28th June 2011:
Haringey Core Strategy Examination in Public
Written Representations on behalf of Mr. Stephen Brice [our bold emphases below are not in the original]
Dear Mr Brice,
I refer to the letter dated 1st June 2011 received from Knights Solicitors on behalf of Mr. Stephen Brice (a member of the Pinkham Way Alliance).
The Council would like to clarify the following points as set out in your letter:
1. Change of site allocation from employment to industrial use
- Friern Barnet site has a 'Defined Employment Area - Employment Location' designation in the UDP 2006. This designation includes “B” uses, but also provides flexibility to “non-B” type employment generating uses, such as retail, leisure, creative and cultural industries.
- Friern Barnet site is designated as a 'Local Employment Area' in the Core Strategy Proposed Submission draft May 2010, as land that is suitable for “B” uses. It also offered flexibility for other employment generating uses. The Core Strategy Proposed Submission draft was consulted on in May/June 2010, according to planning regulations, and there were no objections to the designation for the site, which included “B” uses.
- Strategic Policy SP8 of the Proposed Submission stated that the Council had identified other employment generating sites which would benefit from concentration of employment generating uses, or mixed use, including residential and community facilities. The policy stated that the redevelopment of these areas would ensure that there will be no overall loss of employment generating floorspace.
- The Council felt that the wording was not clear enough, and some of the sites which came under this designation were not suitable for this level of flexibility. If the Core Strategy Proposed Submission draft designations were left unchanged, the concern was that this would lead to applications for uses which would not be suitable for their location. This also accords with the London Plan, and the DRLP.
- Therefore, the Council decided that Friern Barnet site and the Bounds Green site needed stronger employment land designation. They were designated as 'Locally Significant Industrial Site' (LSIS). This approach also accords well with the concept of sustainable communities. Both of these sites are in the west of the borough, where there is comparatively less industrial land availability. The fundamental changes document (Nov 2010) was consulted on, according to planning regulations, and there were no objections to designating this site as a LSIS.
- In summary, “B” type industrial uses can be located in the Locally Significant Industrial Site designation. “B” type uses can also be located in the Local Employment Areas- Employment Land. Where LSIL differs from the LEA is that it does not offer flexibility for non-B type employment uses.
- The Council, when reviewing the designation for Friern Barnet site, also took account of the 'North London Waste Plan preferred options'. The designations in the Core Strategy need to provide a planning framework for the next 15 years, and should not remove flexibility for other emerging plans, or major infrastructure needs.
- Taking these into account does not mean that the Council has declared the site as a waste management site, ahead of the North London Waste Plan adoption, or that it already made its mind up about the site as a waste management site ahead of a planning application.
- Regarding Mr Brice’s objection in paragraphs 7.7 and 7.8, Haringey’s proposed changes to Friern Barnet site are not based on the GLA response, or the one from Nathaniel Lichfield and Partners on behalf of SEGRO. The reference to these consultees in paragraph 7.7 of Mr. Brice’s letter refers to the fact that both parties made comments to SP8 during the consultation, specifically to other sites within the Locally Significant Industrial Sites (LSIS) category.
- The 'Focused Changes Schedule' (as submitted in March 2011) was produced to document the changes arising from the additional regulation 27 consultation; it does not provide the reason for changing the employment land designations.
- Therefore, the Council considers the argument put forward by Mr Brice for the Pinkham Way Alliance for the land designations for Friern Barnet site [is] a superfluous one.
2. Removal of designation as Site of Borough Importance for Nature Conservation (Grade 1)
- The Council can confirm that they have not removed the nature conservation designation of the Friern Barnet Site.
- In line with the Town and Country Planning (Local Development) (England) Regulations 2004, Haringey submitted for examination along with the Core Strategy, proposed changes to the proposals map (document reference CSSD-04). The series of map extractions and the corresponding table show up-to-date changes to the current UDP Proposals Map, and acts as a link between the current UDP Proposals Map, and the envisaged Proposals Map which will accompany the Core Strategy. If there [were] a change proposed to the nature conservation designation of Friern Barnet Site it would have been shown here.
- The Council does recognise the error on Figure 6.2 of the submitted Core Strategy (chapter 6.3 on Open Space and Biodiversity). This map is intended to be illustrative only, and does not show all of the borough’s open space and biodiversity designations. This error will be corrected as part of the Core Strategy hearing process, and with the Inspector’s agreement, the Council will revise this map to show the correct information, to be included in the adopted Core Strategy.
- To summarise, the Council [is] not proposing to remove the nature conservation designation at Friern Barnet, and Figure 6.2 of the submitted Core Strategy will be corrected to include all of the borough’s open spaces and biodiversity designations.
3. Haringey’s consultation process
- The Council’s analysis of the formal representations received during Regulation 27 Consultation (May/June 2010) showed that the responses fell into two broad categories: minor amendments, and fundamental policy changes. The minor amendments simply clarify the Council’s policy intent, correct typographical errors, improve referencing, or update supporting evidence. None of these amendments significantly affect the policy direction, or soundness of the Core Strategy.
- Representations that made fundamental points about our policy direction, soundness, or new evidence base which has been issued following consultation, led to the need for the Core Strategy to be re-consulted on before, being submitted to the Secretary of State, to ensure that the document is sound. Following new evidence, the affordable housing policy and employment land designations were revised, and re-consulted on from 4th November until 2nd December 2010.
- Notification of the additional regulation 27 consultation, outlining the purpose and process, was sent to those who made representations during the previous stage of consultation in May/June 2010, and those businesses affected in the Defined Employment Areas (DEAs). The consultation details were also posted in local newspapers; Tottenham and Wood Green Journal and the Hornsey Journal, and on the Council website.
- The Council’s Statement of Community Involvement (SCI) does not set out specific procedures for consulting on additional regulation 27 documents however; the consultation that was carried out was targeted to the participants who specifically expressed an interest in the initial regulation 27 consultation, and those local businesses affected by the changes to the DEAs. The four-week consultation period was deemed appropriate to the type of consultation document, i.e. it was a proportion of the Core Strategy document, and aimed at a target audience.
- Paragraph 2.1 of the Council’s additional consultation addendum (document reference CSSD-03) specifically sets out the guidance in which the Council followed, when proposing the changes to the Core Strategy. Issues like general conformity with the London Plan, consistency with national guidance, whether the changes were consistent with other relevant plans and strategies, and whether they resulted in any further environmental, economic or social implications not already covered in the Sustainability Appraisal, were all taken into account.
4. The Sustainability Appraisal (SA) Process
- A Sustainability Appraisal was undertaken on the revisions to the employment land designations, and found no significant effects, as a result of these policy changes. These changes are supported by the Submission Core Strategy Sustainability Appraisal. Results of this appraisal can be found on pages 138-143 of the Submission Core Strategy SA Appendices (document reference CSSD-06).
Haringey Planning Policy Team
5th July 2011:
The 'Pinkham Way Alliance' response to the above letter is here.
"... In all circumstances, it will remain fundamentally unsound for the Core Strategy to change the Friern Barnet site's existing designation for 'employment generating uses, subject to no adverse effect on the nature conservation value of the site', and to designate the site instead as being suitable for any form of industrial use."
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