Exploring the implications of the Broad Locations of Growth (BLGs) on green belt in the draft London Plan.
The draft replacement London Plan, published this week, for the first time in its quarter-century history directs a handful of the capital’s suburban boroughs to find space on their green belt for housing.
This marks a significant shift in policy from the previous version, adopted in 2021, which made it clear that green belt should be protected from development. This change does, however, bring the draft Plan into alignment with what’s expected in the new National Planning Policy Framework (NPPF), which will now not arrive until after the summer recess—probably in September.
This is what the draft Plan has to say about the release of green belt land for housing:
Green Belt sustainable locations
Major proposals should only be regarded as being within a sustainable location for the development type proposed where at least one of the following sustainable location tests are met, as relevant:
1. The site is identified as such within an adopted Local Plan, site allocation and/or masterplan that is consistent with this Plan.
2. The site is associated with a government-designated New Town, as described by National Policy Statement.
3. Where 1 and 2 are not met:
a) For residential-led proposals, the vast majority of new homes would be situated within a 1200m walking distance (or 15 minutes) of one of the rail stations shown on Figure 6.4, or within 400m of a bus route that meets the criteria in Box PV7C.
Draft London Plan, Greater London Authority, July 2026
The document identifies eight boroughs where green belt release is expected to deliver a total of 56,100 homes, and it even goes as far as setting out the anticipated densities for those zones immediately around accessible stations (or “Broad Locations of Growth” – BLGs), which are significantly higher than the densities described within the NPPF.
According to the accompanying impact assessment, each BLG has been assessed as being able to deliver a minimum of 3,000 homes, although the document is not specific about where they should go.
Here’s a full list of the BLGs, and the stations that fall within them, and around which these new homes are expected to be built:
| BLG No. | BLG Name | Stations |
|---|---|---|
| 49 | Croydon–New Addington | South Croydon, East Croydon, Lebanon Road, Sandilands, Lloyd Park, Coombe Lane, Gravel Hill, Addington Village, Fieldway, King Henry’s Drive, New Addington, Addiscombe |
| 50 | Eastern Hainault Loop | Barkingside, Fairlop, Hainault, Newbury Park |
| 51 | East of Ickenham | Hillingdon, Ickenham, Northolt, Ruislip Gardens, South Ruislip, Uxbridge |
| 52 | Mill Hill & Barnet | Mill Hill Broadway, Finchley Central, High Barnet, Mill Hill East, Totteridge & Whetstone, West Finchley, Woodside Park |
| 53 | Northwood | Hatch End, Headstone Lane, Northwood, Northwood Hills, Pinner |
| 54 | Crews Hill & Chase Park | Crews Hill, Hadley Wood, Gordon Hill, Cockfosters, Oakwood |
| 55 | Upminster | Upminster, Upminster Bridge |
| 56 | Harold Park | Gidea Park, Harold Wood |
| 57 | West Ruislip | Ruislip, West Ruislip |
| 58 | Dagenham | Dagenham Dock, Dagenham East, Dagenham Heathway, Elm Park, Hornchurch |
And the map from the accompanying Integrated Impact Assessment document (not in the Plan itself) which locates these around the capital:
Extract from the draft London Plan showing the approximate location of the ten-year Broad Locations of Growth
Sensibly, the proposed densities taper from the station centre, from 160 dwellings per hectare (dph) within 480m, to 90dph between 800m and 1,200m away. These are really high: the NPPF calls for densities of between 40-50dph within 800m of a well-connected station; a quarter of the London Plan proposals.
The draft Plan also provides typical building heights within these zones, too:
| Walking Distance | Average Net Density | Typical Building Heights |
|---|---|---|
| Less than 480m | 160 | 5–6 |
| 480–800m | 130 | 4–5 |
| 800–1,200m | 90 | 3–4 |
| More than 1,200m, where the site is within 400m of a stop on a bus corridor meeting the requirements of Box PV7C | 90 | 3–4 |
Set out within the document is a list of the accessible stations around which these green belt homes are expected to be built, across the eight boroughs in which they’re located.
I’ve mapped each one, below.
The east London borough of Barking & Dagenham has three principal areas of green belt: along its eastern border with Romford, and in the north where a spear of green belt extends into London between Redbridge and Havering.
Barking & Dagenham is the only borough in the list that is entirely landlocked by other London boroughs, and as a result its green belt is pretty anachronistic, clearly failing to meet the test of the NPPF—and I would suggest, by that measure, all of it counts as grey belt.
The areas with the development potential are clustered around Dagenham East, including one of my favourite bits of London’s green belt: the May & Baker Way Car Park. Let the beauty of this green and pleasant land wash over you.
Forming part of Barking & Dagenham's metropolitan green belt, this huge car park serves the May & Baker Community Football Club.
According to the draft London Plan, LBBD has to find space for just 1,140 homes on its greenfield land. A chunk of this might be on the Crowlands Heath golf course, a site which straddles the border with Havering (see below) and which, annoyingly for the council, it owns the freehold of despite two-thirds of it being on the wrong side of its eastern boundary.
In total, 178 hectares of the borough’s green belt lies within 1,200m of Dagenham East. House prices are a big challenge in this part of London, though.
In the new Plan, Barnet now has the highest housing target of all of the London boroughs. It will need to find space for 32,730 new homes, 7,000 of which are expected to come from green belt release.
Fortunately, Barnet has a lot of green belt, with 553ha of this within 1,200m of the BLG stations; of which there are seven. Six of these are on the two sub-branches of the Northern Line, plus Mill Hill Broadway in the west, on Thameslink, which has recently reverted to public ownership.
The BLG green belt zones include several golf courses (shown hatched, below), plus the proposed location for the ill-fated Barnet Football Club which was refused on the grounds (among other things) of being in green belt. Perhaps they might want another punt?
The 1,200m zones within Barnet also include those around the Enfield stations Hadley Wood and Cockfosters, but given that almost all of this sits across Monken Hadley Common, the only bits of developable land in the northeast corner of the borough would appear to be the playing fields alongside the Dollis Brook.
On that basis, the most likely location for the delivery of new homes on Barnet’s green belt will be around Mill Hill and on the two golf courses straddling Mill Hill East tube stations, which I can see proving, er, unpopular. Seven thousand homes is a lot, even at the very high densities proposed: it’s going to be interesting to see where these come forward.
As Barnet is to the north, Croydon is to the south: the first and second most populous boroughs in London, both on the outer edges of the capital, with substantial green belt and a lot of open space set aside for golf.
The peninsula of green belt extending into southeast London consists mainly of golf courses (there are a lot of them) and the proposed areas for growth sit along the tram route that leads from East Croydon Station to New Addington itself. 5,600 of the boroughs 21,544 homes are expected to be delivered here.
Croydon’s BLG is named after New Addington, the new town extension which lies in the southeastern corner of the borough. My friend, the writer John Grindrod, wrote a delightful book about growing up here, on the edge of the fringes of London, combined with a detailed history of the green belt itself. It’s worth a read.
The location for one of the two new towns in London (or not?) it seems pretty obvious that Crews Hill is ripe for development. It’s by far the largest area of contiguous green belt around any station in London, and is basically in the middle of nowhere, serving London’s largest cluster of garden centres and a council-owned golf course.
There are bigger plans afoot for the Crews Hill / Chase Farm BLG, where Enfield will be expected to deliver 7,000 homes on green belt (less than the draft Local Plan suggests, aiming for 21,000).
Development further west is unlikely, as the areas around Oakwood and Cockfosters stations—the final two on the Piccadilly Line—are largely occupied by Trent Park and Monkey Hadley Common, although there are some pockets of potentially developable land in amongst the protected open space. Plus a couple of golf courses, of course.
Trent Park golf course is ripe for development, and the sites to the east of Oakwood are already optioned up, but the developers who control these areas will certainly be aiming for densities far below that proposed by the Mayor.
Enfield is either going to be able to clear its green belt housing hurdle easily, or miss by a country mile.
Harrow has a weird bit of green belt that’s entirely cut off from the rest of the borough’s peripheral areas. This is Pinner Park Farm, a 93 hectare dairy farm that’s within 15 minutes’ walk of three of the London Plan BLG stations: Pinner on the Metropolitan Line, and Hatch End and Headstone Lane on the Lioness Line.
I don’t know about you, but raising cattle in such a well-connected location seems like a rather inefficient use of land, and whilst I’m sure that the cows love being only half an hour from the shopping and nightlife of the West End, I can’t help but think forty-off thousand people might benefit a little more.
According to the BLG densities, Harrow could build 10,000 homes here—an entire new town!—and half of its entire London Plan target on the area occupied by the farm alone.
Just over a quarter of Harrow’s housing target of 12,010 is expected to come from green belt release. Some of it will, presumably, will have to be here. And there’s almost certainly space for a lot more besides.
There’s one thing for sure: there won’t be many new homes built on this bit of green belt close to Northwood Hills station that sits across the borough boundary with Hillingdon. For reasons only known to them, this bit of green belt appears to include a large housing estate. When the anti-development brigade talk about green belt being “the countryside next door“, this is one of the bits of it they need to go and have a look at.
Havering has, for the time being at least, set aside its plans to secede from the rest of London, but it might want to think again now that the Mayor is requiring it to release green belt for 12,060 homes, which amounts to 55% of its total target.
The draft London Plan identifies six stations as BLGs: two on the Elizabeth Line at Gidea Park and Harold Wood, and the final four at the eastern end of the District Line: Elm Park, Hornchurch, Upminster Bridge and Upminster.
There are pockets of developable green belt around each of these, but the most significant opportunity lies around Harold Wood, with a large chunk of land to east of the station.
Time will tell whether the new Reform-led council has the appetite for this. The test will come sooner than expected when it’s called upon to determine an application for 1,300 new homes on Crowlands Heath Golf Course (see Barking & Dagenham, above); not one of the BLG areas identified within the London Plan, but green belt nonetheless.
The Reform councillor’s manifesto for Havering is rather light on detail, but claims it will “[p]rotect and enhance our parks and green spaces” whilst simultaneously “cutting red tape for development”. Let’s see which of these it chooses.
The previous, independent, administration expressed a preference for affordable family homes on green belt over residential towers in central Romford, but the easternmost wards are all still under independent control—and this is likely to be where most of the green belt release will occur.
A large chunk of Hillingdon’s green belt will be lost if Heathrow’s third runway goes ahead, although the Mayor has reiterated his opposition to the proposals.
Hillingdon’s BLGs are all in the north of the borough, however, around the cluster of stations along the two forks of the Metropolitan Line.
There are plenty of bits of underused land within 1,200m of these stations, although, by and large, they tend to be at the outer edges of this distance. And lots of golf courses fall within this scope, too. This is the most fragmented of all of the potentially developable green belt of all of London’s boroughs.
The new council administration is clearly going to fight this tooth and nail, particularly as the BLG locations are exclusively within the staunchly Tory-voting wards. At over 60%, Hillingdon also has the largest proportion of its housing target to be found on green belt. Expect fireworks.
Redbridge has two large areas of green belt, one in the south west corner around Wanstead (this bit is green belt in name alone, being enveloped entirely by urban areas), and a second to the west of the Central Line between Newbury Park and Hainault.
The tube line skirts the Fairlop Country Park (presumably not a location for new homes, given its protected status) and the Fairlop Waters golf course (which might be).
According to the draft Plan, Redbridge needs to find space for 5,400 homes on green belt; a third of its total of 16,130. I’m struggling to see where they might go. Look at the image below and try to imagine 5,400 homes somewhere in here that doesn’t involve building on the park:
It’s not clear to me why Ealing and Bromley (the London borough with the largest amount of green belt, both by total area and proportion) have been excluded from the initial tranche of BLGs, as both have stations close to the green belt, and Ealing even has one that’s identified as such, at Northolt; and at least some developable land within 1,200m. Ealing isn’t even identified as a future candidate BLG, which is odd.
And then to Bromley, in the south east of the city. Here’s a map of the borough showing all its stations, and the concentric density rings around them. Despite having the largest area of green belt of any London borough, Bromley is not expected to lose any of it in delivering its (very modest, and extremely precise) total target of 7,507 homes.
This seems peculiar, given that the government’s standard method for calculating its own targets requires Bromley to deliver just over 15,000 homes; twice as many as the London Plan demands.
The reason for this is appears to be that the Bakerloo Line Extension, which is planned to extend as far as Hayes, is at least a couple of decades away, and three of the “Future Candidate” BLGs within Bromley—at St Mary Cray, Knockholt and Chislehurst & Petts Wood—indicate the need for significant green belt release at some point in the future.
There are plenty of other stations in close proximity to the green belt, though, and it seems odd to ignore the potential of these to meet London’s housing challenge, especially when the total number of homes it requires fall so far short of the government’s target.
Why defer these to a later date when there’s plenty of capacity, and demand, for new homes in the shorter term?
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