Government New Towns consultation – deadline May 19

This is page 1

• Select – I am a member of the public, giving my views as an individual
• Complete Name, Email address, Postcode
• Select – Crews Hill and Chase Park, Enfield
• Select – London
• Select – Resident nearby or Other
  [If you select Other use the box to describe your interest. You might want to use Other because ‘resident nearby’ rather implies a NIMBY attitude when the new town would affect residents from all over Enfield and neighbouring Hertfordshire and further]

This is page 2

If you are representing an organisation, type in the name of the organisation and your role, then select an option to describe its nature and size.

This is page 3 – Question 7

Select none of the options

In the box type:
Only brownfield sites with multiple public transport options and within walking/cycling distance of jobs & services are suitable. This is not the case with the Enfield site.

[You are, of course, free to say whatever you want here and for all the questions. This is just a suggestion]

This is page 4 – Question 8

Select – Crews Hill and Chase Park, Enfield

In the box type:
The choice of this greenfield site goes against all the brownfield first policies that are in place.

Major state intervention would be needed to put in place infrastructure and community services before houses are built, to provide incentives to employers, and to build social housing.

The area is not a blank slate waiting to be developed.   The new town would be place-breaking, not place-making.

This is page 5 – Question 9

Select – No

Select – Crews Hill and Chase Park, Enfield

In the box type:
The SEA has not identified or properly weighted the main environmental issues relevant to Crews Hill and Chase Park.  It is too high-level and appears to have ignored the extensive database of evidence about the area prepared for the ongoing local plan examination.

To state that any harms would be outweighed by the need for housing is a weak argument given the multiple other solutions to the housing crisis that are not mentioned at all.

This is page 6 – Question 10

Select – Yes

Select – Crews Hill and Chase Park, Enfield

In the box type:
There is abundant local evidence already available through the Enfield Local Plan process and related evidence base.

This must be reviewed before any final decision is made about the new town location.   Until all of those opportunities to provide housing are exhausted there is no need to build a single new town, particularly on greenfield sites.

This is page 7 – Question 11

Select – Yes

Select – Crews Hill and Chase Park, Enfield

In the box type:
The first stage of the mitigation hierarchy is ‘avoid harm’. Therefore, to avoid harm, not a single new town should be built on greenfield.

The do-nothing scenario is not accurate. Not building new towns does not exacerbate the housing crisis. Not building social housing does exacerbate the housing crisis. That is what is needed.

This is page 8 – Question 12

In the box type:
Detailed analysis of the SEA section relating to Crews Hill and Chase Park, reveals it to be based on the same high-level, misleading statements and assumptions that were presented in the New Towns Taskforce report, and that information must have come from Enfield Council’s submission – which the council refused to release to an FOI from the GLA. It seems that the original submission was taken at face value with no independent evidence-gathering to check its accuracy.  That must be rectified.

This is page 9 – Question 13

Select – No

In the box type:
The site is greenfield and, for reasons set out above, should not be considered.

This is page 10 – Question 14

Select – No

In the box type:
Without very substantial state investment, new towns will not provide 40% ‘affordable’ housing, let alone genuinely affordable social housing, nor will they deliver the necessary infrastructure in a timely fashion, before housing (if at all).

This is page 11 – Question 15

[You can select Not sure and bypass this question]

This is page 12 – Question 16

[You can select Neutral and bypass this question]

This is page 13 – Question 17

[You can select Not sure and bypass this question]

This is page 14 – Question 18

Select – Not sure

In the box type:
There is too much flexibility and for certain key public interest principles there should be no flexibility at all.  For instance, there should be robust policies that ensure a greenfield last approach. There can be flexibility in how outcomes are achieved, not flexibility over whether they are achieved.

This is page 15 – Question 19

Select – No

In the box type:
It is meaningless. It will be undeliverable and renegotiated and also will not result in social housing, which is what is needed. This comes back to the central issue with this project: lack of substantial public funding.

The consultation should be honest about timing and not lead people to believe that affordable homes are imminent. A new town may take many years before it delivers homes at scale. Evidence should be provided of tenure mix, timelines and so on to avoid the risk of misleading people.

This is page 16 – Question 20

Select – No

In the box type:
The social and economic benefits of a new town should not be assumed simply because a proposal is labelled a new town. They should be evidenced. 

As with so much of the new towns process, assumptions have been allowed to replace evidence and ambitions and rhetoric to replace the hard work of fact-finding and independent research.  The potential harms of the new town to the environment and the Green Belt are more well-evidenced than any of the benefits.

This is page 17 – Question 21

Select – No

In the box type:
Without exception, there should be no new towns in the Green Belt.

The starting point should be whether development can be delivered on brownfield land, underused land and existing urban sites first.  In the case of Crews Hill & Chase Park, these tests are not met because the Council’s Local Plan identifies more than 700 brownfield sites with capacity for around 30,000 homes

This is page 18 – Question 22

Select – No

In the box type:
There should be no safeguarding of any greenfield land until every brownfield opportunity, empty home and unbuilt planning permission has been used.

This is page 19 – Question 23

[You can select Not sure and bypass this question]

This is page 20 – Question 24

[You can bypass this question]

This is page 21 – Question 25

In the box type:
The public is being asked to comment on a proposal without the evidence needed to judge it.

A new town of up to 21,000 homes across around 884 hectares at Crews Hill and Chase Park would be one of the most significant changes to Enfield for generations. It would affect homes, jobs, transport, public services, Green Belt, nature, landscape, food-growing, water, climate resilience and public access to open countryside.

The decision should therefore be evidence-led from the outset.

At present, too much of the public case rests on assertion. Claims have been made about housing, transport, sustainability, ecology, economic growth, public benefit and the suitability of the site. But the underlying evidence has not been published in a form that allows residents, businesses, campaigners or independent experts to test those claims.

Unlike large settlements proposed through a local plan, there is no independent arbiter in the form of the Planning Inspectorate to robustly check for soundness of the proposals. These new towns are being pushed through the system without the benefit of any scrutiny other than this consultation, for which responses can simply be ignored.