Summary of Main Points
Although the consultation document purports to be a draft of the Site Allocations DPD, it is incomplete insofar as the future employment land designations within the borough are concerned. The draft does not include any of the sites which are currently designated as employment sites and leaves the issue of what sites should be taken forward in the Site Allocations DPD to some future stage of the process following the completion of the proposed Employment Land Study.
Although the Pinkham Way SINC is identified as one of 3 proposed land “allocations” in the Muswell Hill sub area of the Borough (as Site MH3) the draft document does not include any specific proposals as to the future use or designation of the site. Rather, the document states that, “subject to the findings of the Open Space Review, Employment Land Review and the North London Waste Plan this site will be allocated as necessary”.
But there is no NWLP (even in draft form). The NLWP cannot therefore be a relevant consideration for this document.
The lack of completeness of the draft consultation document results in its not being clear what exactly the council is consulting on in relation to the Pinkham Way site, given that a) the Open Space Study and Employment Land study are not available and b) as stated above, there is no North London Waste Plan.
Within a year of the Planning Inspector’s rejection of a previous attempt to redesignate the site as Industrial, the NLWA has now requested that Haringey Council uses its scarce resources to try and find justification for redesignation to LSIS.
We do not consider that Council resources should be used to satisfy the wishes or to protect future unspecified options for a landowner, in this case the NLWA, when it does not even have any immediate or medium term proposals for its use. (At the site visit undertaken in December 2013 and attended by PWA members, the NLWA officers advised the Council that it has no plans for the use or development of the Pinkham Way SINC in the short or medium term.)
The Pinkham Way SINC is an important Site of Nature Conservation of Borough-wide significance; its protection as such should be the primary objective for the Council. The future protection and proper management of the site is critical if its nature conservation value is to be sustained and enhanced. NB please see reference below to our proposals for local community participation in the future management of the site.
The development of the site for any major built development would be incompatible with the site’s importance for nature conservation and as open land. The site is highly valued by local residents for its biodiversity value and as a local amenity space for informal recreation and should be designated for this purpose.
The allocation of the site for employment use would be incompatible with its nature conservation interest and value and is not supported by the Council’s own policies relating to the Muswell Hill locality (eg on employment and open space/biodiversity). In addition, on the Council’s own assessment, it is ‘poorly’ served by public transport, now an integral consideration of the deliverability of any site for development. Poor public transport links encourage car use.
The site is unsuitable for any form of major built development by virtue of its location, the poor accessibility by public transport mentioned above, its lack of direct access to the North Circular Road, its proximity to residential areas, and the significant development constraints imposed by virtue of its value for open space, nature conservation and its integral function as part of an important green chain within this part of north London.
The ownership of the land is irrelevant to the Council’s consideration and determination of the use and designation of the site. The Council will be aware that, subsequent to the NLWA’s initial submission to the Site Allocation DPD, the Authority announced in September 2013
a) the abandonment of its procurement strategy, within which the development envisaged at Pinkham Way would have been taken forward, and b) that its investment in a major treatment facility would now be concentrated at its existing waste site at Edmonton.
Pinkham Way SINC should be designated as a Site of Importance for Nature Conservation and as a protected open space; its employment designation should not be carried forward.
There should be a scheme of effective management in place to preserve, enrich and improve the biodiversity value of the site in accordance with the objectives of the Council’s Biodiversity Action Plan 2009 and to provide for public access in a managed way which is compatible with the site’s nature conservation value.
PWA has commissioned a Site Management Plan – to be submitted with this response - and has asked not only its supporters, but all local residents, for a commitment in principle to offer practical help (ie work on the site perhaps once a month) in putting this plan into action - similar to the successful arrangements at Coppetts Wood/Glebelands Local Nature Reserve – the old companion sewage works to Friern Barnet.
We believe that the dual designation of this site as SINC/ Employment Land is an anomaly and is fundamentally flawed. The Council refers to “a site with more than one designation” as if this was common to a number of sites within the Borough.
This is simply not the case. The Pinkham Way SINC is the only site within the Borough which has a “dual designation”. Furthermore, as far as the PWA can establish, the designation of the Pinkham Way SINC is also unique within Greater London.
The effect of this is that, although it is one of 9 Grade 1 SINCs, it appears, in successive versions of local plans, to have been intentionally given a lower level of protection by the Council.
This is unprecedented and demands a clear and special justification, which PWA considers does not exist. Additionally, the weakening of protection for one SINC leads unintentionally to weakened protection for all other SINCs in Haringey.
Haringey Council now has a golden opportunity to abandon the unwarranted approach that it has taken for so long to this site and to give it the full and proper protection that it deserves and needs, if its nature conservation value is to be preserved and enriched in line with the Council’s Biodiversity Action Plan 2009.
As PWA has argued several times over the last two years, the Pinkham Way SINC should properly be regarded as Greenfield land, and should be treated as such in all work relating to the sequential assessment in site selection and sustainability appraisal of plan options. The Council will remember that case law supporting this argument was presented to officers during the site visit in December 2013.