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H A R I N G E Y L O C A L P L A N - R E G U L A T I O N 1 9 - M A R C H 2 0 1 6

Download the full submission document in PDF format:

Read an overview of our response submitted on 4th March 2016 below:




This stage is about the soundness and legality of Haringey’s revised Local Plan. The following are the main points of our proposed submission, the completed version of which will be available after submission on March 4th.

Having looked at the evidence produced by Haringey Council and having met with its officers on numerous occasions, it is our view that the Pinkham Way site has not been objectively assessed during the Local Plan review process. The Council seems determined to keep the employment designation at all costs in the hope that the site can be used for waste management by the NLWA or others.

This has resulted in many egregious errors and omissions, including, but not limited to, the following:
• its disregarding of inconvenient evidence, whether submitted by its own advisors or by PWA;
• its suppression of material viability evidence about the site;
• its convoluted and fatuous inventions concerning the site’s status as Open Space;
• its consistent failure since 2012 to address the arguments that PWA has made about the site’s status as brownfield land;
• its failure to address the issue of the culverted water course;
• its misrepresentation of the substance and weight of PWA’s evidence, and of the depth and breadth of the concern still felt by residents;


• Without producing a shred of evidence to the contrary, Haringey Council has ignored clear advice and evidence from its own advisors, Atkins, that the site is unsuitable for the future employment needs of the borough. The Council simply says ‘there is a continuing need for employment spaces in the borough’.

• The Pinkham Way site won’t deliver employment spaces - the Council’s other consultants, GVA Grimley, dismissed the site from its study ‘Workspace Viability’ on the grounds that, it ‘... has limited workspace drivers to support future workspace delivery’. Meaning it is simply not suitable for workspaces either.

• Some weeks after the Plan consultation closed (March 2015), a viability report prepared by GVA Grimley specifically for the Pinkham Way site was disclosed by the Council under FoI. We analysed the figures and found that Grimley’s had factored in significantly lower development costs than used for other Haringey sites which they had subsequently assessed. They also grossly underestimated the remediation costs. Even using these more favourable figures, they still found that 100% employment use would not be viable “under any scenario” but that some element of employment use might be possible if it was cross subsidised with housing. When we challenged the basis of the figures used in the viability report the Council was unable, or unwilling, to explain why they differed from those used on other sites.

• The Council has since stated that it does not want housing development on Pinkham Way and indeed has reinforced that by classifying it Employment Land rather than a Regeneration Area, which would be more flexible.


The previous Local Plan Inspector recommended that the Open Space value of the Pinkham Way site should be assessed at the earliest opportunity.

• The LUC Open Space Study in October 2014 would have been the ideal opportunity to do that but the Council refused to include it on the grounds that “ … it was not publicly accessible – a key requirement of the Study.”

• Six of the sites included in that study were classified as ‘inaccessible’ and were assessed as open space. We believe the Council chose to deliberately avoid assessing the open space value because it feared the result would further demonstrate its unsuitability for employment use.

• Inexplicably, the Council now takes the view that the Pinkham Way site is not an Open Space because it is fenced and it is not designated ‘open space’ in the local plan!

• The whole purpose of reviewing the local plan is to assess whether designations are still valid and supported by objective evidence. In the Atkins Open Space study (2003), the site was identified as Open Space even though at that time it was not accessible to the public and was referred to elsewhere in the study as private recreational space.

• The definition of Open Space in the Council’s Local Plan is: ‘All land in London that is predominately undeveloped ... whether in public or private ownership and whether public access is unrestricted, limited or restricted.’

• The level of public access is not a criterion for open space definition. It is evident to any objective observer that Pinkham Way is a natural open green space covered in woodland and other shrubbery. Its borough wide biodiversity value is acknowledged by its Site of Importance for Nature Conservation designation.

• Pinkham Way qualifies for inclusion in the Grid on two criteria, Open Space and Green Space. The Haringey policies exclude it on both with no justification given.


• This site is not brownfield land according to the definition in The London Plan 2015. The London Plan positively excludes sites from the definition where the remains of a previous use has disappeared or has blended into the landscape in the process of time, or where a site has been overtaken by nature conservation value. It states such sites cannot be regarded as requiring development. All of these apply to Pinkham Way.

• The National Planning Policy Framework also excludes this site from its definition of Previously Developed Land which excludes ‘Land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time’.

• There are no buildings on the site. It has remained undeveloped since the original sewage works was closed, and most of its structures removed, more than 50 years ago.

• It simply defies credibility for the Council to deny Pinkham Way’s open green space status, which is a matter of fact, and to blind itself to the reality that the site falls outside the definition of either PDL or Brownfield land.