Enfield RoadWatch Action Group

We have chosen four questions from four different chapters that we think are important for you to object to. You don’t have to do all of them [or you can respond to totally different ones] but they make important points about Enfield’s Green Belt and the potential issues with its proposed development.

Please rephrase these samples in your own words, if you can, but keep the main points.

Chapter 2 – Making best use of land and achieving good growth

Policy MBUL 1 – Spatial Strategy

​Q6 answer NO, then respond to Q7

​Suggested wording:

I object to sections of this policy.

There needs to be a clear explanation for why a 1,200‑metre walking catchment is being used for stations marked for major housing growth, when national policy uses 800 metres as the standard. The key question is whether there is solid evidence that people living further away (between 800m and 1,200m) will still use the train often enough to support higher‑density, low‑car development under Policy PV7.

This leads to a few important points:

  1. What train service levels (now and in the future) have been assumed when predicting how people in this wider area will travel?
  2. If extra capacity or more frequent trains are needed to make those assumptions realistic, how will those improvements be secured, funded and delivered?
  3. And how will they be timed so that car‑dependent travel patterns do not become established before the upgrades are in place?

This policy identifies J24 as suitable for industrial development.  This directly contradicts the recent conclusion of Enfield’s Planning Inspector in his post-hearing letter, where he states: 73. I do not consider this allocation is soundly based and the potential actions set out in document E9.2 would not alter that conclusion. The allocation would result in a very high degree of harm to Green Belt purposes and would, in effect, create an isolated ‘hole’ in the Green Belt near to Junction 24 of the M25. This would not extend the existing urban edge but rather create an entirely new pocket of built form in an area where there are currently only sporadic buildings. Notwithstanding the proximity of the motorway junction, the area retains a relatively rural character, particularly when heading into Enfield. 74. The introduction of large industrial or logistics buildings into this area would also result in a similarly high degree of harm to the character and appearance of the area.

Additionally this policy states that Local Plans should:  (6) Help realise the identified strategic opportunities for nature recovery, enhanced access to green space, and cleaner, healthier waterways reflected in Environmental Opportunity Areas through site allocations, spatial policies and appropriate developer contributions that secure connected and multi-functional green and blue infrastructure.  

This policy fails to embed protection of existing biodiversity and habitats in the spatial strategy itself, relying instead on mitigation through BNG and other measures to foster nature recovery.  As has become evident, BNG has too many loopholes, resulting in slow rollout of green and blue infrastructure or none at all.  The Statutory Biodiversity Metric undervalues the complex interactions of habitats, so what is lost is not replaced.  And given that many habitats can take 30 years or more to reach maturity, this omission in the policy could work against Nature Recovery instead of helping it.

Chapter 3- Delivering the homes and neighbourhoods Londoners need

Policy HN1 Increasing London’s housing stock

Q6 answer NO, then respond to Q7

Suggested wording:

I agree that more homes are needed, but the numbers proposed for Crews Hill and Chase Park are not well‑evidenced and do not appear realistic or achievable.

Enfield’s Local Plan expects about 3,445 homes to come forward in these areas between 2027/28 and 2036/37. The draft London Plan, however, assumes 7,000 homes in the same period. This increase is hard to justify given concerns expressed by the GLA and TfL during Enfield’s local plan examination about poor public transport access, the likelihood of car‑dependent travel, and the major infrastructure upgrades that would be needed to make development sustainable.

There is also a wider risk. Building large amounts of Green Belt housing at the same time as major brownfield regeneration could divert investment, developer capacity and transport funding away from better‑connected urban sites. The GLA raised this issue during Enfield’s Local Plan process, but it does not seem to have been addressed here.

For these reasons, the GLA should explain what new evidence supports the proposed 7,000‑homes and show that it can be delivered without harming brownfield housing delivery. If this cannot be demonstrated, the volume or timing of development at Crews Hill and Chase Park should be reconsidered.

Chapter 5 – Creating a greener, resilient and healthy city

Policy GR6 – Trees, biodiversity and geodiversity

Q21 answer NO, then respond to Q22

Suggested wording:

I want to see nature protected and restored, but the draft London Plan has not shown that the amount of development proposed for Crews Hill and Chase Park fits with that aim. If building at this scale would damage sensitive land, then the locations and the amount of development need to be reconsidered.

These areas are not empty pieces of Green Belt. They include valuable habitats, recognised nature sites (SINCs), woodland, hedgerows, grassland and watercourses. Enfield Council’s own ecological studies, as well as commissioned professional reports and evidence submitted by local groups, highlight the biodiversity importance of these places. The Inspector reviewing Enfield’s Local Plan has already asked for stronger protection for SINCs at Crews Hill. This cannot be ignored.

Despite this, the draft London Plan assumes 7,000 homes can be built at Crews Hill and Chase Park by 2036/37, which is roughly double the number Enfield expects over the same period.  Before relying on such a large increase, the GLA needs to show clearly how this level of development could happen without causing unacceptable harm to existing habitats or breaking up SINCs. The priority should be protecting the nature that already exists, not assuming that any loss can simply be replaced later with new planting or biodiversity projects somewhere else.

As has become evident since its inception, BNG has too many loopholes, resulting in slow rollout of green and blue infrastructure or none at all.  The Statutory Biodiversity Metric undervalues the complex interactions of existing habitats, so what is lost is not replaced. And given that many habitats can take 30 years or more to reach maturity, this omission in the policy could work against Nature Recovery instead of helping it.

Chapter 6 – Place visions and place-based approaches

Policy PV7 – Sustainable development and enhancement of the Green Belt

Q24 answer NO, then respond to Q25

Suggested wording:

I do not think PV7 is sound in its current form. A large Green Belt site should not be labelled “sustainable” just because one small corner happens to be close to a station.

Crews Hill and Chase Park face major transport and environmental challenges. These areas include recognised nature sites (SINCs), important habitats, woodland, hedgerows, watercourses and open countryside utilised as an asset by the community. Evidence gathered through Enfield’s Local Plan has already shown that some parts of these sites are too sensitive for development and need stronger protection. This has also been supported by the Local Plan.

Despite this, the draft London Plan assumes 7,000 homes can be built here by 2036/37, compared with around 3,445 in Enfield’s own housing trajectory.

Before accepting such a large increase, the GLA needs to show two things clearly:

  • That this level of development can be supported by genuinely sustainable transport delivered before car use becomes embedded, and
  • That it can happen without damaging or breaking up important habitats and designated nature‑conservation areas.

The Plan should set out which areas of land are environmentally sensitive and must be safeguarded. It should not rely on the idea that biodiversity loss can simply be “made up for” somewhere else with new planting or green space.