In July we wrote to Enfield Council to express our concerns about the Draft Local Plan Consultation and have decided to publish our letter.
The full letter can be downloaded here.
In summary, our concerns are that:
- Important information is missing from the draft Local Plan, making it impossible to give a fully considered response.
- Information has been presented in a way that appears designed to prejudice the consultation responses and is not presented in an even-handed manner.
- There are significant inconsistencies between the documents; information in the Evidence Base does not support other claims made in the Plan.
- Key elements of the Plan are inaccurate.
- The Plan includes a lot of jargon and acronyms, which reduces the potential for public engagement and understanding.
- The questions within the consultation itself are poorly drafted and full of planning speak. They appear to be designed to put the general public off responding, rather than to encourage positive engagement.
- With more than 65 documents to review, many of which are several hundred pages in length, the sheer volume of information is overwhelming and off-putting and reduces the potential for meaningful public engagement.
- Important documents have been added to the Evidence Base, weeks after the consultation started.
- Maps are of such poor quality that key information cannot be read and some maps are incorrect.
- Comments in the Plan and supporting documents give the impression that the authors do not know Enfield, which undermines confidence in the Plan. For example, the Growth Topic Paper says the University of Middlesex campus is located in Trent Park, which it vacated in 2012.
- The Plan includes misinformation e.g. the London National Park City Foundation have written to Enfield Council to say that references made to them in the Plan about the Foundation’s aims and objectives are “incorrect” and “misleading“.
- Frequently referring to the London National Park City Foundation in the Plan, without first seeking the charity’s approval is troubling.
These are just a few examples of some of the issues we have encountered so far whilst attempting to write a considered response to the Local Plan consultation. We have identified many more issues than the examples given in our letter.
We believe that the extent and nature of this misinformation goes far beyond what might be considered reasonable ‘human error’ and calls into question the validity of both the Plan and the consultation.
In our letter we also expressed our concern about the council’s response to a letter sent to them by the London National Park City Foundation, which was reported by Enfield Dispatch here (Environmental charity slams council’s ‘misleading’ Green Belt rationale).
The council said in its response that “We reject any suggestion we have linked the National Park City concept with the draft Enfield Local Plan preferred option … “.
The council’s public response is nothing short of extraordinary and seems to us to be highly misleading. The council has clearly linked the National Park City concept with its preferred option in the draft Plan.
Furthermore, the council’s claim that unless the Green Belt is built on, people will be packed “into small units in dense towers with a lack of access to open space and supporting infrastructure” is inaccurate and misleading. The use of emotive language appears to be an attempt to scaremonger. It is notable that even the Plan itself contradicts this claim, as it states that tall buildings are not the only solution to delivering high quantities of housing and refers to the benefits of viable alternatives.
In short, the council’s public response to the letter from the London National Park City Foundation appears to be an attempt to distort reality, mislead the public and prejudice the consultation process.
The nature and extent of the issues we have encountered are serious, and it is our firm opinion that the Local Plan consultation documents in their current form are not fit for purpose.
It is also our opinion that the consultation is not being conducted positively and in good faith and is being managed in order to achieve the council’s desired outcome.