The second week of Hearings have dealt with employment land, the Green Belt and the Spatial Strategy which underpins the remainder of the Plan.
The Council should consider reasonable alternatives when deciding on sites for housing and employment land. Whilst this seems to have happened for housing, there was discussion as to whether this was also applied to employment, with the Council saying it had and others pointing to the lack of evidence. The Plan also seeks to create new office space at Meridian Water, but those representing IKEA said that there was no demand. IKEA also suggested that their site could accommodate more housing than Enfield proposed. The Council noted several times the considerable loss of office space in the Borough since 2015 under permitted development rights. However, it had the power to control this and was urged to do so by many organisations, including The Society, but declined.
The second day was spent looking at the Green Belt. This attracted a large number of Groups to the Hearing as well as a significant number in the audience. The Council were challenged about the way sites were assessed which would have prevented Green Belt release but claimed all those that had been suggested had been examined. The Society had noted a large (and unaccounted) area of employment land use at Meridian Water which if included would have prevented the need for Green Belt sites for logistics. The Council argued that this was not a mistake and in a complicated exchange with the Inspector, it appeared to be a “maths” interpretation. A number of Groups stressed that the capacity of brown-field sites had not been maximised, but the Council argued it had “optimised” sites.
There was also discussion around the role (if any) that the December 2024 NPPF should have in the consideration of the Plan which takes a different view about “grey belt”. Although the Plan is being examined under the December 2023 version, the Council argued that it should take account of the new provisions.
The Council said that harm to the Green Belt was just one factor among many when considering sites and that in itself it was not a bar to allocation. When considering if sites were isolated, again a number of factors were considered including access to local services. Objections to Green Belt sites have included factors such as poor public transport but the Council have taken a broad interpretation of this. The Inspector asked if sites were well served by public transport or could be and in response the Council’s consultants said that it was both.
There was a lot of discussion about the amount of family housing as various figures appear in the Plan, ranging from 40% to 70%. It was the Council’s view that 40% was a minimum and that a higher figure was an aspiration.
To release land from the Green Belt the Council is required to provide ‘compensatory improvements’ to land elsewhere and the Council are proposing a new Country Park on the northern section of Vicarage Farm, alongside Hadley Road. The Inspector asked if the Country Park was compensation for all the Green Belt releases or just Chase Park and Crews Hill. The Council confirmed it was compensation just for the Chase Park and Crews Hill and that other areas would be identified in the future. The land where the new Country Park is proposed is owned by Comer Homes and they confirmed that they had no intension to build on the land and for it to remain in the Green Belt as farmland.
Finally on day 2 the Inspector questioned the Council on why the Plan included three sites in the Green Belt for purposes which otherwise did not need to be explicitly identified in the Plan. (Sloeman’s Farm burial site, Whitewebbs for recreation/sport purposes and A10/Church street for a crematorium.) His questions were prompted because he had noticed that buildings were proposed for all three locations.
The final day was spent examining the Spatial Strategy. Again more documents were identified in the discussions which the Inspector has asked for. This included an updated Statement of Common Ground with TfL as TfL continue to argue that Chase Park and Crews Hill have not been proposed with appropriate policies for sustainable travel. One such policy highlighted was car-parking provision, where TfL want to see a much lower figure than the proposed 1.5 spaces per dwelling.
The Council said they were satisfied that the costs of the mitigations of transport problems identified could be met, though the detail still needed to be worked on. The Council’s view was that costs had been tested through the Whole Plan Viability Assessment but further work was being done.
There was discussion about the transport modelling which had been undertaken and which has been criticised by Broxbourne Borough Council who’s own modelling suggested increased congestion on the A10 which the Council’s assessment contradicted. In reply the Council pointed to Statements of Common Ground with both Highways England and Hertfordshire County Council where no concerns were raised.
There was a discussion about Whole Plan Viability. The Council confirmed that a comprehensive and standardised approach had been taken which assumed £50k per unit contribution to costs but agreed whether the figure was correct for Chase Park and Crews Hill. In the Council’s view there were no extraordinary costs associated with the Plan. The Council had also tested £75k per unit and said it had a small effect on the affordable housing numbers. The Council offered the details of the extra testing to the Inspector and the Council’s consultants for this subject, HDA, confirmed that all the costs including bridges, transport, schools and open spaces had been factored-in.
Next steps
At the end of the final day the Inspector set out the future time-table for the Examination. As Steven Lee is also working on the Bristol Local Plan there is likely to be an enforced delay until May. In the meantime he will assess the extra documents that he has asked to see as well as any new Representations which were omitted from the database and which the Council has now committed to sorting out by the end of March.
The Inspector said that the next stage in May will look at the site allocations in detail and this suggests that he is not yet minded to eliminate any parts of the Plan.
Further reading
You can read The Enfield Dispatch’s report on the Green Belt discussions here: enfielddispatch.co.uk/high-harm-to-green-belt-caused-by-housing-plans-enfield-council-admits/