Dear Enfield Council
Re. Response to the Local Plan Issues and Options Consultation
Thank you for the opportunity to respond to this important consultation.
While I support housing development and support the ambition to meet Enfield’s housing needs, I strongly object to the proposal to release Green Belt for housing or other purposes. My responses to the consultation questions below reflect my beliefs that there are alternatives available to meet housing targets and that the Green Belt is a precious resource that should be protected and preserved for future generations.
Question 1 –
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
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.
Question 2 –
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.
Question 3 –
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 possible 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!
Question 4 –
b) The options are not clear, but I would support a policy that values and protects Enfield’s heritage and culture.
d) Hard to answer without a definition of ‘appropriate’.
Question 5 –
b) Depends on the location
Question 8 –
Please refer to my response to Q2 about the brownfield register.
Question 10 –
c) Please refer to my responses to Q2 and Q3.
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.
Question 13 –
All of the above, plus leisure centres, Council offices, transport hubs and retail.
Question 14 –
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.
d) and e) I refer you to my previous response. Open spaces, including the Green Belt, serve many functions and should be preserved and protected.
h) It can contribute a lot by not building on the Green Belt!
Question 16 –
c) Protect the Green Belt and don’t suggest building on it.
I look forward to a Draft Local Plan that has creative solutions and does not target any sections of the Green Belt for de-designation.
The comments provided in my response to this consultation are my own views.