Enfield Council’s draft Local Plan says that 25,000 homes need to be built in Enfield over the next 20-years. The council claims there are not enough brownfield sites to accommodate these homes, so 6,500 need to be built in greenbelt areas. In this paper we explain why this claim is incorrect.
There are many benefits associated with building on brownfield sites
A brownfield site is previously developed land, which has the potential to be redeveloped. By comparison, a greenfield site is land that has not previously been developed, such as woodland, agricultural land and greenbelt land.
The redevelopment of brownfield sites plays an important part in the renewal of our towns, suburbs and industrial areas. Building housing on these sites can bring multiple benefits, especially as the sites are often in sustainable locations and near existing infrastructure.
The redevelopment of brownfield sites can help to create new jobs and bring investment into urban areas to benefit existing residents. For example, the investment can be used to decontaminate land, create parks, develop better climate change protections, visually improve an area, enhance public services and essential amenities, and improve access to safe active travel routes.
Enfield council claims there are not enough brownfield sites.
Enfield Council’s draft Local Plan says that 25,000 homes need to be built in Enfield over the next 20-years and claims that 6,500 of these will need to be built in greenbelt areas because there are not enough brownfield sites.
Brownfield sites can deliver far more homes than the council claims.
We have reviewed the council’s draft Local Plan in detail, and it appears that far more homes could be built on brownfield sites than the council claims. There are two main reasons for this:
- Anomalies in the council’s calculations.
- The council has excluded brownfield sites.
Taking each of these in turn:
(1) Anomalies in the council’s calculations.
- The draft Local Plan does not include enough small sites to meet the London Plan target. To meet the Mayor’s London Plan target, a minimum of 7,060 homes should be built on small brownfield sites in Enfield over the next 20-years i.e. sites smaller than 0.25 hectares. Although the council states a clear intention to meet this target (see Policy DM H4 p203), only around 4,100 homes on small sites have been allowed for in the draft Local Plan. Therefore undercounting about 3,000 homes that could be built on small sites. We have previously reported on this issue in more detail here.
- The draft Local Plan actually identifies enough housing on large brownfield sites to deliver the housing needed. Around 17,940 homes will need to be built on large brownfield sites (>0.25 hectares) in Enfield over the next 20-years. A detailed reading of the draft Local Plan shows that the council has identified large brownfield sites to deliver 19,596 homes, which is 1,656 more than needed. 
- The draft Local Plan has undercounted the number of homes some brownfield sites with existing planning approval will deliver. Some brownfield sites already have planning approval. The draft Local Plan includes housing estimates for these sites that are lower than the number already approved, therefore undercounting the homes these sites will deliver. 
- The draft Local Plan’s estimates for the number of homes brownfield sites can deliver are lower than estimates in other council documents. Some estimates made about the number of homes a brownfield site could deliver are substantially lower than other assessments made by the council. This is another way homes have been undercounted. 
- The estimated delivery timelines has resulted in further undercounting: The draft Local Plan estimates when the housing on some large sites will be completed, and predicts that a number of sites will not deliver housing until after 2039 (i.e. beyond the 20-year Plan period). However, other council documents show that these sites will deliver housing sooner than is predicted in the draft Local Plan. This inconsistency is another source of significant undercounting of homes that could be built on brownfield sites within the Plan period. 
After accounting for these anomalies, we estimate that there are already brownfield sites identified in the draft Local Plan capable of delivering 29,660 homes over the next 20-years. 
(2) The council has excluded brownfield sites.
A number of brownfield sites have been excluded from the draft Local Plan, which if included, could deliver a far more homes. For example, there are sites at Meridian Water and in Brimsdown that have not been included in the draft Local Plan and which could deliver around 9,000 additional homes, as well as new and additional employment space. [See Appendix A]
There are also a large number of smaller brownfield sites, which were submitted to the council by housing campaign groups in January 2019. These sites are generally in sustainable locations and could make a significant contribution towards delivering the housing Enfield needs. The council decided not to include many of these sites in the draft Local Plan due to a lack of information.  However, the campaign groups have not been asked to provide the missing information.
Our analysis of the draft Local Plan (and the Local Plan Evidence Base) demonstrates that far more homes could be built on brownfield sites than the council claims and that there are sufficient brownfield sites to deliver the 25,000 homes target.
More information is available in the full paper which can be downloaded below.
Better Homes Enfield