Thursday, 7 July 2011

David Burrowes MP's submission to the 'North London Waste Plan'

(The ten footniotes are listed, most of them with web links, at the end of the document.)

Archie Onslow
North London Waste Plan
Camden Town Hall
Argyle Street
London, WC1H 8EQ
Wednesday 6th July 2011

I am writing to formally object to the legal soundness of the 'North London Waste Plan', published May 2011, on the following grounds:

1. The consultation process has not allowed for effective engagement of all interested parties, and the evidence base therefore lacks justification
2. The plan’s chosen approach is not appropriate given the fact that it is not supported by one of the seven boroughs; therefore it is undeliverable and unsound under PPS12.
3. Due to the detrimental impact of the site on the local area the site could not possibly be consistent with ‘Policy NLWP 4 – Protecting Amenity’, and therefore the plan is not deliverable.

1. Lack of consultation with local residents and stakeholders

1.1.The consultation on the North London Waste Plan only consulted with residents within a particular distance from the site, and not those in the area along the North Circular who will be negatively impacted by the heavy traffic attending the depot.

1.2.The original consultation on the draft plan also received fewer than 400 responses for all of the seven Boroughs, which considering there are around 15,000 individuals in the Enfield Southgate area bordering this site, seems wholly insufficient.

1.3.Anecdotal evidence would suggest that very few residents in Enfield were consulted due to the fact that the site itself lay in Haringey, certainly those in the Bowes, Palmers Green and Southgate Green areas felt that at no point had their input been sought on these plans.

2. Deliverability of the North London Waste Plan without the commitment of all seven Boroughs

2.1.Point 4.4 of Planning Policy Statement 12: Local Spatial Planning states that:

“The delivery strategy is central. It needs to show how the objectives will be delivered, whether through actions taken by the council as planning authority, such as determining planning applications, or through actions taken by other parts of the Council or other bodies. Particular attention should be given to the coordination of these different actions so that they pull together towards achieving the objectives and delivering the vision. The strategy needs to set out as far as practicable when, where and by whom these actions will take place. It needs to demonstrate that the agencies/partners necessary for its delivery have been involved in its preparation, and the resources required have been given due consideration and have a realistic prospect of being provided in the life of the strategy. If this is not the case, the strategy will be undeliverable.”[1]

2.2.The North London Waste Plan, which must be in conformity with core strategies, would therefore need full support and engagement from all seven boroughs in order to be deliverable by the above definition.

2.3.It is clear that in regards to Enfield Council this is not the case. I would draw your attention to the following public statements by Cllr. Achilleas Georgiou, Deputy Leader of Enfield Council:
  • Signed a piece of literature with the title ‘NO to Pinkham Way’[2]
  • Signed a letter to a local newspaper in which he stated ‘nowhere in or near Enfield should host further waste facilities: not Pinkham Way’[3]
  • Wrote in a leaflet and on a blog that the Pinkham Way site is ‘morally and ecologically wrong’[4]
  • Stated at a recent public meeting that those authoring the NLWP had ‘made a mistake’ and that he had’ deep objections’ to the Pinkham Way site.[5]
 2.4.It is clear that a rejection of the Pinkham Way site is in effect a rejection of the waste management approach put forward in the North London Waste Plan, and therefore a rejection of the plan itself. Therefore the strategy has failed to set out that each of the seven boroughs ‘have been involved in [the NLWP’s] preparation, and the resources required have been given due consideration and have a realistic prospect of being provided in the life of the strategy’ and therefore the plan is legally unsound.

3. Detrimental impact to the local area and internal inconsistency with NLWP4 – Protecting Amenity

3.1.There are a number of areas where the proposed site at Pinkham Way will not be able to deliver on Policy NLWP 4 – Protecting Amenity, rendering the plan internally inconsistent and therefore legally unsound.

3.2.The Pinkham Way site cannot be delivered consistently with Policy NLWP4 part b[6] due to the high number of waste trucks travelling to and from the site. Although the waste management site itself and the MBT technology it contains will not produce considerable emissions, the pollution and toxins generated by the traffic along the North Circular will be extremely damaging.

3.3.This will be exacerbated by the heavy traffic along this stretch of road, which serves as a vital link from North to Central London. The high volume of trucks will increase congestion to unbearable levels, particularly around the busy Bounds Green junction with the A406. This factor, as well as contradicting point b of NLWP4 Policy, also contradicts point g[7].

3.4.Primarily the site is inconsistent with point d[8] as the scale form and character of the site are not suitable for an area undergoing considerable regeneration. The area surrounding the site has finally secured funding for regeneration and investment, which are summarised in the North Circular Area Action Plan[9] and the New Southgate Master Plan[10]. The proposed site will obstruct the steps put forward in these plans and will therefore not be a ‘good neighbour’.

I wish to formally object to the NLWP on the basis of it being unjustified, undeliverable and legally unsound. The Pinkham Way proposal is in the wrong place at the wrong time and alternatives should be investigated with proper consultation and commitment. Once alternatives are found, I look forward to engaging with a newly formed strategy for the management of North London’s Waste.

David Burrowes MP
Member of Parliament for Enfield Southgate
Member of Parliament for Enfield Southgate
Constituency Office - 1c Chaseville Parade, Chaseville Park Road, Winchmore Hill, London, N21 1PG

Tel: 0208 360 0234
Fax: 0208 364 2766

[6] ‘adequate means of controlling noise, dust, litter, vermin, odours and other emissions are incorporated into the scheme’
[7] ‘There are no significant adverse transport effects outside or inside the site as a result of the development’
[8] ‘the development is of a scale, form and character appropriate to its location and incorporates
a high quality of design’

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