Sunday, 23 October 2011

Pinkham Way Alliance: Responding to the Haringey's 'Core Strategy' re-consultation

"We hope as many people as possible will respond individually to this consultation, and we have put together a series of points (below) to consider, in your response to Haringey. 

"It is important to emphasise that the response to this consultation should be limited to the question of the redesignation of the Pinkham Wood site, the danger to the site's nature conservation status caused by any planned development, and the soundness or otherwise of Haringey's evidence for it. 

"Comment can be made about the way the consultation itself has been conducted, but please note that comments should NOT cover traffic and congestion, pollution and air quality, proximity to homes and schools, or problems about recycling and waste management. There will be a chance to comment on these aspects of the issue, when consultation takes place on the planning applications next year.

"The Pinkham Way Alliance is also preparing a response based on our points below, and if you prefer, you can add your name to that by signing up through this online form before 2nd November 2011."

Points to consider for response to re-consultation on Haringey's Core Strategy

"Haringey Council are re-consulting about its proposal to re-designate the Former Friern Barnet Sewage treatment site (Pinkham Woods) from:
EL - Employment Use
(subject to no adverse impact on the nature conservation value of the site), to:
LSIS - Locally Significant Industrial Use
(with no linked protection for the nature conservation value of the site)
"The implications of this are:
  • the loss of the caveat to protect the nature conservation is a major change to the protection this site would receive, and consequently there is a likelihood of losing this valuable nature conservation site, which is one of only nine sites designated Grade 1 of Borough Importance for Nature Conservation
  • It will widen the range of uses on the site to include heavy industrial type uses, with all their potential noise, pollution and traffic congestion
  • re-designation would mean the site would become vulnerable to Policy 4.4 of the London Plan, which directs local authorities in London to identify Locally Significant Industrial Sites which might be suitable for waste management. If the site was not re-designated LSIS, it would not fall within this policy."

"We strongly object to this re-designation for the following reasons:
  • It is not based on robust or credible evidence. No credible evidence was produced at the Examination in Public, and the re-consultation document CSSD-3 has no new evidence. The updated Sustainability Appraisal which has been produced by Hyder Consulting UK Limited to provide further evidence in support of this re-consultation does not contain any new evidence to support this re-designation; on the contrary, it points out the threat to the biodiversity of the site (see below).

    In the Core Strategy pre-submission draft, the site was designated Employment Land, with supporting evidence for this designation. Why did the Council change the designation following consultation? What evidence emerged, to persuade them the designation should be changed to LSIS? By their own admission, 'pre-application discussions' have influenced this re-designation.

    Barnet Council's existing Mill Hill depot
    These discussions relate to the proposal by North London Waste Authority and Barnet Council, to construct a massive MTB waste processing plant (to deal with up to 300,000 tonnes of waste per year), and Barnet Council’s proposal to relocate its refuse vehicle depot (for vehicles it uses for waste collection and passenger transport and for parking space for Barnet Council’s fleet of refuse/recycling and staff vehicles, plus a small office/storage building and a refuelling station)
  • There is no evidence that Haringey considered whether this was the most appropriate strategy against alternatives such as Metropolitan Open Land designation, alternative Local Green Space designation (or local SLOL designation?) or Green Grid cross-boundary green space, connecting Barnet, Haringey and Enfield
  • It is not consistent with national policy: PPS 9 is the overarching framework in which policies should be developed - particular para 9 which states that networks of natural habitats provide a valuable resource
  • It does not accord with Regional Policy: See The London Plan, in particular Policy 7 (7.14 and 7.18-7.21)
  • It is not deliverable: The LSIS designation is only deliverable if the Grade 1 Borough Importance for Nature designation is removed or substantially compromised. The Council’s own additional evidence points out, in relation to the Friern Barnet site in particular, that any development on the site has potential to have biodiversity impacts, because it is a Site of Importance for Nature Conservation (p.6 of Hyder Addendum SA). The bigger the development, the bigger the impact.
For all the above reasons, the re-designation is not soundly based."

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