Enfield RoadWatch Action Group

In this section, we will post links to consultations that are relevant to our campaign along with explanatory notes.  We hope you will take the time to participate by clicking through and sharing your views and ideas.

May 2019 – Thanks to everyone who submitted a response to the recent Local Plan consultation!  We await the results, but we think many of you participated.  We hope the Council received a loud and clear message that the Green Belt should be protected for future generations.  You can read Enfield RoadWatch’s full consultation response below.

There are no current local plan consultations for Enfield.  The next consultation is expected in late 2019 or early 2020.  Please join our email list and you will be notified of any important events.  In the meantime, you can keep up the pressure by writing to your ward councillors and other politicians.  Click here for more information: How Can I Help?

2018-19  Regulation 18 Local Plan Issues and Options Consultation. 

This very important consultation closed at 5pm on Thursday, February 28, 2019.

Enfield RoadWatch’s response to the consultation, background information and suggested responses are archived here.

PUBLIC CONSULTATION (REGULATION 18) TOWARDS A NEW LOCAL PLAN 2036 – ISSUES AND OPTIONS – RESPONSE FROM ENFIELD ROADWATCH

1.1 Enfield RoadWatch began life in 2015 to object to the potential development of an important area of Green Belt South of Enfield Road.  However, wider threats to the Green Belt and the increasing importance and benefits of the borough’s entire network of Green Belt and Metropolitan Open Land [MOL] led the action group to expand their goals and mission. Enfield RoadWatch has a supporter list of well over 1,000 and more than 22,000 people have signed our petition.  We work with other local and national organisations which share the same goals including The Enfield Society, the Federation of Enfield Residents’ and Allied Associations [FERAA], CPRE-London, London Green Belt Council and many community groups.  We have also been supported by politicians in most parties, including Enfield North MP, Joan Ryan. Enfield London Assembly Member, Joanne McCartney and The Lord Storey, CBE.

1.2 In December 2018, Enfield Council published a Regulation 18 Issues and Options paper as part of the development of a new Local Plan for the Borough. This is an important document that seeks views on the way in which development should proceed over the period 2020 to 2036. “The key function of a successful Local Plan for Enfield, is to accommodate growth in a way that makes the borough better for everyone”

1.3 The new Local Plan is required to meet new national legislation/Guidance and be compatible with the Major’s draft London Plan.  The Plan has to meet the needs of an ever-increasing population, provide a long-term vision for the Borough and meet key strategic infrastructure projects such as Crossrail 2 should it be confirmed.

1.4 The principle challenges for the Plan are

  • Providing more housing. The Council has a borough-wide target of 50% affordable housing and to prioritise social rented homes
  • Protecting the Green Belt and other open spaces
  • Identifying sites for development and
  • Regeneration

1.5  The Council is also consulting on a draft ‘Heritage Strategy’. This is not part of the Local Plan but it is important that it links with the overall aims of the Local Plan so that protecting Enfield’s heritage is not overlooked.   The Heritage Strategy should be used to inform the policies which would emerge in the new Local Plan.  Furthermore there should be policies within the Local Plan seeking to fulfil the objectives of the Heritage Strategy.  Moreover, the Heritage Strategy should in part inform site allocations. Enfield RoadWatch welcomes this document that brings together information on the Borough’s Conservation Areas, Listed Buildings including the Local List, its heritage and history. The inclusion of heritage landscapes and land uses is applauded. It is hoped that the new ‘Heritage Strategy’ will aid planners and developers to keep these important aspects of the borough in mind.

1.6 The Regulation 18 Local Plan consultation document is 216-pages, although a summary has also been published.  Enfield RoadWatch has reviewed the plan and taken expert advice and has the following observations:

  1. Commentary on the consultation process.

2.1 Enfield RoadWatch welcomes the Council’s efforts to involve the wider community through local meetings, the on-line consultation exercise and social media. We also appreciate the longer-than-usual consultation period.  However, we would like to make a few points that could improve the process for future consultations:

  1. There was a lack of consistency between the online and printed consultation questionnaires, which caused confusion.
  2. All of the drop-in sessions were mid-week, during the day-time with only two sessions running until 7.00pm, making them impractical for working people.  They were also not advertised using traditional methods but only on a digital platform.  The onus was on individual Councillors to make their constituents aware of the consultation by inviting officers to Ward Forums and other means.  It would be helpful to see the Equality Impact Assessment and the risks the Council assessed in taking this approach.
  3. It is also noted that despite ‘Our Enfield’, the Council’s magazine, being identified in the Statement of Community Involvement as the communication vehicle for every home in the borough to reach in particular vulnerable housebound elderly, people with disabilities, this consultation was not advertised in any of the issues, from and including December 2017.
  4. There was an inconsistency in the various media about who could participate with the term ‘residents’ appearing often when the consultation was in fact open to much wider participation.
  5. Advertising and promotion of the consultation was not as widespread as for the ‘wheelie bin’ and other consultations, despite its importance. This resulted in many people being totally unaware of this very important process.
  6. The limited advertising campaign was unclear in its messaging, with its purpose only being visible in the website/ email address at the bottom of the adverts, where it was easily missed. This also resulted in a lack of awareness about the consultation.
  7. It is also noted that Local Planning authorities must publish information at least annually that shows progress with Local Plan preparation, reports any activity relating to the duty to cooperate and shows how the implementation of policies in the Local Plan is progressing and that they are encouraged to report as frequently as possible on planning matters to communities. This is important to enable communities and interested parties to be aware of progress.  Enfield’s own Monitoring Report 2016 is significantly out of date, adopted in 2017, and we ask that it is kept updated.
  8. We also note that despite the Council’s website advertising a summary of previous responses to the initial consultation and The Enfield Conversation both these documents are inaccessible but would have been useful for people to take into account when completing this current consultation.
  9. To understand the proposals fully, the consultation demanded expertise and/or access to background documents to an extent that most residents could not participate in an informed way. Enfield RoadWatch suggests that the Council should now establish a dedicated webpage from which one can drill down into the evidence base.   This would be the easiest way to find the background evidence documents.
  1. Commentary on the Local Plan

3.1  Enfield RoadWatch wants to be assured that the proposals in the Local Plan are:

  • Based on a strategy which meets objectively assessed development and infrastructure requirements;
  • Justified as part of an appropriate strategy;
  • Effective and deliverable over its period;
  • Consistent with national policy and the London Plan.
  • In accordance with general requirements of national planning policy and that preparation and review of all policies are supported by relevant and up-to-date evidence (see NPPF 2018, paragraph 31).

3.2  Enfield RoadWatch supports the objective of addressing inequality and poverty. The Borough has too many low paid jobs, areas of poor quality and overcrowded housing and areas in need of regeneration. Enfield RoadWatch believes that one way to address these issues would be to invest in the masterplanning of a number of areas [discussed later] to avoid piecemeal development and to bring infrastructure improvements in tandem with new housing and regeneration.  The Council should, if necessary, be willing to exercise compulsory purchase powers to ensure comprehensive developments.

3.3  Enfield RoadWatch also believes that the Borough’s employment areas, especially Strategic Industrial Locations [SIL] and Locally Significant Industrial Sites [LSIS], should undergo a masterplanning exercise. We understand that the Borough is a Provider Borough, called upon to increase employment space. However, we also understand from discussions with the GLA planning team that employment space can be intensified in some areas to meet that demand while releasing other industrial land that would be better-used for mixed-use for reasons such as its proximity to public transport.  There is a particularly strong case for limited change to the designation of SIL areas to the north and south of Southbury Road. This is because they are already compromised in terms of proximity to proposed housing, but also because they can deliver, in our estimation, alongside other nearby sites, upwards of 17,500 new homes.

3.4  Enfield RoadWatch is concerned about demographic projections which are used to create housing and other targets, because they are based on trends which can and do change.

3.5  Enfield RoadWatch accepts the need for change and development so long as this is linked to the protection of Enfield’s heritage and its green spaces.

3.6  All future development should seek to achieve design excellence.  The recent establishment of the ‘Place and Design Quality Panel’ is welcomed but further pressure needs to be placed on developers to submit their design to this type of scrutiny. Any developer working in Enfield should be made fully aware that the Borough is seeking high quality design that reflects the local environment.  There should be appropriate policies in the emerging Plan to ensure good design.

  1. The Green Belt.

4.1 The purpose of the Green Belt is stated in the Government Circular, 3 August 1955,

“Checking the unrestricted growth of built-up areas”. The policy has served the south east of England well since the late 1940’s.

4.2  Enfield RoadWatch does not believe that there is a need to carry out any systematic review of the Green Belt in Enfield and is opposed to a wider Green Belt Review.  The document titled ‘Enfield’s Local Plan – Evidence Base – Detailed Green Belt Boundary Review – March 2013’ was approved and adopted.  It contains phrases confirming the longevity of the findings, including:

  • [Local Authorities should] Satisfy themselves that Green Belt boundaries will not need to be altered at the end of the development plan period.
  • The review provides an understanding of the current strengths and weaknesses of the existing Green Belt boundaries and has in turn recommended amending the boundary where appropriate to provide certainty over the next 15 to 20 years.

Therefore the existing Boundary Review is still valid and current and another review is absolutely unnecessary.   The wording in the Regulation 18 document implying that it must be done to comply with the NPPF is inaccurate.  Any Green Belt review should always be the very last stage in the process after the Local Authority has failed to find sufficient previously-developed land.  That is not the case in Enfield as will be highlighted later.

4.3  Allowing development in the Green Belt would cause harm to the Borough in the following ways:

  • It would be a failure to preserve the openness and permanence of the Green Belt, harming its integrity and amenity value for current and future generations.
  • It would encourage low-density, car-dependent development which would add to congestion, noise and air pollution in a Borough which is attempting to reduce car trips with the introduction of cycle lanes.
  • It would be ineffective in addressing Enfield’s housing needs which could be better tackled by developing large strategic sites with good public transport links.
  • It would entail the loss of good quality agricultural land which could and should in fact be put back to use to create a sustainable local food source for Enfield markets as per the GLA’s Farming in London’s Green Belt report of Dec 2018.
  • It would also entail the loss of amenity space for Enfield and London residents, the potential of which is great and enhancements can and should be planned.

4.4.  Enfield RoadWatch objects to the removal  of any land from the Green Belt.  While housing targets have increased along with London’s population, policies protecting the Green Belt in the NPPF and London Plan have not changed.  In fact housing is specifically excluded as an ‘exceptional circumstance’ which could allow the release of Green Belt.

4.5  Enfield RoadWatch does not support any expansion of development into Green Belt land.   The Council should seek to embrace, enhance and improve the Green Belt taking enforcement action where there is inappropriate use and seeking to maximise its use for agriculture, wildlife conservation and promoting healthier living.

4.6  Enfield RoadWatch is disappointed that the Regulation 18 document makes no provision for protecting or promoting agriculture in the borough.  This is a direct departure from the 2014 DMD which makes special mention of its historic and current importance.  Growing food locally is becoming increasingly relevant for environmental and economic reasons and its importance is recognised in the GLA’s Farming in London’s Green Belt report of Dec 2018. The emerging Local Plan should include policies to encourage, promote and protect agriculture and productive use of agricultural land in the borough. 

4.7 One of the options in the Regulation 18 document is to look at development in the Crews Hill area due to the railway link, the fact the Green Belt is already partly developed in this area and its strategic location on the London-Stansted-Cambridge Innovation Corridor.  Enfield RoadWatch believes that the Green Belt needs to remain a complete circle around London to provide essential open space, cleaner air and a wildlife corridor; it has protected London since the mid-20th century. Once you erode the Green Belt that erosion is likely to continue due to pressures on adjacent land. It is also noted that although Crews Hill Railway Station provides a railway service, there are no other public facilities (schools, medical facilities, etc.) and non- railway links are very poor. There is only a very limited bus service between Crews Hill and Enfield Town.  Crews Hill is not a sustainable location given the very limited services available within that settlement.  If a settlement is going to provide appropriate services then there would have to be a huge expansion which would fly in the face of Green Belt policy.  Housing development in Crews Hill would also displace many successful small tenant businesses that have been there for decades.

  1. Housing.

5.1  The emerging Local Plan should allocate specific sites for development and hence there should be no ad hoc or piecemeal developments other than very small sites.  Furthermore, each allocated site should have a specific written policy which should detail how development is to be achieved, i.e. that a masterplan will be necessary and the development must be comprehensive as opposed to piecemeal.  In practice, to achieve comprehensive development, CPO powers will almost certainly be necessary. 

5.2 To enable local participation, Enfield RoadWatch considers that all growth schemes should come through the Local Plan and a planning brief should be prepared for all development sites. To ensure that development is strategically planned, the Council should encourage the development of local neighbourhood plans.

5.3 In recent years about 800 new homes a year have been built in Enfield, the London Plan seeks to increase that number to 1,876 per year and the Government’s Planning Policy Framework (2018) using a national assessment of need suggests that up to 3,500 new homes per year could be required. Both these figures provide an enormous expansion of new house building and will present considerable challenges and local opposition. Providing for this growth is therefore a key element and the Plan identifies the different ways in which change and development could be accommodated while still protecting the Borough’s heritage and the local environment.

5.4 Enfield RoadWatch considers that Enfield’s housing target must be further tested by an up-to-date Housing Needs Assessment and that the target must be kept under review. There is some evidence that the projections are overestimating future requirements. We note that Enfield School Roll Projections for entry to primary school at aged 3 and 4 over-estimated the demand resulting in surplus places following the Primary School expansion programme. There is also the need to provide an appropriate mix of dwellings (rather than further blanket provision of small flats) with consideration given to providing adequate space standards and amenity space.

5.5 The search for potential sites for housing and employment should focus first on previously developed land – PDL – (brownfield sites) particularly in the Upper Lee Valley, the London, Stansted, Cambridge Corridor and along the A10. Enfield RoadWatch in collaboration with CPRE-London and The Enfield Society conducted an extensive analysis of available PDL and their findings were published in Space to Build, Enfield.   In researching Space to Build, Enfield sites were identified which could be better used i.e. built higher using air space. These include surface car parks, low density / low-rise retail or industrial spaces, garages and other low-rise buildings in areas where it would be appropriate to increase height.  An assumption was made that surface car parking is a poor use of space which could be better deployed either by incorporating parking within a development (for example building over car parking space), moving parking to a site nearby to free up a site for development or, where appropriate, eliminating parking.  A total of 510 sites were identified, incorporating 480ha. The full report has been provided to the LBE planning department, Councillors and others.  Space to Build, Enfield and its accompanying master analysis form part of this response to the consultation.  In light of the findings in the report Enfield RoadWatch makes the following recommendations:

  • The Council should adopt a proactive approach to promoting appropriate sites for development, especially mixed-use development There are many sites which could be developed to make better use of space in Enfield, for example supermarket sites with surface car parking and poorly-used industrial or commercial sites in need of regeneration. Along with smaller sites, these could accommodate upwards of 37,000 new homes at a conservative estimate, according to our survey.
  • Enfield should create a policy designed to proactively promote the development of the larger sites listed in the report. The policy could state that the borough will engage with owners and developers who wish to consider development of their site and that the borough would encourage pre-application discussions to establish parameters for a particular site. Enfield could create a panel of developers and architects to assist with this process.

5.6  Enfield’s targets for housing and increased employment space are high but achievable on PDL.  The key recommendations of the Space to Build, Enfield report as it relates to housing and infrastructure are:

  • Affordable housing Enfield is dominated by relatively low density, suburban housing with car-parking. Large ‘opportunity’ sites with good public transport can and should be used to create an alternative i.e. large-scale high density, car-free / car-lite developments which are affordable for young people / people on lower incomes who are also more likely to rely on public transport and are less able to afford a car. Low-density, car-dependent development in Green Belt will not meet these needs.
  • Capacity within Enfield for masterplanning Enfield and the GLA must work together to ensure Enfield has adequate capacity to establish masterplans for, at a minimum, Southbury/Ponders End and Edmonton Green/Edmonton Futures Housing Zone. Other areas in Enfield also need masterplans to ensure economic, social, environmental and infrastructure issues, such as transport, schools and health facilities, are planned effectively. Edmonton is a particularly deprived area which deserves better. Southbury is a huge opportunity for Enfield and is a space which could host a really attractive new district centre which can transform the area for all Enfield residents.
  • Southbury / Ponders End opportunity area Southbury should be designated a Mayoral Housing Zone with the Upper Lea Valley Opportunity Area extended to encompass it. Enfield should establish capacity and work with the GLA to create a Masterplan for the Southbury area incorporating the areas proposed above, as soon as possible, and should avoid piecemeal development in the area. The Colosseum Park development should not go ahead unless and until the masterplan is in place – though clearly this is a huge opportunity for early gains so masterplanners should work with the developers to ensure it is ready to go once the masterplan is ready. Ponders End should also be designated a Mayoral Housing Zone and/or Opportunity Area, and connected to the Southbury Area Masterplan, so that services, amenities, etc . are planned in tandem, given the proximity of the areas. The area around Ponders End Station has huge potential to deliver housing in mixed-used developments at the southern end of the Brimsdown Estate and on the Redburn and Meridian estates.
  • Edmonton Green / Edmonton Futures Mayoral Housing Zone opportunity area The Edmonton Futures Mayoral Housing Zone should be extended to incorporate Edmonton Green and these areas should be masterplanned in tandem with support from GLA.   This is a particularly deprived part of the borough which suffered from the riots but missed out on regeneration like that in White Hart Lane. The area is in desperate need of a masterplan and there is huge potential to transform the area for existing residents and to attract new business.

5.7  Transport improvements must be brought forward to support these targets, in particular rail improvements on the West Anglia main line, upgraded service on the Cheshunt London Overground Line and improvements to bus provision in the Upper Lee Valley corridor. Space to Build, Enfield makes the following recommendations with regard to rail improvements:

  • London Overground to Enfield Town / Cheshunt TfL should increase trains on the Southbury Loop north of Edmonton Green to  4 trains per hour at peak. Both the Southbury Loop and the Enfield Town branch should be upgraded to 3 trains per hour off peak and at weekends. That would allow a clockwork timetable of 6 trains per hour from Edmonton Green to Liverpool Street. There is a strong business case for the Southbury option, which would also unlock development at Turkey St.  Ultimately, a new station should be planned between Southbury and Turkey Street at Carterhatch Lane, to open that area up.
  • West Anglia Line Enfield should work with other affected boroughs, as well as TfL and the GLA, to reinstate the plan to quad track the West Anglia line from Stratford to Brimsdown as a priority. This would facilitate up to 8 trains per hour with some platform work at Stratford. Quad-tracking is also the stimulus for a new station at Pickett’s Lock, which could also be a Crossrail 2 station, serving new housing west of the tracks. The Upper Lee Valley Opportunity Area Planning Framework [OAPF] envisages walking and cycling bridges over the railway at Goodwin and Charlton Roads. The 1995 business case for a new station at Pickett’s Lock should be updated to deliver the new station between the two bridges.
  1. Realising opportunities and a call for sites.

6.1 The Regulation 18 consultation refers to the need to identify sites for housing and associated community use. Residents, property owners and developers are invited to submit ideas.  Space to Build, Enfield identifies sites ranging from very large to hundreds of small sites.  A document has been created for each of the 21 wards in Enfield which lists and has photographic images of every site.  There is a spreadsheet analysis of all the sites.  Enfield RoadWatch has submitted these documents and asks that the Council reviews these sites carefully as part of the Call for Sites in producing options for future development.   Because of the impracticality of completing a Call for Sites form for each of the sites in the report, we state for the record, at the suggestion of Neeru Kareer,  (Head of Strategic Planning & Design (Interim) L.B.E.) that the Enfield Roadwatch submission to the Reg 18 Local Plan consultation including attachments is duly made and will be considered officially by the LPA, as confirmed by officers at our meeting on January 29, 2019 when officers confirmed they would explore the information provided as urban intensification and site capacity studies are progressed.

  1. Small sites.

7.1  Enfield RoadWatch understands from discussions with GLA planners that the London Plan requirement for 50% of development opportunities to come from small sites (less than 0.25 hectares) is a target, not an absolute and that its goal is to promote opportunities for smaller developers.   Our survey shows the goal is probably not achievable in Enfield.  However, we understand that the availability of other PDL to meet the housing target would be considered favourably.  This should not preclude the use of small sites such as unused garages where they are appropriate for development.  

  1. Protection for Public Houses.

8.1 Enfield RoadWatch agrees with The Enfield Society in its concern about the closure of public houses throughout the Borough and with its recommendations for protecting those that remain.  The emerging Plan ought to include a policy saying that the change of use for a public house to residential will not generally be allowed unless it meets set criteria  e.g. demonstration that it is financially unviable and that there have been efforts to market the property as a public house at a realistic sales figure.

Authors:

Carol Fisk

Ian D’Souza

Elizabeth Nuckowska

Keith Bilton

Attachments:   Space to Build, Enfield – complete report with ward documents and master analysis previously submitted digitally to LBE Head of Planning, Vincent Lacovara for the Local Plan team.    END

 

[The Reg. 18 Issues and Options Consultation closed on February 28, 2019 – our consultation material is archived below]

  • Do you enjoy the Garden Centres in Crews Hill and think it would be a mistake to replace them with housing?
  • Do you believe Enfield is special because of its Green Belt and Open Spaces?
  • Do you think new development should bring an improved quality of life for current residents?
  • Do you want to keep the Green Belt safe for wildlife, recreation, food-production, keeping the air clean and us healthy?
  • Do you want Enfield Council to explore ALL possibilities before allowing housing to be built on Green Belt land, including at Crews Hill?
  • Do you want to keep London Green for future generations?

If you’ve answered YES to any of these, be part of the future now and respond to the consultation.  Anyone who lives, works, studies or has an interest in Enfield can respond individually.  Here’s how:

  • Email – Send your response using our suggestions below or your own comments to localplan@enfield.gov.uk.  You must include your name and address.  We recommend this as the simplest option.
  • Online consultation – the online survey is a summary which skips many of the questions in the printed version.  In both cases, the questions do not reflect all the underlying policies, so please read our summary below for guidance.  We recommend providing comments rather than yes/no answers.  https://new.enfield.gov.uk/services/planning/planning-policy/local-plan/#1
  • By post – Paper copies of the consultation should be available in libraries.  The paper version is quite long and complicated and other documents need to be consulted for it to make sense.  Our summary below may help you with this.  Responses, which can either be the form from the printed consultation or a simple letter, should be sent to:  Strategic Planning and Design, Enfield Council, Freepost NW5 036, EN1 3BR.  Postage is free.

If you use a suggested response, please include a few words of your own to make it individual and don’t forget to add your name and address.  Thanks!

Suggested short response to consultation. Copy & paste then email.

Suggested longer response to consultation. Copy & paste into email

Background information for consultation response

Space to Build, Enfield published! Building on the Green Belt is the worst possible option!

Enfield RoadWatch Green Belt awareness campaign

Please note: our comments and suggestions relate only to policies that could affect the Green Belt and Open Spaces.  The consultation also deals with many other important issues, which you can read about on the Council website.

For additional information see:

Consultation update – February 3 2019

January 2019 Newsletter.  Important information.

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Wren Academy Enfield survey [Closed – Wren Academy is now due to open on the Chase Farm site in September 2020]

Find out more here: Wren Academy Enfield

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Draft London Plan Consultation [Closed – New London Plan awaiting final approval]

The London Plan is a strategic plan which shapes how London evolves and develops. It sets a policy framework for local plans across London and all planning decisions should follow London Plan policies.  This plan will greatly impact Enfield’s Local Plan, which is currently under revision.  The draft London Plan is a very long and complicated document.  It can be downloaded here:  https://www.london.gov.uk/what-we-do/planning/london-plan/new-london-plan/download-draft-london-plan

We will post and distribute some analysis early in 2018.  Your comments, which should refer to the relevant policy or paragraph of the document, can be submitted in three ways:

  • online through a consultation tool at www.london.gov.uk/new-london-plan
  • by mail to  Sadiq Khan (Mayor of London), New London Plan, GLA City Hall London Plan Team, Post Point 18, FREEPOST RTJC-XBZZ-GJKZ, London SE1 2AA
  • by email to LondonPlan@london.gov.uk with ‘New Draft London Plan’ as the title.

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