THE LONDON PLAN: THE SPATIAL DEVELOPMENT STRATEGY FOR GREATER LONDON
DRAFT FOR PUBLIC CONSULTATION DECEMBER 2017 - MARCH 2018
MAIN POINTS OF PWA SUBMISSION
PWA welcomes the Mayor’s stated ambition to make London at least 50% green by 2050; his recognition of the value of London’s network of green and open spaces in terms of their economic and social value and the importance of linkage between SINCs/green spaces to help species migrate to avoid the consequences of climate change. We also welcome the clarification in the Plan about suitable sites for locating waste treatment facilities.
However, PWA’s main concern relates to the inclusion of the Pinkham Way site in the New Southgate Opportunity Area. Our comments are mainly focused on the policies relating to that.
Major development is planned for New Southgate Opportunity Area (Crossrail 2 North). Expected capacity is for 5000 new jobs and 2,500 new homes. Possible proposal to construct concrete raft over the Pinkham Way section of the N Circular, to mitigate congestion, and to build on the resulting land released. The Pinkham Way site is shown as either within, or immediately adjacent to, the New Southgate Opportunity Area.
PWA will argue that Pinkham Way is not a suitable site for development because:
•Part of the site is designated Metropolitan Open Land and LP Policy G3 states that MOL should be protected, with any proposed changes supported by 'thorough evidence' (8.3.2) The whole of the site is a green open space which is designated a Site of Borough Wide Importance for Nature Conservation;
•the site is a London BAP Priority Habitat containing species protected under the Wildlife and Countryside Act 1981 and classified as priority in the UK BAP
•There are over 1500 trees on the site. LP Policy G7 states that trees and woodlands should be protected. The plan emphasises the value of what it calls the ‘urban forest’ ie trees and the Mayor’s stated aim is to increase London tree cover by 10%
•It provides foraging and breeding sites for many species, some endangered, and a rich variety of flora. Birds classified as “Endangered” by the RSPB are breeding on the site
•it is part of an important link in a Green Chain of SINCs, from Parkland Walk and Alexandra Park via Albert Road Rec, Muswell Hill Golf Course and allotments, Tunnel Gardens and Bluebell Wood through to Coppetts Wood and Glebelands LNR.
•Haringey’s Open Space and Biodiversity Study October 2014 described the site as ‘ … unique in Haringey for its size and mosaic habitat’.
•Natural England stated in September 2015 that Pinkham Way is ‘ … a rich biodiverse mix of habitats which if developed would be a loss to London as a whole’.
•NLW Plan consultants Urban Vision stated that development would result ‘in a loss of Green Infrastructure’.
•LP Policy G6 states that “Sites of Importance for Nature Conservation (SINCs) should be protected. The greatest protection should be given to the most significant sites.”
•Policy G6 also states that the wildlife value of these sites must be protected, and appropriate maintenance regimes should be established to maintain or enhance the wildlife value of sites 8.6.2
•Consultants for both iterations of the NLWP (N London Waste Plan) have identified PW’s importance in flood alleviation by acting as a greenfield site which absorbs huge amounts of surface water which would otherwise find its way into the adjacent valley, ie the A406 North Circular Road. This is Flood Zone 3b – the highest risk for flooding
•the land is widely contaminated. Remediation would be very costly (up to £1.3m per hectare according to the Homes and Community Agency Guidance 2015). In 2011 Arups told the NLWA (N London Waste Authority) that remediation of any area of the site would destroy the nature conservation value of that area.
•Development of nature conservation sites is against national, regional and local policy
•Open spaces are protected under national, regional and local policy. PW unequivocally qualifies as Open Space.
NB Waste Policy S18 is inconsistent with Policies E6, SK1, E4, and E7 insofar as it refers to Locally Significant Employment Sites/Land. This is the only reference to LSES/L and it is not referred to in the narrative. It should be amended to Locally Significant Industrial Sites which would be consistent with the explanatory narrative throughout the rest of policies and narrative in the Plan and it would remove the confusion about whether designated ‘Employment sites’ were suitable for waste uses.