Enfield RoadWatch Action Group

Background information for consultation response

This document includes comments that you can use in your responses to the Consultation questions and some background information. The question numbers are taken from the printed version of the Consultation.  For some reason, a different numbering system is used for the online version, but most of the same topics appear. The suggested responses can be found between the red ‘Response start’ and ‘Response end’ notes. Background analysis can be found in blue.

The most important question to respond to is Question 14 – Enfield’s Green and Blue Spaces.

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Q1 Current Local Plan

Response start
I have identified the following policies that are still Relevant because they highlight the importance of and/or protect the Green Belt:

Core Strategy: 7, 8, 9, 11, 12, 13, 20, 21, 25, 30, 31, 33, 34, 35, 36.
Development Management Document: 59, 61-65, 72-75, 77, 82-91

The following policies that relate to the Green Belt need to be changed:
Core Strategy: 29 and 32 should be changed to reflect the importance of the Green Belt to these functions.
Development Management Document: 71, 78, 79 and 80 should remove the loopholes that make the stated protection dubious.

Several policies in both documents need to be changed to allow changes of land use [excluding the Green Belt] that would permit mixed use development.

Response end

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Q2 Are there any sites that you would like to see identified as a site capable of contributing towards Enfield’s overall development needs?

Response start

1. NO GREEN BELT SITES SHOULD BE CONSIDERED FOR RELEASE. GROWTH CAN BE ACCOMMODATED ON PREVIOUSLY DEVELOPED LAND/ BROWNFIELD.
2. Enfield RoadWatch and CPRE-London have compiled a comprehensive register of brownfield opportunities of all types and sizes which shows sufficient sites for housing and infrastructure during the plan period and beyond.
3. The A10 Retail Parks and Southbury area should be masterplanned before piecemeal development picks away at the prime sites. With increased train service, this area could provide a new mixed-use community of many more homes than Meridian Water.
4. Enfield’s Strategic Industrial Locations [SIL[ need to be masterplanned so that areas closest to public transport can be released for mixed use development, while other areas can be intensified through stacking or better land-use, with no loss of employment.

Response end

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Q3 Key Priorities in the draft New Local Plan 2036.

Response start

a) All the options listed on page 9 are worth exploring, except for the final option which suggests revisiting the Green Belt boundaries, which is unnecessary, given that a robust, thorough and professional boundary review was conducted, approved and adopted in 2013. To quote the Council itself: The review’s primary objective is to provide for a strong defensible Green Belt boundary that will endure and protect the openness and rural character of the surrounding countryside of Enfield from encroachment. 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. Another boundary review should not be needed until 2028 at the earliest.

b) The Council should explore the development opportunities offered by possibe increased service on the Liverpool Street – Cheshunt line, which would allow some development and improvements on suitable sites at Southbury and Turkey Street Stations, in addition to Edmonton Green. It should also explore the possibility of reinstating the Carterhatch Lane Station on this line between Southbury and Turkey Street, to permit some development in that area.

c) The Local Plan revision should not be used as a reason to release Green Belt. It is unnecessary.

d) Please see my response to Q2.

e) The suggested options will definitely contribute to the accommodation of Enfield’s growing population. However, these options need to be combined with creative masterplanning of several large sites, including the Southbury/A10 corridor, Brimsdown and Edmonton Green and its surrounds, and more estate regeneration, all in conjunction with transportation upgrades. All these solutions together will not only provide good homes for the borough’s residents, but will create new vibrant communities and improvements in deprived areas. THERE IS NO NEED TO BUILD ON THE GREEN BELT!

Response end

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Q4 Enhancing Heritage & Culture that define Enfield now and in the future.

Note:  The underlying policy covers landscape too, mentioning existing characterisation studies and the importance of historic land-use patterns.  It is therefore important to respond.

Response start

a) Yes!

b) The options are not clear, but I would support a policy that values and protects Enfield’s heritage and culture.

[Skipping c, d and e]

d) Hard to answer without a definition of ‘appropriate’.

Response end

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Q5 Design Excellence

Note:  This section does have a bearing on the Green Belt because it relates to housing density.

Response start

a) Yes

b) Depends on the location

c) Yes

Response end

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Meeting Enfield’s Housing Needs

Note:  This next section is tricky.  The draft local plan has a lot of information that is not reflected at all in the consultation.  For instance, on page 84 of the draft local plan they claim:  Whilst development should be prioritised on brownfield land, a Green Belt Review to establish whether land could be used to make a positive contribution to sustainable growth in a planned way is supported.  The 2015/16 consultation showed  82% of respondents against development on the Green Belt so the support for a new review was minimal.

Q8 Self-build sites

Response start

Please refer to my response to Q2 about the brownfield register.

Response end

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Q10 Promoting a competitive economy

Skipping a) and b)

c) On land protected for industrial uses in Enfield, which sites would benefit most from intensification for employment and/or mixed use?

Response start

c) Please refer to my responses to Q2 and Q3.

Response end

d) Are there any not previously identified sites in Enfield that would be suitable for industrial purposes?

Note:   The draft local plan states:  6.2.15 It is impractical to suggest that the scale of new employment land required could be found within the existing urban areas and therefore whilst at the same time assessing the land requirements for new housing in the Green Belt we also need to consider what if any industrial land might need to be delivered in the Green Belt if the relevant strategic requirements are to be met.

Response start

d) Industry should not be moved into the Green Belt. Additional employment space can be achieved by mixed-use development and intensification of existing industrial sites.

Response end

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Q13 Community and Social Infrastructure

Skip a), b), c).

d) Which infrastructure has the greatest potential to be co-located within larger multi-purpose buildings which can adapt to various uses? For example, schools and residential, schools / community facilities dual use, health facilities and libraries?

Response start

All of the above, plus leisure centres, Council offices, transport hubs and retail.

Response end

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Q14 Enfield’s Green and Blue Spaces

Note:  Some tricky questions here!    First, the consultation is using the term ‘open space’ inconsistently throughout the document.   All Green Belt is open space but not all open space is Green Belt or MOL.  The draft local plan makes a distinction between open space, Green Belt and MOL. For example, P159.  Together with the Green Belt and Metropolitan Open Land (MOL), open spaces are integral to the character and image of the borough.   But the consultation throws them all in together so the questions are hard to answer accurately. 

Also, it sells the benefits and distinctions of the Green Belt short and does not allow for comment on the proposed Green Belt Boundary Review, so responses should stress the benefits and the fact that the review is not needed.

Skip a) and b

c)  Is the quality and accessibility of open and blue spaces more valuable than the actual quantum?  Note:  This is a tricky question!

Response start

c) The importance of open and blue spaces cannot be judged by their quality, accessibility or size. Open spaces serve a wide variety of purposes. In addition to the traditional five purposes of the Green Belt, a long list of environmental, economic and social benefits have now been identified including:
• Creating a sense-of-place and facilitating community cohesion;
• Increasing physical activity for adults and children;
• Adapting to climate change through CO2 absorption, shading or flood alleviation;
• Improving mental health;
• Creating more attractive places to work, live and visit;
• Encouraging active transport like walking and cycling;
• Improving air quality;
• Improving water quality by reducing harmful runoff into local rivers; and
• Enhancing biodiversity and opportunities for wildlife.

Therefore, open spaces, including Green Belt sites, which may appear inaccessible or of low quality, are in fact serving very important functions. For these reasons, all our Green Belt sites should be preserved and protected. I would also like to reinforce my response to Q2 that another Green Belt Boundary Review is unnecessary because the 2013 review is still valid.

Response end

d)  Are there any designated open spaces that do not properly serve open space functions and could be improved or even re-designated for other uses?

Note:   Another tricky question that is impossible to answer because different open spaces have different functions and most serve environmental and ecological functions that may not be obvious to the casual observer!  Refer to previous response.

Response start

I refer you to my previous response. Open spaces, including the Green Belt, serve many functions and should be preserved and protected.

Response end

e)  Where an existing open space has no reasonable prospect of being fit for purpose should the Council consider its redevelopment to help fund improvements to other open spaces? yes/no – please explain your answer.

Note:  As with c) and d), this is impossible to answer, because fit for purpose is not defined.   These three questions appear to be targeting the Green Belt without saying anything about the Green Belt, so we need to make the case for no release!

Response start

e) I refer you to my response for section (c).

Response end

Skip f) and g)

h)  To what extent and how should development contribute to increased biodiversity? Note: Finally one that’s easy to answer!

Response start

h) It can contribute a lot by not building on the Green Belt!

Response end

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Q16 Sustainable infrastructure and environmental impact

a) What interventions should the new Local Plan prioritise to make Enfield a more sustainable place in the future?

Response start

a) Protect the Green Belt and don’t suggest building on it!

Response end

Skip b), c), d).

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If you choose to email or post your response, please make sure to include your name and address and, if you decide to use some or all of our comments, please include the line: ‘The comments provided in my response to this consultation are my own views.’ Thank you!

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