“the essential characteristics of Green Belts are their openness and their permanence”
The Green Belt has been enshrined in government planning policy since 1955. Green Belt policy has been described as ‘the most effective planning policy we’ve had – ever. It has done what it says on the tin. It was always part of a two pronged strategic approach – restrict growth in some areas and support it elsewhere.’
Yet despite its “permanence” and its acknowledged success our Green Belt is under threat.
In 2024 the government introduced a new land classification into planning rules – reclassifying areas of land within the Green Belt as ‘grey belt’. The definition includes sites which have previously been developed, such as car parks and redundant petrol stations, disused buildings. However it is also vague enough to allow areas of open productive countryside to be described as ‘infill’ and therefore ‘grey’. Land on the edge of existing settlements, near roads or transport hubs is also being described as ‘grey’. Many environmental groups have protested.
The government says the land is needed for house building, because, they argue, there aren’t enough so-called brownfield sites available to reach their ambitious house building target. Enfield Council has embraced this new land use categorisation, now deeming that significant sections of Enfield’s Green Belt are low quality, of little value and thus could be classified as grey belt and developed.
Does this look ‘grey’ to you? The developer thinks so.
WHO OWNS ENFIELD’S GREEN BELT?
Around 35% of the borough of Enfield is Green Belt, mostly rolling countryside and golf courses, including the last remnants of the historic Enfield Chase. Most of this land is owned by Enfield Council
Existing Green Belt and Metropolitan Open Land in the borough of Enfield
ENFIELD COUNCIL’S ENVIRONMENTAL PLEDGES
In the Council’s Climate Action Plan 2024 and Blue and Green environmental strategy (2021-2031) it pledges to protect local wildlife habitats and enhance biodiversity; create new open spaces, reduce flood risks and pollution – working towards becoming a carbon-neutral borough by 2024, with an aspiration to become London’s greenest borough.
On the plus side, Enfield Council has gained national recognition in creating urban wetlands to reduce flood risk, improve water quality and enhancing biodiversity. The Enfield Chase Landscape Restoration is London’s largest woodland and nature restoration initiative. “The aim is to convert up to 1,000 hectares of farmland into a publicly accessible nature space which links to our existing parks and open spaces”. More than 100,000 trees have been planted in the past five years. supported by the Mayor of London and the Forestry Commission and Defra is on board for a multi-million 20-year grant for the overall project, which the Council has described as “giving Enfield green lungs”.
How will this award-winning landscape regeneration be impacted by the New Towns Taskforce proposals?
AT THE SAME TIME ENFIELD COUNCIL IS TRYING TO CHIP AWAY AT THE GREEN BELT
What is Enfield Council currently looking to dispose of?
- 286 hectares of Green Belt around Crews Hill and 166 hectares of Green Belt around Vicarage Farm were included in the Local Plan. If the new town goes ahead, this would expand to 884 hectares, one third of Enfield’s Green Belt.
- 90 hectares of land at Holly Hill Farm located between The Ridgeway and the M25 have been put up for sale following a review of surplus property assets.
- 11 Hectares at New Cottage Farm, between The Ridgeway and the M25. This land is covered by restrictive covenants and the Council will have to apply to the Department of Levelling Up Housing and Communities (DLUHC) for an order releasing the restrictive covenants to be able to dispose of this site.
- And, very controversially, 53 hectares of Whitewebbs Park, which is targeted to be leased to Tottenham Hotspur for a new women’s training ground. This unpopular deal is forecast to provide the council with an income of only £2m over the 25 year period of the lease, much below its true market value. As with the other threatened Green Belt sites, the fight to save Whitewebbs Park continues.
When the Green Belt is gone, it has gone forever!
Enfield Council are custodians of our green assets. How well do you think they are doing?
As the keeper of the borough’s 123 parks, the Council’s performance is in need of improvement. In the latest Good Parks for London report by the charity Parks for London, Enfield was ranked last out of 25 participating boroughs. Only one of Enfield’s parks holds a Green Flag Award, down from 10 in 2016. By way of comparison, Hillingdon has 66 Green Flag parks.
WHAT PROTECTION IS THERE FOR NATURE IN ENFIELD?
Biodiversity is under threat; globally species are declining at an alarming rate and the extent and quality of the ecosystems that supports them is diminishing. Enfield Council
Under the statutory requirements of London Plan Policy G6 (Biodiversity and Access to Nature) boroughs must ensure that special protection is given to protected environmental sites, such as Sites of Importance for Nature Conservation (SINCs), and those containing priority species or habitats. There are a number of SINCs in the area earmarked for the Crews Hill & Chase Park New Town.
But nature does not live only in the SINCs. Preliminary Ecological Assessments [PEAs] of Vicarage Farm, the Enfield Road fields and Crews Hill Golf Course, all threatened by development, reveal a rich tapestry of habitats supporting many species of wildlife living and visiting the area. The RSPB in their Regulation 19 objection to the new local plan, described Enfield’s Green Belt as ‘a landscape-wide area of significant historic natural countryside’ and stated that the proposed development would break up wildlife habitats and corridors, saying ‘fragmentation and isolation of habitats is hastening the drastic overall decline in species.’ The UK is one of the most nature-depleted countries in the world – in the top bottom 10% for biodiversity – and protecting what we have left is critical.
It is true that new developments must aim to secure a net gain in biodiversity. [There must be an early environmental assessment at very beginning of the planning process.] However, Biodiversity Net Gain [BNG] has been criticised by environmental groups for not delivering on its aims, partly because developers find ways to circumvent the spirit of the legislation. While the Council acknowledges nature decline, they are also willing to rely on the shaky foundation of BNG and that is bad news for Nature.
How will the new town affect biodiversity in Enfield?
A Strategic Environmental Assessment [SEA] is being conducted as required by the Environmental Assessment of Plans and Programmes Regulations 2004. “It provides a high level of protection to the environment by ensuring environmental and sustainability considerations are built into the preparation of relevant plans and programmes that set a framework for development consent”
The results of a Strategic Environmental Assessment (SEA) on all the designated new town sites will be released soon
PLANETARY BOUNDARIES
There are boundaries to how much damage the environment can take before abrupt changes occur and life as we know it cannot be sustained.
“Planetary boundaries” describe the limits to the impact of human activities on the Earth’s life support systems.
If these limits are exceeded the environment may not be able to continue to self-regulate.
There are nine interconnected planetary boundaries. Of these, nature, climate change and water systems in London could be pushed towards their limits by building on greenfield land for Crews Hill & Chase Park New Town.
The impact on nature and biodiversity loss is explained above in WHAT PROTECTION IS THERE FOR NATURE IN ENFIELD?
It’s not that housing cannot be built, providing homes is essential. But building to the extent planned, up to 21000 homes on 884 acres of countryside, could remove greenfield landscapes that help cool the city, store carbon in soils and vegetation, slow and soak up rainfall, and support ecological networks.
The London Plan requires Whole Life-Cycle Carbon Assessments which usually, and importantly, focus on the carbon in buildings and materials. But the full carbon consequences of building a new settlement on greenfield land is rarely captured in this analysis.
The one-off loss of soil carbon and biomass from land take, or the ongoing loss of carbon sequestration when farmland, grassland, hedgerows and mature trees are replaced by sealed surfaces and managed landscaping, are rarely included. For a proposal of this scale, such omissions matter greatly.
There is a concealed carbon cost to building at scale on green fields which should be appraised before any decision is made.
Such land use change is avoidable with brownfield first approaches.
Similarly, we need to know about the impact of the loss of green space on the urban heat risk. And whether this can be mitigated by an overheating and canopy strategy,- mandating high tree canopies, shade, cool routes, and connected green and blue corridors and secure long-term maintenance within plausible financial and time limits.
Fresh water matters in a city where water resources are already stretched.
We need to know about the flood risk of a new town on green fields and the financial credibility of incorporating a mandatory, and effective, flood and drainage strategy committed to greenfield runoff rates and integral sustainable drainage, with guaranteed long-term maintenance.
The two closest stations are on the very perimeter of the proposed site, so everyday distances are long. And because public transport upgrades arrive late, high car ownership is very likely to become embedded causing unnecessarily high carbon emissions, further reducing climate resilience.
A clear transport plan with enforceable outcomes is also necessary, because transport is decisive for both emissions and resilience.
If a new town is promoted as sustainable, all these requirements must be evidenced and secured early, not assumed and dealt with later.
Without that, the scheme risks breaching the spirit of “planetary boundaries” thinking: pushing additional pressure onto climate, nature and water systems, when lower-impact options exist through brownfield delivery and more efficient use of land.
The Strategic Environmental Assessment (SEA) of the New Town proposals is due to be published soon, followed by a short consultation process. The Environment Agency asserts that “The SEA process will assess the likely significant environmental effects of the proposed New Towns programme, alongside reasonable alternatives. It ensures these environmental effects are known, publicised, consulted on, integrated into decisions, and then monitored.”
We shall see.