
Kingston Upon Thames is a London Borough in the South West of the GLA. It is mostly urban with 17% of its land area designated as green belt.
A core strategy adopted in 2012 aimed to meet the minimum target of 375 homes per year set by the London Local Plan. This number has since risen to 643 homes per year and the housing market area assessed need is 717 homes per year. So far very little of its green belt has been threatened with development.
The council is preparing a new 25-year Local Plan to start from 2019. There has been a call for sites to finish at the end of 2017.
Borough of Elmbridge
Elmbridge is a populated area within the South West corner of the M25. A little over half of its area is green belt.
The council conducted a consultation at the end of 2016. The preferred option is to develop about 4% of their green belt in order to meet the assessed need.
Mole Valley District
The Mole Valley District stretches south from Leatherhead by the M25 towards Gatwick Airport. About a fifth of its area in the South is outside the green belt and about half of its green belt is also in the Surrey Hills AONB. There are smaller towns including Dorking at its centre.
The council have been slow to revise their plan to bring it in line with the OAN. The current plan should fulfil an earlier assessed need of 221 dpa but they have been under-delivering for the last 8 years. The latest OAN is 391 homes per year. In 2017 the council conducted a consultation on development options. Despite the area of unprotected rural land they stated prior to the options consultation that it might be necessary to lose 0.5% to 1% of their green belt. Only enough space for 2,900 homes had been identified which is only half the assessed need with the AONB mostly protected. However in September 2017 there was a new proposal for a 3000 home garden village near Ockley which is just outside the green belt and AONB. That could bring them much closer to meeting their assessed need.
They may also be made to consider some unmet need from the more crowded and constrained boroughs nearer to London and in the same housing market area. The target for plan adoption in 2018 is very optimistic considering the early stage of preparation.
West Surrey Market Area
Borough of Waverley
Waverley in the South West corner of London's green belt South of Guildford includes significant areas of the Surrey Hills AONB between the towns of Farnham and Goldalming. Significantly it also includes an area of unconstrained open land around the smaller towns of Dunsfold and Cranleigh.
The council have split its Local Plan into two parts so that it could be examined sooner. Part 1 covers general strategies including housing numbers with part 2 under preparation to detail individual development sites.
Part 1 was submitted for examination in 2017. The assigned planning inspector Jonathan Bore raised Waverley's assessed need from 519 to 590 homes. This was to include an update to the housing projections and 50% of Wokings unmet need because Waverley is the only borough in its housing market area with some undeveloped non-green belt land. The council allocated the extra need to sites within and outside the green belt. This raised objections from Farnham Parish Council because the new proposals exceeded housing numbers already agreed for its neighbourhood plan.
A developer launched an appeal against a refused planning permission for 1800 homes at an aerodrome in Dunsfold on the basis of the inspectors decision. The council and local residents continued to oppose the development despite it being on previously developed land which is not constrained as green belt. Lawyers have asked the Secretary of State to call-in both the development and the Local Plan.
In response to the modification consultation ending the examination process campaigners submitted a report challenging the inspector's housing target numbers. The detailed review cammissioned by the CPRE concluded that the housing target should be reduced by 29% based on two factors: Woking's unmet need and the uplift factor.
Borough of Guildford
Guildford lies within the Southern part of the Metropolitan green belt close to the M25 and M3, It is mostly rural apart from the large town of Guildford itself. The surrounding countryside is entirely green belt and in addition the Southern half is part of the Surry Hills Area of Outstanding natural Beauty
In early 2017 the council responded to pressure from green belt campaigners by reducing the housing target from 693 to 654 new homes each year. By increasing density on town centre brownfield sites and adjusting phasing of delivery it was possible to save some of the larger green belt sites for the pre-submission consultation. There are concerns that the planning inspector will ask for the numbers to be increased. It remains to be seen whether Guildford has done enough to satisfy the requirements of Duty to Cooperate.
Campaigners are also fighting a proposed 2000 home new town on green belt at Three Farms Meadows. The council refused planning permission but have been accused of making a lame defence to an appeal.
Borough of Woking
The borough of Woking stetches out from the M25 between the M3 and A3. The urban area of Woking is at its centre surrounded by rural green belt which constitutes about 60% of its land area.
A Core Strategy was adopted in 2012 with a target to build 292 houses each year from 2010 to 2027. This was sufficient to meet assessed needs of the time, but with recent updates to housing projections this makes up only about half of the boroughs need for housing. Some areas of Green belt were designated as reserved for the period 2027-2040. The council has stated in responses to the Waverley examination that it will not bring these forward to help with unmet need before then because of constraints.
Evidence is being procured for revision of the plan and preparations have attracted a lot of interest from campaigners. In 2015 there were 32,712 responses to one consultation.
In the ongoing 2017 examination of the Waverley Local Plan Part 1 the planning inspector instructed Waverley Council to increase its housing target to accommodate half of Woking’s unmet need. He commented that this was necessary because Waverley is the least constrained of the three boroughs in the housing market area.
Runnymede and Spelthorne Market Area
Borough of Spelthorne
Spelthorne is a borough mostly inside the M25 between the M3 and M4 and South of Heathrow Airport. 65% is green belt but much of the land along the Thames is taken up by reservoirs or is at risk of flooding.
The current Local Plan is from 2001. They decided to start working on a replacement plan in 2014 and have been preparing since then. There have been some consultations on parts of this evidence but otherwise progress seems very slow indeed.
In 2017 Kempton Park racecourse was proposed by its owners for development to provide 3000 homes. This was opposed by the council and residents due to it being green belt land.
Borough of Runnymede
The Borough of Runnymead is an area of mixed rural and urban development centred on the junction with the M25 and M3. It includes Thorpe Park and a number of small towns. All of its open land is designated as green belt.
In 2014 the council submitted a Core Strategy to the Secretary of State for examination. The plan set out to meet about 68% of its assessed need at the time citing green belt and flood constraints as justification for the shortfall. The planning inspector quickly rejected the plan on the grounds of incomplete evidence and failure on Duty to Cooperate. The plan was then withdrawn for revision.
In 2016 the council conducted a public consultation on Issues Options and Preferred Approaches for a revised 15-year Local Plan. A number of housing target options with proposed with the number of homes ranging from 2,850-10,165. The highest target would have met the assessed need which has doubled since the 2014 withdrawal.
In early 2017 a proposed garden village at Longcross was announced to be among 14 garden vallages given government backing. The site is along side the M3 by the border with the neighbouring planning authority of Surrey Heath. The 84 hectares of land would be developed for around 1,500 homes. There was an additional sites and options consultation in 2017.
Hart, Rushmoor and Surrey Heath Market Area
Surrey Heath is a district straddling the M3 which is mostly rural with its largest town being Camberley. The half nearest to London is green belt. The district is part of a housing market area with neighbours Hart and Rushmoor which are both unconstrained for development.
The council says it is preparing evidence for a new Local Plan but there has been very little progress or consultation. Fairoaks Garden Village has been proposed for 1500 homes in the green belt in the face of strong resident opposition.
Berkshire Market Area
Bracknell Forst is on the Western side of the London green belt at one of its thinnest points. In consequence much of its rural area is unconstrained even around the main town of Bracknell. Much of its open non-green belt land remains covered with ancient woodlands which affords some protection from development.
The council is working with a site allocations plan from 2013 and a core strategy from 2008. A new Local Plan is in preparation but the draft Local Plan for consultation is behind schedule with adoption anticipated for 2019. The largest area of green belt that is threatened is Jealotts Hill where some employment use provides an excuse for development of 1200 homes.
Borough of Wokingham
Wokingham is a borough on the Western edge of London's green belt just to the East of Reading, It includes some large urban areas such as the town of Wokingham but also has rural landscape. Only about 25% of its area is designated as green belt so it is mostly unconstrained for development.
Wokingham council has begun the process of gathering evidence and considering options for a revised 20-year Local Plan. The Borough's assessed need for housing has been put at around 17,000 homes. A number of options have been looked at. A garden village of 16,000 homes at Grazeley has been proposed as one solution to meeting the boroughs requirements. This would divert development outside the green belt. However, this idea is unpopular because a proposal to develop the site was previously fought off in the 1990s.
The council does not have a Local Plan compliant with the NPPF, yet it has not progressed very far with preparations.
Royal Borough of Windsor and Maidenhead
The Royal Borough of Windsor and Maidenhead lies to the West of London outside the M25 and along the route of the M4. Apart from its two nominal towns it is mostly rural and designated as green belt.
The councils 20-year Local Plan has now been published for pre-submission consultation in 2017. The housing target of 14,240 homes matches the assessed need. Most of the development will be on 26 green belt sites focused mainly around Maidenhead. These add up to 262hectares of green belt out of the total 305 hectares of land that will be developed. There has been string opposition to the loss from residents and some councillors.
The council has nevertheless been criticised by neighbouring councils such as Slough for not taking on some of their unmet housing need.
Borough of Slough
The borough of Slough is a town near the junction of the M4 and M25 with a large industrial area at its centre. It lies close to Windsor, Maidenhead and Heathrow Airport. About a quarter of its area is designated as green belt.
The adopted Slough local plan is out of date and progress on a replacement is at a very preliminary stage. An issues and options consultation was held at the beginning of 2017. The town has a need for 20,000 homes until 2035, but it can only accommodate about 60% of that number and has asked its neighbours, South Bucks and Windsor and Maidenhead to help meet the rest of it's need. In October 2017 Slough council asked South Bucks to build an urban extension of 10,000 onto the North of Slough to help meet its need. Although South Bucks is planning to build next to Slough it does not concede any additional numbers.
The area of green belt between Slough and Heathrow is well protected, yet it will be under pressure if the airport is expanded.
Buckinghamshire Market Area
South Bucks District
South Bucks is a mainly rural area of South Buckinghamshire mostly between the M4 and M40, and outside the M25. 87% of its area declared as green belt and about a third is also in the Colne Valley Regional Park. The remainder consists of small towns and villages of which the largest are Beaconsfield, Gerrards Cross and Burnham. The much larger town of Slough has been surgically cut from the South of the district to form its own unitary authority. Other large urban areas are just outside its borders including Maidenhead, Windsor and High Wycombe, with the urban areas of West London meeting its Eastern border.
From the point of view of an outsider it might seem natural for South Bucks to work with Slough to help meet some of the need which Slough is unlikely to be able to accommodate, but that would require more loss of green belt. Instead South Bucks has teamed up with Chiltern District to form a joint plan and the two councils have criticised Slough for not aiming to meet its needs within its own borders. Housing delivery in the District has been very low even compared to its own fairly light assessed needs.
While avoiding demands to meet the needs of their neighbours, South Bucks and Chiltern are still looking at options to release green belt for a development target of 15,100 homes in a 20-year plan which would fully meet their own assessed needs. 15 green belt sites have been identified for development across Chiltern and South Bucks, amounting to 1.4% of their green belt.
Chiltern District is mostly rural with the small towns of Amersham and Chesham. All of its countryside is designated as green belt but in addition most of it is within the Chiltern Hills AONB which should afford additional protection
The council has agreed to form a joint 20-year Local Plan with South Bucks which is also largely rural green belt, but not AONB. Together they have agreed to meet their own needs of 15,100 homes with some release of green belt around the towns and outside the AONB.
Buckinghamshire County Council objected to green belt release planned for Chiltern and South Bucks, saying that the development should be met by Aylesbury Vale instead, which is mostly not green belt.
Wycombe lies around the Western extremity of the Metropolitan green belt. It is mainly rural with its only large town being High Wycombe. About 50% is green belt but most of it is also constrained for development as the conservation area of the Chiltern Hills AONB. There is an unconstrained rural area in the North covering about 10% of the district. High levels of housing development within the Chiltern Hills would be very damaging to the landscape.
The council consulted on its 20-year local plan in 2016. Housing need was put at 15,100 homes but because of the development constraints it will only be able to meet two thirds of its need within its own boundary and has stated that it will work with Aylesbury Vale District Council to meet the rest.
Green belt land is being lost at sites around High Wycombe
Vale of Aylesbury District
Aylesbury Vale is a large mainly rural district to the North West of London in Buckinghamshire between the M40 and the M1. About 6% of it in the South is green belt and AONB, but the rest is unconstrained. The largest town is Aylesbury.
The council have agreed to set a target of 27,000 homes in their 20-year plan. This is considerably more than their own assessed need of about 20,000 and will help meet the housing needs of Wycombe and Chiltern districts which are constrained by green belt and AONB. It is slightly less than their calculated Local Housing Need which is set high because of a high past building rate.
About 16,000 of the homes will be built around Aylesbury which is to be redesignated as one of three garden towns given backing by the government in January 2017.
West London Market Area
London Borough of Hounslow
Hounslow is a borough in the West of London stretching out North of the Thames towards Heathrow. About a fifth of its area is green belt.
In 2015 the council adopted a 15-year Local Plan with a target of 12,330 homes or 822 per year. This is well below the 1,350 dwellings per year that the plan accepts as their unconstrained need, but greater than the 593 minimum specified in the London Plan. Recent housing delivery has however been lower despite much higher rates historically.
The Local Plan was examined by planning inspector Robert Mellor who accepted it on condition that a partial review focusing on the Great West Corridor and the West of the Borough would follow. This review has now started with aspirations to adopt in 2019. An initial consultation on the review started in October 2017.
There are plans to extract gravel from a 44 hectare green belt site of Rectory Farm to form a subterranean development
London Borough of Ealing
Ealing is a predominantly built-up area in the West of London. It has a small area of green belt.
A Local Plan was adopted in 2012. Recent housing delivery has not met its assessed needs in the London Plan but no revision is underway. In 2014 20 hectares of green belt was released for development. In 2017 there was a campaign to save the site at Warren Farm.
Ealing includes a large part of the Old Oak and Park Royal regeneration development said to be the largest in the UK. It is expected to bring 25,000 new homes and 65,000 new jobs in Ealing, Brent, Hammersmith and Fulham.
London Borough of Hillingdon
Hillingdon is the most Western London Borough and is notable for Heathrow airport in its Southern corner. In the North it is less densely populated with about 40% of the borough being green belt.
The minimum housing target for Hillingdon in the London Plan is 560 homes per year. This is a very low number given the size and population of the London Borough and this is due to the London Plans focus on development in East London. Part 1 of a Local Plan was adopted in 2012 which was already about 14% short of the assessed needs at the time. Part 2 is due for adoption soon. The council have acknowledged a significant increase in assessed need for housing and is slowly preparing a revision for part 1 due for adoption in 2020.
The council were criticised in the press for building 40% of new homes on the green belt in 2014 and 2015.
London Borough of Harrow
The name of Harrow invokes images of affluence. This may be an accurate picture of life near the school of Harrow Hill, but other areas of the borough are less well off. It is situated in North West London well inside the M25. About a fifth of its area is green belt.
Harrow is another council which was astute enough to bring in a revised Local Plan in 2012 to be compliant with revised national policy before assessed needs for housing rose dramatically. They have made no moves towards reviewing the plan. There is no revised SHMA or even a schedule for the next Local Plan. The council acknowledges that there is a high assessed need for housing of at least 1,200 dwellings per year but their stated position is that this cannot be accommodated in Harrow and that the London Plan caters for their unmet need in East London. As detailed under those London Boroughs delivery targets in East London are likely to be unrealistic in the current economic and political climate, but that is not Harrow's problem. To be fair housing delivery in Harrow has been relatively high in recent years but there has been resistance to further plans for high rise developments as favoured by the London Mayor.
Luton and Central Bedfordshire Market Area
Central Bedfordshire is a mostly rural district on the Northern edge of the London green belt. About 60% of its area is unconstrained. Its green belt protects the towns of Leighton Buzzard, Houghton Regis and also Luton which is in its own unitary authority bordering the district. Smaller villages and towns contribute to a high total population.
The neighbouring town of Luton has asked Central Bedfordshire to take 285 homes per year from its unmet need. The Local Plan aims to meet all of the district's own need plus 120 extra homes per year.
A public consultation on the council's draft local plan is now in progress. The pre-submission consultation is expected next year with adoption in 2019.
Recent housing delivery has been exceptionally high with much of it in the green belt. Campaigners in central Bedfordshire claim that 677 hectares of green belt around Leighton Buzzard and Houghton Regis have been lost to development in recent years, without it being released from the green belt. A further 615 hectares is at rick in the draft Local Plan. This level of development suggests that green belt legislation is effectively being totally ignored by the council and the government is taking no action to protect it.
The CPRE has warned that under the draft local plan housing targets could go as high as 42,000 to 54,000 over 20 years, the second highest in the country after tower hamlets. The government's proposed change to the method of calulating assessed needs confirmed these fears. Under the new system Central Bedfordshire would be punished for its recent high rate of housing delivery which pushes their LHN up to 2,553 dpa. In October 2017 the council took a decision to speed up its preparations in a bid to submit its plan before the changes could come into effect.
Borough of Luton
The borough of Luton is an almost entirely urban authority with small pockets of green belt. The M1 and a mainline railway pass through the town. Luton airport is within its boundaries.
In its 20-year local plan the council stated that it can only deliver 6,700 homes out of its assessed need of 17,800.
The Luton Local Plan was submitted for examination in April 2016. The inspector was Jeremy Youle. A modification consultation was completed in May 2017. In August 2017 the plan was declared sound subject to modifications. The remaining unmet housing need was 9,300 homes. The inspector asked for a modification to clarify how that might be met.
In November 2017 the plan was formally adopted by the council with plans for an early review of numbers to be undertaken.
South West Hertfordshire Market Area
Borough of Dacorum
Dacorum is a borough in the North West metropolitan green belt. It includes the new town of Hemel Hempstead and smaller towns of Birkhamstead and Tring. All of its rural areas are constrained either as green belt or as Area of Outstanding Natural Beauty. In fact about half of the borough is in the Chilterns Hills AONB
Docorum approved a Local Plan in 2013 but is now required to review and update it. The council has indicated that they will try to find space for 17,000 homes to meet their assessed need. Their eastern neighbour St Albans plans to build 2500 homes onto Hemel Hempstead in their area and Dacorum has contested that half of that housing should go towards meeting their need.
Three Rivers District
Three Rivers includes areas of countryside and low density urban areas around Watford (which is in its own borough). The M25 passes through the district. All of its urban areas are designated as green belt. Typical house prices range from £1 million to £2.5 million.
The council approved a local plan in 2011 which would meet 90% of its 5000 home assessed need at the time. Now it must update the plan to meet its new assessed need. The district may also be asked to pick up some unmet need from Watford. They are in the earliest stages of this process with a goal to adopt in 2020.
In 2014 the council quietly voted to remove 110 hectares of land from the green belt in areas where development was intended. Residents did not seem to have been properly consulted as they were surprised later on when developments came forward.
Three Rivers appears to have gotten away with submitting a low target Local Plan early on. An updated assessment would more than double the housing requirement. The government seems to simply accept their claim that it is compliant, so they are under no pressure to produce a new plan very quickly.
Borough of Watford
Watford borough is a mostly urban authority but with 20% area that is designated as green belt. It lies between the districts of Three River and Hertsmere to the West of the M1 and inside the M25 to the North West of London. The London underground metropolitan line runs out to Watford junction. There are also mainline trains running into the city
The council has a 25-year local plan that runs from 2006 to 2031 which is now being updated with a part 2 specifying housing development locations. The town does not have enough undeveloped space to meet its assessed need for housing so of its neighbours will be expected to help through duty to cooperate. The nearest are however green belt constrained.
Watford has submitted a plan which aims to provide 260 homes each year over the plan period making 6,500 in total. This is 43% of its OAN, however, since the first ten years of its plan has already passed it is not clear how much unmet need this actually implies.
In 2017 part 2 of the plan was ready for submission to the planning inspectorate when Councillors decided that the housing target was too low compared with the revised assessed need. In September the plan was brought back for review.
Borough of Hertsmere
Hertsmere lies mainly within the northern section of the M25. It has a considerable amount of rural space for an inner borough but also includes the isolated towns of Borehamwood, Radlett, Bushey and Potters bar.
A Core Startegy was adopted in 2013 but with a low housing target 24% below its assessed need. Assessed needs have since risen and this now needs to be reviewed. A new Local plan preparation is at an early stage with adoption expected in 2019, but it is indicated that it will be a 15-year plan with the assessed need of 9000 homes being met.
In November 2016 an area of 60 hectares was released from the Hertsmere green belt with the adoption of the council's Site Allocations and Development Management Policies Plan
In September 2017 a Local Plan options report was put to public consultation. The estimated need of 9000 new homes over 15 years is likely to be controversial because on the one hand it appears to ignore the latest housing projections which would be likely to increase the number, and on the other it ignores the proposed new system for calculating Local Housing Need which could reduce the target by nearly 40% in Hertsemre's case. A garden village of 4000 homes is one option for consideration.
North Hertfordshire and Stevenage Market Area
North Hertfordshire District
North Hertfordshire is a large district on the outer northern edge of the London gren belt. It includes Letchworth Garden City, Hitchin and Royston which are surrounded by countryside of which about half is designated as green belt. In addition it has borders with the individual urban authorities of Luton and Stevenage. The northern corner is in the Chiltern Hills AONB.
Apart from Royston its urban areas are surrounded by green belt to protect them from sprawl. North Hertfordshire could have respected this constraint by building a new settlement in its areas that are not protected or by extending Royston, but instead the council has chosen to ignore the purposes of the green belt and extend each of these towns.
The 20-year plan proposes 14,000 new homes for its own assessed needs plus an additional 2,000 homes to help meet the needs of neighbouring Luton which does not have enough undeveloped land of its own. Nearly 10,000 of these homes will be built on land released from the green belt.
The plan was submitted for examination in June 2017. Simon Berkeley has been assigned as planning inspector and the process of examination is expected to begin soon.
Borough of Stevenage
Stevenage Borough consists of Stevenage New Town with about 10% area in green belt. Its housing was assessed jointly with North Hertfordshire to provide more scope for accommodating its full need. The two councils had previously been in dispute over cooperation but now seem to have reached a truce based on their combined Market Area.
The 20-year local plan proposed a target of 7,600 homes including 2,250 in a small areas of green belt to the North and South-East of the town. These was strongly opposed by residents
The plan was examined in hearings between January and March 2017. This was followed by some modifications and a further consultation. Conclusions and adoption are expected soon.
The town has faced pressure from unwelcome developments nearby in the East Hertfordhsire local plan.
St Albans Market Area
St. Albans City and District
St Albans District contains the urban areas of St Albans city and Harpenden. In addition it is near to district towns such as Watford, Luton and Stevenage which have very little countryside to help meet their assessed needs for development. Hemel Hempstead is just across its boundary and other large towns are not far away. The M25 passes through its southern corner. All its countryside is desgnated as green belt.
The story of St Alban's attempts to form a 20-year Local Plan for the period 2011-2031 is a long one. The district has been under pressure from its neighbours to take some of their unmet need for housing since the NPPF was drawn up. Early on residents helped form a strong legal case for the use of the green belt constraint to lower housing targets. This should have left the council well informed and in a position to draw up a sound plan. Instead they have submitted a document that simply ignores updated estimates of their OAN which should be about 710 homes per year. They appear to have simply based their plan on an old figure of 436 dpa without justification or any legal defence against the additional requests from neighbouring councils. Furthermore they have released green belt near Hemel Hempstead in neigbouring Dacorum, placing strain on its infrastructure without allowing any of it to count towards Docorum'a needs.
Their plan has been separated into a Strategic Local Plan (SLP) giving its core strategy, and a Detailed Local Plan (DLP) with the site allocations. The SLP was submitted to the Secretary of State in August 2016. Planning inspector David Hogger was appointed to conduct the examination. Taking into account objections from neighbours, Hogger recommended that the plan should be withdrawn over failure on the Duty to Cooperate. St Alban's ordered a Judicial Review in the High Court to try to quash the decision, but in July 2017 this bid failed.
St Albans council failed to produce a joint Market Area with any neighbours. They had their own Market Area with a low assessment based on out-of-date projections and methods. This was the key point made by the judge in their judicial review. Their neighbours produced a better assessment to prove them wrong. Ironically some of their neighbours have gotten away with producing local plans with low targets simply by submitting them very early. Now they are being slow to review their own figures on the grounds that they have a legal plan in place. If St Albans had listened to their residents, produced robust evidence and developed a cogent legal case, then the outcome could have been very different.
Welwyn Hatfield Market Area
Borough of Welwyn Hatfield
Welwyn Hatfield is a largely rural borough North of the M25 encompassing the isolated towns of Welwyn Garden City and Hatfield. All of its undeveloped countryside is designated as green belt providing a constraint to development.
In 2016 The council published a 20-year Local Plan with a target for housing of 12,000 homes. At that time its assessed need was 13,000 but in May 2017 an update to the Market Area increased this to 16,000. This was after final consultation and just prior to submission to the planning inspectorate, yet the inspector has complained in initial assessments not only that it did not meet the old figure, but also that it falls far short of the revised number.
In the pre-submission consultation 86% of residents considered it unsound, mostly because of over-development. The inspector dismissed this by saying that they expressed different views. The impact of growth on infrastructure from outside the borough was also a source of contention. In particular plans in the neighbouring borough of St Albans to the East include development near to Welwyn Garden City. Relatively small amounts of green belt have been allocated for development but this still raised objections.
Before examination began the inspector issued 37 questions on Duty to Cooperate and a further 40 in other areas including eight regarding green belt. In early stages of the hearing the future of the plan hung in the balance because of the attack from St Albans over the principle of Duty to Cooperate. This was seen by some as revenge for St Albans losing its own plan over Duty to Cooperate when it was atacked by its neighbours including Welwyn Hatfield.
Broxbourne Market Area
Borough of Broxbourne
Broxbourne lies to the North of London along the A10 outside the M25. Its urban area in a continuous finger of housing connected to London via Enfield. It consists of Cheshunt, Broxbourne and Hoddesdon. Two third of its area on the East is rural and all designated as green belt. There is also green belt in the West but this is part of the Lee Valley Park and is not suitable for development.
The A10 dual carriageway can become heavily congested and its rail link into Liverpool Street also has a stretched capacity.
The council has proposed the creation of a Garden Village in the green belt at Brookfield as a major development. Originally the draft Local Plan had a housing target of 6000 but this was increased to 7000 to meet its assessed needs. However, the assessed need has not yet been updated with the latest growth projections and it is expected that the target may increase. Pre-submission consultation is currently scheduled for October 2017.
Barnet Market Area
London Borough of Barnet
The London Borough of Barnet covers as urban area comprising Edgware and Barnet itself with the remaining 25% of its area designated as green belt. The borough has the largest population in the GLA and also one of the highest assessed needs for new housing.
The council adopted a core strategy in 2012 at the time the London Plan set a minimum target of 10,000 homes for 2001 to 2016 but this later rose to 23,489 for the period 2015 to 2025 alone. A Housing strategy for the decade was published in 2015. They intend to deliver a large number of new homes through regeneration in Brent Cross, Cricklewood, Colindale and Mill Hill East. Given the huge number of homes they are expected to provide it is hard to believe that these are realistic plans for achieving it.
They are now working on a new Local Plan which should be submitted in 2018 and adopted in 2019, but they do not appear to be on schedule.
Enfield Market Area
London Borough of Enfield
Enfield is a North London Borough just inside the M25. About two thirds is the urban area of Enfield, Southgate and Ponders End. The remainder is green belt.
The council is preparing a new 15-year Local Plan for the period 2017 to 2032, but they have done little more than carry out an early stage consultation is 2016. There current core strategy dates from 2010 so they cannot be considered compliant with current national policy.
West Essex and East Hertfordshire Market Area
East Hertfordshire District
East Hertfordshire is a large, mainly rural district including the towns of Hertford, Ware and Bishop Stortford as well as many smaller villages. It also has the large town of Harlow near its border. The A10 dual carriageway runs through its middle. There are rail links to its towns but they do not service well its main rural area in the North.
About half of its area is unconstrained countryside that by planning rules is fair game for development. Another third is designated as green belt. The council submitted a 22-year plan with a housing target of 16,390 based on meeting an assesed need of 745 dpa. This was in accordance with its Market Area produced in September 2015 based on 2012 growth projections.
Development proposals included a 10,000 home New Town at Gilston Park just North of Harlow. Harlow and Gilston is one of three proposed garden towns given backing by the government in January 2017. Other new settlements were placed close to its border near Stevenage and Welwyn Garden City which are in other districts. These would be on green belt that should protect these towns from sprawl. Objectors from these neighbouring councils felt that it would be better to build a larger garden city outside the green belt and isolated from existing towns.
A pre-submission consultation was held in December 2016 and the examination started in May 2018 with Christine Thorby as the inspector. Her first action was to insist in using 2014 projections and suggested a raised OAN of 886 dpa for a target of 19,300 homes. There were also questions over whether the council had considered unmet need from London. To meet this target the council added in new developments that had not been through consultation.
Harlow is a new town district with mainly urban area and about 20% open space designated as green belt situated between the Lee Valley and the M11. They are currently consulting on options and it is not clear whether or not they will be able to meet their own need. Despite the early stage of plan preparation they expect to hold the pre-submission consultation in early 2018.
It is likely that high density development will be required to set an acceptable target. The towns predicament is not helped by neighbouring districts of East Hertfordshire and Epping Forest who aim to build additional settlements nearby.
Epping Forest District
Epping Forest is a large mainly rural district crossed by the M11 and M25. The town of Loughton stretches out from London within the M25 with the small isolated towns of Epping and Waltham Abbey just outside the orbital. The rest of the district is sparsely populated in smaller towns and villages. All of its rural area is designated as green belt.
The council consulted on its draft local plan at the end of 2016 with proposals to meets its full assessed need which at that time was 11,400 homes. This included developments mainly around Waltham Abbey, Epping and North Weald. There were strong objections to these plans because of the large loss of green belt.
The council is now preparing for pre-submission consultation, however it is likely to be told to take into account an 11% increase in its OAN from a recent Market Area update. There is also the prospect of requests from London boroughs for help with meeting their unmet need. In particular Redbridge on its southern border has an unmet need of over 10,000 homes and during its recent examination the planning inspector suggested they should look to Epping Forest for help.
Uttelsford is a large rural district including small towns such as Saffron Walden, Clavering, Stansted, Takeley, Thaxted, great Dunmow and Stebbing. The area is crossed by the M11, the A120 and it includes Stansted Airport. Only 5% of its extensive area is green belt making it a potential target for green belt constrained councils who want to pass on unmet need.
Earlier attempts at a local plan ran into trouble at examination in 2014. A plan for a new settlement of 2,100 was criticised over lack of road infrastucture and for being too small. It was withdrawn.
Pre-submission consultations were held in July 2017. A cornerstone of the plan is a triad of three new garden towns: A 5000 home new town between Safron Waldon and Cambridge which is to be unimaginatively called the North Uttlesford Garden Village. Another new community of 3,500 homes is planned near Little Easton and there is one more west of Braintree. Residents fear that these could each grow to over 10,000 homes.
An update to the Market Area that will probably need to taken into account at the examination increased the assessed need by 18%. Basildon has also hinted that it may ask Uttlesford to help with some of its unmet need.
North Essex Market Area
Borough of Chelmsford
Chelmsford Borough consists of its main large central city of Chelmsford surrounded by countryside. As the administrative centre of Essex it has good quality transport links including the A12 trunk road and the A130 both of which are being widened to three lane dual carriageways. There is also a rail link into London.
About half its countryside is green belt with the remainder unconstrained. Chelmsford is working in cooperation with its housing market neighbours Braintree and Colchester on a series of garden communities supported by upgrades to the A12 and A120. 10,000 new homes will also be built around the city. The council is expected to meet its assessed need without releasing land from the green belt. However, it is developing a large brownfield site in the grene belt at Runwell near Wickford that was identified for development in the earlier adopted plan.
The draft local plan consultation was held in March 2017 and met with heavy opposition from residents.
Outer North East London Market Area
London Borough of Waltham Forest
Waltham Forest is an outer London Borough covered mostly by the urban areas of Leyton, Walthamstow and Chingford. The remaining 20% area is green belt.
In 2011 it submitted a 15-year core strategy for 10,320 new homes. This was approved and adopted in 2012. At the time this was in line with growth requirements in the London Plan, but it has become increasingly out-of-date since then. The Outer North East London Market Area of 2016 puts its assessed need at 2,017 homes per year which is more than three times the target it is working to. The council has a very leisurely schedule for preparing an updated plan. Early preparation is underway but completion is not expected before 2020.
In the meantime the council has been involved in Duty to Cooperate negotiations with neighbouring councils. In particular it was one of the councils that rounded heavily on St Albans over their failure to meet assessed housing needs.
London Borough of Newham
Newham is a borough near the centre of London that includes London City Airport and the Olympic Park. Most of the area is dense Victorian terraced housing but there are parks in the North. It has a small area of green belt
The borough hopes to build 35,000 new homes by 2025 and create a 100,000 new jobs. This will be done through regeneration projects in areas such as Canning Town and Custom House where 5000 homes are planned. It is not obvious that the full aspirations are anything like achievable in the timescale. A Detailed Sites and Policies document was examined in 2016. The rest of the Local Plan is due to be submitted in 2018.
London Borough of Redbridge
Redbridge in North East London includes Ilford, Woodford and Barkingside. Although it is densely populated it still keeps some sizeable areas of valuable green belt but no other potential greenfield development sites.
In June 2017 Redbridge completed pre-submission consultations and submitted a Local Plan with a housing target of 1,123 houses per annum, only a little over half its assessed need. The figure is based instead on the minimum requirements of the London Plan which is due to be updated shortly.
The plan has been criticised by residents for it's proposed concentration of high density tower blocks in Ilford, especially as this case shortly after the Grenfell Tower fire. Other campaigners and the Mayor of London critcised the proposed release of some areas of green belt although much more would have been needed to meet the borough's assessed need for housing.
The examination was handed to planning inspector David Smith who had previously dealt with the Castle Point examination. Although Redbridge is also a sub-OAN plan the numbers are much higher in this case, and Smith has conducted the examination very differently. After several weeks of hearings the soundness of the plan has been fully tested with representations from all concerned parties including developers and campaigners.
The inspector did however question the council on its unmet need and asked in particular about its consultation with it's neighbour Epping Forest which has large areas of unspoilt countryside, also designated as green belt. The council had carried out extensive consultation with all its neighbours and other authorities further outside of London.
The plan now has a very uneven housing trajectory which rises sharply to 2295 homes being built in the year 2019/2020. It then slows down gradually to a rate of 563 homes per year by 2030.
Modifcations to the plan have been proposed which must now be subected to 6 weeks of consultation. The inspector will give his final decisions about two months later.
In September 2017 the inspector sided with green belt campaigners and told the council that they must look at ways to meet their need without building on green belt sites at Oakfield and Ford.
London Borough of Barking and Dagenham
Barking and Dagenham is a high density urban area of London but it does also include some pockets of green belt.
New plans announced in early 2017 by the London Mayor propose 36,000 new homes in the borough. This will be mostly in a riverside development that will extend into the Rainham Marshes in Havering. To accompany the new homes there will be only 10,000 new jobs. In other words only one new job is planned for every 3.5 homes. Critics say that the deliverability and sustainability of the project is highly doubtful.
London Borough of Havering
Havering is the Eastern most London Borough consisting of a single urban area amalgamating Romford, Hornchurch, Gallows Corner, Upminster and Cranham. These towns are surrounded by green belt that covers half the area of the borough. The population is well served by roads including the A12, A127 and the M25 although these do suffer from heavy congestion. There are also two mainline rail links with joint tracks for underground and Crossrail.
A 15-year plan for 17,550 homes was prepared in November 2016 which proposed to meet the London Plan minimum target of 1,170 homes per year. In 2015 the council had suggested 47 green belt sites that could be developed but these were not included in the 2016 draft. There was little response from residents to the public consultations. It had been expected that the plan would be submitted for examination in 2017.
However, in February 2017 the council suddenly announced that it would aim to build 30,000 homes by 2035 in order to become more a part of London. This led to a motion to in the council to remove the borough from the GLA but the move was defeated. The higher targets are expected to be part of the emerging update to the London Plan. This will feature less capacity for parking with more of an emphasis on public transport. The new high density developments will focus on Rainham, South Hornchurch and Elm Park
In 2016 permission was given for 300 homes on a former hospital site considered to be brownfield in the green belt.
In August 2017 the Local Plan was put to pre-submission consultation without the larger target taken into account. Nor was there any provision to review the targets in the near future. In fact sites were identified for only 12,190 homes over 15 years against an assessed need of 20,490. Green belt boundaries would not be amended. The council claimed that unmet need would be taken up by other London boroughs. This move will be welcomed by residents who have fought a strong social media campaign to reduce the housing target but the argumenst the council have used are unconvincing given that the London Plan seeks for unmet need to be taken up in East London boroughs including Havering.
Brentwood Market Area
Borough of Brentwood
Brentwood is a mainly rural borough just outside the M25. Its main town of Brentwood lies in the A12 corridor which also includes Mountnessing and Ingatestone. The borough extends South across the A127 where the largest village is West Horndon. The North is largely small rural villages. All of its countryside is in green belt. The A12 is classified as a trunk so it recieves support from highways England. It is therefore a much higher quality dual carriageway than the A127 and is due to be widened to three lanes each way over the next few years. In addition the A12 corridor is due to benefit from Crossrail which should increase capacity of its rail links.
Despite the heavy investment along the A12 where most of Brentwood’s need to new housing is focussed, the council has looked South of the A127 for land to develop. Initially they planned a large development in West Horndon but faced strong resident opposition. When Basildon announced that it wanted to extend its town West at Dunton up to the Brentwood border, Brentwood took the opportunity to consult of a large development of 6000 homes in a garden suburb straddling the two boroughs. When this was opposed by residents in West Basildon, the Basildon side backed off but Brentwood retained its plans in the form of an independent garden village of 2,500 homes. This was later increased to 3,500 homes with 500 more in West Horndon
In 2015 and 2016 Brentwood consulted on a plan with a target of 5,500 homes most of which were concentrated in the developments south of the A127. This was despite the infrastructure investment along the A12 which should have unlocked housing development around the boroughs main urban areas. The plan received broad support from its own residents except near the few areas of green belt to be developed near Brentwood Town, but was strongly opposed in Basildon.
The plan was due for submission to the Secretary of State in early 2017 but the deadline passed without explanation or update to the schedule. It has been speculated that there are concerns over the potential unsoundness of the plan causing them to seek stronger evidence. The figure used for their objectively assessed housing need is now some four years out of date and is likely to increase significantly when revised. There may also be demands from unmet need in nearby London boroughs such as Havering as well as other South Essex boroughs such as Basildon. The outcome of a new call for sites and revised HELAA in 2017 are awaited.
Thames Gateway South Essex Market Area
Borough of Thurrock
The borough of Thurrock lies on either side of the M25 on the North side of the Thames Crossing. It's main urban area joins with London but it also includes the separated towns of Corringham, Stanford-le-Hope, Ockenden, Orsett and Horndon-on-the Hill. Its extensive rural area is all designated as green belt.
The Thurrock borough Local Plan for 2001-2021 earmarked its extensive brownfield sites for priority development. Although significant new housing was built in areas such as Chafford Hundred, other areas such as Purfleet were spurned by developers leading to a severe under-delivery. In 2012 Thurrock Council amended the plan with the release of 51 hectares of green belt. Some smaller areas of green belt development have also been permitted due to very exceptional circumstances.
Since 2014 the council have been preparing a new Local Plan. They carried out a broad consultation under regulation 18 in 2016. The very small number of representations submitted to the consultation may be attributed to the broad nature of the consultation which did not mention any specific sites, but residents may also have been diverted by the Lower Thames Crossing consultation which attracted a lot of attention. Another factor to blame was the council's goal of trying to restrict the consultation to its own residents with narrowly targeted publicity.
A new HELAA and Green Belt Review has been expected for some time to be followed by a second stage consultation. These are overdue mainly because of delays while waiting for the decision on the route of the Lower Thames Crossing which was finally announced early in 2017.
The updated OAN would imply a housing target up to 20,000 for a 20-year plan, but figures as high as 30,000 homes have been mentioned in the press. The excess may be due to earlier under-delivery and also high levels of unmet need from East London which may be partly imposed on Thurrock. The Lower Thames Crossing has also been advertised with the goal of unlocking housing development in the area even though neither is popular with local residents. This raises the prospect of an imminent consultation on strategy proposing large scale development of the boroughs green belt on specific sites which would come as a great shock to residents of the Thurrock and neighbouring Basildon. Campaigners are now waiting to see what approach the council might take in mitigation of the political impact in the aftermath of the Lower Thames Crossing debacle.
In September 2017 the council revealed that they had a housing target of 32,000 over a 20-year period with 26,000 to be built on green belt. This is well above even the highest figure proposed as their assessed need with the excess demand assumed to come from unmet needs in other boroughs, and especialy from within London.
Borough of Basildon
Basildon Borough consists of three main urban areas (Billericay, Wickford and Basildon Town), with other smaller communities. The surrounding rural areas are all designated as metropolitan green belt. In early 2016 Basildon Council held a regulation 18 consultation on a Draft Local Plan with a housing target of 15,200 meeting the OAN of the time. Specific sites were listed for release from the green belt to support about 9000 of the homes. A further consultation was held later in 2016 to consider some new and alternative sites brought forward by developers. The authority could be put under further pressure from neighbouring councils and London Boroughs to accommodate some of their needs. Residents have vigorously opposed release and development of the green belt in the consultations
Infrastructure in the area is also a significant constraint, particularly the A127 dual carriageway which has been underfunded since it was detrunked in 1997, passing responsibility for the road from the cenbtral highways authority to Essex County Council. In addition to new housing in Basildon itself, the road which already has levels of traffic that would normally justfy a three lane motorway, will be put under pressure from massive housing developments in Brentwood, Rochford, Castle Point. A particular concern for residents is the proposed Dunton Hills Garden Village in the neighbouring borough of Brentwood which would include 3,500 new homes next to the A127 and next to the Basildon border.
In May 2017 an update to the Thames Gateway Market Area increased the OAN to impose a twenty-year housing need of around 20,000 homes. The council signed a MoU with its Market Area neighbours (Thurrock, Castle Point, Rochford and Southend) all of which are also green belt constrained. The intent is to discuss hiousing need across the area.
In 2017 following a political change of control on Basildon Council there was a new pledge to look again at green belt and infrastructure constraints to see if a lower housing target could be justified on grounds of sustainability. The regulation 19 consultation and submission to the Secretary of State is now scheduled for Q2 2018 with adoption in Q2 2019.
Castle Point District
Castle Point consists of the loosely disconnected island of Canvey and the main-land towns and villages of Hadleigh, South Benfleet and Thundersley. Its urban areas merge with those of Southend to the East. All of the surrounding urban area is designated as Metropolitan green belt.
In March 2016 the council decided in response to pressure from residents to approve submission of a Local Plan with a housing target of just 100 houses per year. This was justified by constraints from green belt, infrastructure and flood risk. Areas of green belt release was ostensibly limited to those parts subject to previous development, but in reality they also included some green fields. Nevertheless the extent of green belt loss was considerably less than the original plan which would have met the council's assessed needs, but which was strongly opposed by residents.
In 2014 the council had consulted with the housing minister of the time on the legal case for using the green belt constraint. The minister was recorded saying that the council did not have to release green belt to meet its needs if it did not wish to. This was confirmed by subsequent clarification in the government's planning practice guidance and repeated statements by the Secretary of State Eric Pickles.
When public examination began in late 2016 the planning inspector David Smith decided to begin with a day of hearings dedicated to compliance with the duty to cooperate. Officers of the other councils in the housing market area and Essex County Council were called to speak. The public were allowed to attend but not participate. Castle Point council was criticised by its neighbours for not meeting its need on housing and traveller pitches as well as an alleged failure to discuss a link road between Canvey and Thurrock. Council officers appeared to answer questions fully, showing that they had indeed held meetings on these issues, while its neighbours had failed to raise concerns before the regulation 19 consultation. Nevertheless, the inspector decided subsequently that the condition of duty to cooperate had not been met. Castle Point council decided not to challenge the decision and withdrew its plan.
As a result of the short hearing the soundness of using the green belt and other constraints was never tested, much to the disappointment of other councils which had hoped it would set a precedent they could follow
Castle Point council have joined discussions with their neighbours on development need. Preparation of the Local Plan has returned to square one with a new round of consultations planned. Submission and adoption of a revised plan is scheduled for 2019.
Rochford district is largely rural area interspersed with the isolated towns of Rayleigh, Hullbridge, Hockley and Rochford. All rural area is green belt constrained with the exception of Foulness Island in the East which is constrained by flood risk.
In 2013 Rochford released 190 hectares of green belt land around Rayliegh, Hullbridge and Rochford Town some of which has already been built out. Residents launched a judicial review after approval of the release but failed at considerable financial cost to individual residents. Public limits on financial liability for judicial reviews were subsequently doubled by the government so it is recommended that campaign groups take advantage of the cost-free public consultation and examination processes rather than expensive judicial reviews which often have little chance of success no matter how good the moral case may seem.
The district were required to carry out an early review of future housing need and consequently are now working towards a new Local Plan for approval in 2020. They are also involved in cooperative discussions with their housing market neighbours on meeting need. It is thought that they may be affected by unmet need from neighbouring Southend which has very little urban or brownfield potential to fill its high assessed need.
Borough of Southend-on-Sea
Southend is a densely populated urban area which also incorporates Westcliff-on--Sea and Shoeburyness. It joins the urban areas of Castle Point to its West while the remaining land-border with Rochford to the North is more rural.
With a large assessed need of 1072 dwellings per year and only 610 hectares of rural land which is all classified as green belt, Southend has very limited scope for further development. Much of its unmet need is therefore likely to be pushed on to its market area neighbours, especially Rochford. It is currently participating in joint meetings on development.
Like Rochford, Southend is in the early stages of updating its plan with a goal of adoption around 2020. There was a call for sites and a town centre consultation in 2017. Nevertheless it is likely to have a much earlier impact on development through its requirements for cooperation from its neighbours.