Civic groups unite in opposition to council green belt and tall buildings plans

The chair of the National Park City Foundation and the founder of the National Park City project have today sent a joint letter to Enfield Council leader Nesil Caliskan sharply criticising some of the wording in the draft Enfield Local Plan which suggests that references to the London National Park City in the draft document provide justification for de-designating "considerable areas of London Green Belt in the borough". The letter also reiterates opposition to de-designating any Green Belt land in Enfield.

Copy addressees include senior figures, starting with the Mayor of London, Sadiq Khan.




Councillor Nesil Caliskan Leader
London Borough of Enfield
Civic Centre
Silver Street
London EN1 3XA
By email

14 July 2021

Dear Councillor Caliskan,

London Borough of Enfield and London National Park City

We write on behalf of the National Park City Foundation, the charity behind London National Park City to point out recent remarks which we consider misappropriate and misrepresent London National Park City and its status, and to ask that you and Council colleagues rectify so that future references to London National Park City and its aims and status are accurate.

We should be pleased to meet you and colleagues to explain the points in this letter. Equally, should there be any questions arise we should be pleased to discuss and clarify those to overcome any misunderstandings and reach a position where we can work together productively.

Our concerns centre on the London Borough of Enfield’s preferred option to de-designate considerable areas of London Green Belt for housing and its use of London National Park City in justifying and making the case for that policy.

As we understand the proposal, the London Borough of Enfield has justified its proposed loss to development of Green Belt in the borough on the basis that remaining Green Belt would be improved as part of London National Park City.

That is a misreading of London National Park City, which is about the entire urban realm and fabric, not just parks, green spaces. We appeared at the Examination in Public (EiP) into the new London Plan in defence of London’s Green Belt and Metropolitan Open Space, attending the same session as Enfield Council representatives. It should therefore be clear to anyone at Enfield Council that London National Park City does not support the loss of green space not least Green Belt. It is therefore misleading for the London Borough of Enfield to refer to London National Park City in writing or verbally as part of justifying its proposals for the loss of Green Belt.

We note numerous references in Enfield Council’s Local Plan to London National Park City including the dedicated policy 3.7 on page 70, which we would normally be pleased to see. While the Council’s proposals for the restoration of Enfield Chase appear laudable and the planned enhancements for public access seem ambitious, they are not a justification for the loss of Green Belt, which we do not support, and which both government planning policy and the new London Plan aim to avoid.

Paragraph 3.8.8 on page 71 of the Enfield Local Plan states that “The designation is not strictly a national park...”. To be both clear and correct, London National Park City has no formal planning or legal status and neither has nor seeks the kind of planning role of the established National Parks.

Any comparison with England’s 10 National parks established in law is only valid in terms of applying the kind of thinking at the heart of National Parks to start reversing London’s declining environmental conditions which have a bearing on learning, health, fitness, recreation and community. Planning policies must start improving life in London, including protecting and restoring nature and ecosystems, not finding new ways to justify deliberate choices to allow their further erosion.

Along with all Local Planning Authorities in London the London Borough of Enfield already has the powers in planning rules to set the policies and supplementary guidance to ensure protection for existing green and blue spaces, including both Green Belt and London’s unique designation of Metropolitan London Land (MOL).

It is incorrect and misleading for anyone to imply or state that London’s National Park City status can provide any form of protection for land, features or natural assets either extant or in the future. London National Park City does not confer any protection of existing or remaining Green Belt neither does it provide any assurance that future threats either from further development pressures or from the application of Local Planning Authority policies.

It is also not clear to us from reading the Local Plan how future Green Belt in Enfield borough would not also come under pressure for the very same reasons used in the recent justifications.

Paragraph 3.8.9 also on page 71 adds that “The National Park City designation has the potential to achieve a net increase of 25% green cover in Enfield...”. Serious application of London National Park City thinking can and should lead elected members, officers and others involving in forming, setting and applying policy, to make better decisions, but it cannot make up for political decisions which require the loss of green space, space for health, recreation, learning and nature.

As London National Park City is also about the entirety of London, not just the parks, green spaces and Green Belt, the London Borough of Enfield and all Local Planning Authorities in London should be examining the entire urban fabric and should avoid using National Park City as a bargaining chip to justify loss of Green Belt and green space.

We very much welcome where Local Planning Authorities seek to make the most of London National Park City. We can help LPAs do that well in ways that fully respect and avoid misappropriating the purpose and aims of London National Park City, including the contribution of the many thousands of people, organisations and companies that made it happen.

On 21 and 22 July we mark two years since London became the world’s first National Park City and you and your colleagues would be very welcome to join in any or all of the events to find out more: https://www.nationalparkcity.london/week2021

We look forward to hearing how you and your colleagues will rectify matters and ensure accurate references to London National Park City from now on to our satisfaction.

Yours sincerely,

Paul de Zylva
Chair
National Park City Foundation

Daniel Raven-Ellison
Founder
National Park City

cc:
Sadiq Khan, Mayor of London / Shirley Rodrigues, Deputy Mayor, Environment
Ruth Knight, GLA
Elected Members, London Borough of Enfield
Ian Davis, LBE Chief Executive
Sarah Cary, LBE Executive Director Place
London Green Belt Council
London National Park City network contacts in Enfield borough

For the second week running council leader Nesil Caliskan finds herself the addressee of an angry letter from a charity leader. Last week it was the National Park City Foundation writing, this week the head of campaigns at CPRE London, the London branch (!) of the Council for the Protection of Rural England.

Alice Roberts is strongly critical of the leader's claim, quoted in Enfield Dispatch, that unless Green Belt land is used for new housebsuuilding, the only alternative will be to "[pack] people into small units in dense towers with a lack of access to open space and supporting infrastructure". On the contrary, she argues that it is proven that there is sufficient brownfield land to satisfy requirements and that building on the greenfield sites allocated in the draft Enfield Local Plan would produce precisely those shortcomings of supporting infrastructure and the lack of public transport provision that will work against the need to create low-car or car-free development.

The full letter can be read on the CPRE London website .



The Enfield Dispatch report containing the quote which upset CPRE London was published on Tuesday. It is based around the letter reported by PGC last week and the council leader's reaction.

My attendance at a Local Plan consultation was illuminating. The small “crowd” included a majority of councillors and linked parties from Cuffley. They were against the housing plans for Crews Hill on the basis train seats from Moorgate would be full. But still OK going into town I suggested, and they agreed. More particularly I was able to ask my question, “why if there is apparently enough brownfield land available are you looking only at that so far listed in the plan for housing, eg Sainsbury at Winchmore Hill?” And the main reason it seems is that such land has to be seen to be “deliverable” by the Planning Inspectorate, so if the owner has not put it forward for consideration, or a few other technical points, it can’t go in without it risking the whole plan being failed on examination. That will be the reason for the “Call for Sites” inevitably included in such exercises.

Very interesting comments on the brownfield sites and the rational for their choice. I think that the so called brown field sites are in many cases local assets, just as much as green space, which the community would be poorer for if they become housing developments. I take it from Karl's comment that the supermarket sites listing in the plan are supported by their owners, and given the rush to buy up supermarket chains by venture capitalists selling of such sites is likely to be pushed. I note that some at least are marked as suitable for mixed development which at least suggests that some retail could remain, but who would enforce that? Do I remember that there are more supermarket sites identified in the west of the borough than the east; if so this might be influenced by the opportunities to build higher priced and more profitable housing in the west?

We already face the loss of sites to housing such as the Colosseum retail park on the A10 , and the Brunswick Park site just over the boundary in Barnet, which will lose local employment and service/retail assets used by local residents.

The once flourishing garden centre focus of Crews Hill is a shadow of its former self; discovering that developers had already bought up the land could partly explain why the decline has been so marked. Nothing will bring this back, and although it sticks in my throat to say so, and it will reward developers who will not build affordable homes, might it be an acceptable trade off to build on some of the greenbelt and keep some of the useful "brownfield" sites as they currently exist?

What is not clear to me is whether once the plan is approved, can anyone control where development takes place? Will we lose both green and brown sites?

Looking at Colin’s comments, the London Plan forecasts a 30% or so surplus in London’s retail space as a result of on line shopping and other trends. Large retail parks such as on the A10 were identified as fit for (housing) redevelopment at that time. For the more local Sainsbury and the like I imagine there could be a strategic view that on line is headed in only one direction, driving less big weekly type shops but instead more small shop top-ups to the home delivery, thus helping make huge footprints (store and tarmac) at eg Sainsbury Winchmore Hill a costly asset to maintain. It seems to me better such surplus is pulled from retail parks and big supermarkets rather than high streets with their broader community purpose.
On the plan, my understanding is that once agreed normal planning processes would still need to be followed but that may be different should Enfield fail to meet its annual statutory house building target – pretty much equivalent what the plan seeks to build over its term I believe. At such a stage I have a recollection of reading of possible government intervention and a weight given to developers to get on with it. How Wild West that may be I don’t know or the specifics driving such government action.
But overall given the statutory (as well as moral) need to house people, we seem to have options to build up (hasn’t gone down well so far), build out (isn’t going down well), or knock down parts and re-plan with a denser housing landscape (I think Haringay tried that recently without success and a lot of damage to politicians and the host community). There’s no easy solution and we shouldn’t pretend there is, however often simply build on all this apparently available brownfield land gets trotted out. Probably useful if someone identifies just where it is and if it’s deliverable rather than simply talking about it in the generality.

Picking up the thread of local assets impacted in the draft Local Plan and now drawing from a recently published appraisal of Tesco’s direction might give some insight to the thinking behind several of our local supermarkets apparently not having a future.
“Instead of having to get in the car and make the weekly trip to the supermarket, customers can now shop whenever, wherever and however they want.”
On line is served via in store picking and Tesco are now building local fulfilment centres to bolster this.
The convenience market has seen rapid growth in the last few years and in Tesco’s case is served by 2000 Express stores plus 950 owned and franchised One-Stop stores. “This is where the bulk of store investment will go, in finding new sites and adding new franchisees, as the firm aims to become more ‘capital light’. That means no more expensive, out of-town megastores.”
Tesco is also piloting on demand services for deliveries within 60 minutes, while urban fulfilment centres have the potential to allow customers to order a full weekly shop and collect it minutes later.
All the well-known names will have their own strategies but all are going to be operating in the same environment which does appear to be one which is looking to be ever less reliant on an own-car based big shop at a big store, but instead smaller, more frequent baskets which are instead and increasingly brought to you. On the flip side I guess it could be an opportunity for our high streets / town centres