Lee Valley Regional Park Authority

TOWN AND COUNTRY PLANNING ACT 1990 (AS AMENDED)

BROXBOURNE LOCAL PLAN EXAMINATION

STATEMENT OF THE LEE VALLEY REGIONAL PARK AUTHORITY

SUBMITTED IN RESPECT OF MATTER 7 GYPSIES AND TRAVELLER AND TRAVELLING SHOWPEOPLE ACCOMMODATION AND ISSUE 4.2

STEPHEN WILKINSON BA(Hons), BPl, DipLA, MBA, MRTPI

BACKGROUND TO THE LEE VALLEY REGIONAL PARK AUTHORITY

1. The Lee Valley Regional Park Authority is a statutory authority created by the Lee Valley Regional Park Act 1966 (the Park Act). It has a statutory responsibility to either provide directly or work with partners to provide facilities for sport, recreation, leisure, entertainment and nature conservation throughout the Park. The Park lies in east London extending northwards from the River Thames to Ware in Hertfordshire and comprises 4,000ha of which 1,600ha are owned and managed by the Authority.

2. The Park includes a mosaic of award-winning facilities and open spaces, including three Olympic Legacy venues and a biodiversity resource of international, national and local importance, some of which is owned and managed by the Authority. The Park attracts approximately 7m visits each year.

THE AUTHORITY’S GOVERNANCE

3. The Authority is managed by a Board, ‘the Authority’, which is made up of elected Members drawn from its funding authorities of the London Boroughs, Hertfordshire and Essex. The Authority delegates to Committees various responsibilities including its responsibilities defined by Section 14 of the Park Act.

4. Under these powers the Authority’s Upper Lee Valley Regeneration and Planning Committee (superseded by the Regeneration and Planning Committee in 2017) agreed responses as successive drafts of the Broxbourne’s local plan have emerged. These are included in the Appendix A, to this statement.

THE AUTHORITY’S PLANNING ROLE

5. Section 12 of the Lee Valley Regional Park Act 1966 identifies the Regional Park as a place for recreation, leisure and nature conservation (Appendix B includes relevant extracts from ‘the Park Act’). Although the Park straddles the boundaries of several local planning authorities this statutory remit seeks to define the Regional Park as a distinct place.

“It shall be the duty of the Authority to develop, improve, preserve and manage or to procure or arrange for the development, improvement, preservation and management of the park as a place for the occupation of leisure, recreation, sport, games or amusements or any similar activity, for the provision of nature reserves and for the provision and enjoyment of entertainments of any kind.”

6. The Authority is not a planning authority but it has a range of powers and duties in relation to the statutory planning process. Section 14(1) of the Park Act requires the Authority to prepare a plan setting out proposals for the future management and development of the Regional Park. Planning authorities are under a mandatory obligation to include those parts of the plan affecting their areas within their own relevant planning strategies and policies. However inclusion of these policies and proposals by riparian boroughs does not necessarily imply they are fully accepted (Section14 (2)(b)).

7. Section 14 (4-7) of the Park Act requires local planning authorities to consult with the Authority on planning matters which they consider could affect the Park. The operation of this requirement has occasioned this statement.

8. Section 14 (8-9) allows the Authority to refer decisions of the riparian authorities to the Secretary of State if it is considered by the Authority that the decision materially conflicts with the proposals of the Authority for the development of the Park.

9. Under its plan making powers the Authority has, over the past 40 years, produced a range of proposals for the future development and management of the Regional Park. Presently, the Park Plan (2000) is the adopted plan for the Regional Park for the purposes of development management. The Park Plan comprises 2 documents; Part 1 which identifies the strategic policy framework and Part 2 which contains detailed proposals for the whole Regional Park. Extracts are included in Appendix C1 and C2 to this statement.

10. Extensive work has been carried out on the replacement planning document for the Park Plan, the Park Development Framework (PDF) to comply with section 14 of the Park Act. A new vision supported by a set of strategic aims for the Park arranged around 6 themes was adopted in 2010.

11. The adopted Vision is for the Park to be a “world class leisure destination” and the adopted aims for each of the 6 themes are as follows:

 Visitors: A Park that is a high quality and regionally unique visitor destination.  Sport and Recreation: A Park that delivers a range of high quality opportunities for sport and recreation.  Biodiversity: A Park that delivers a high quality biodiversity resource for the region.  Community: A Park that helps people improve their wellbeing.  Landscape and Heritage: A Park landscape that embraces the physical, cultural and social heritage of the area.  Environment: A Park that contributes to the environmental sustainability of the region.

The adopted vision places a stronger emphasis on the importance of the visitor and the importance of landscape throughout the Regional Park.

12. The whole of the Park Plan will shortly be replaced by the PDF and the Authority has recently completed public consultation (April –June 2018) on new strategic policies, landscape strategy and guidelines, a Habitats Regulations Assessment and draft proposals for the areas north of the M25 motorway which include all the areas of the Regional Park which fall within the Borough of Broxbourne. The detailed Area Proposals were initially consulted on between December 2014 and January 2015.

13. Accordingly both the Park Plan 2000 and the PDF are relevant in terms of Section 14 (2) of the Park Act and are formal statements of the Authority’s position in respect of proposed development within the Regional Park. Extracts from the adopted and draft documents are included in the Appendices.

14. The Park offers a biodiversity resource of international, national, regional and local importance. In total there are eight sites of Special Scientific Interest (SSSI) in the Park four of which; Amwell Quarry, Rye Meads, Turnford and Cheshunt Pits and Walthamstow Reservoirs, form the Lee Valley Special Protection Area and Ramsar Site. These protected sites and habitats offer a high level of ‘access to nature’ sites for large numbers of visitors as well as being accessible to local people. The Authority produced a Biodiversity Action Plan in 2000 to help protect and manage this resource identifying key targets for improving habitats and species. This document is currently under review and following a consultation period earlier this year, a new BAP is due to be published in the autumn.

NATIONAL PLANNING POLICY FRAMEWORK (NPPF)

15. The adopted NPPF is very clear in its commitment to the protection of the Green Belt and its identification of uses which are considered as not inappropriate. Paragraph 89 identifies the ‘exceptions’ when new buildings can be considered appropriate. These include ‘limited infilling or the partial completion of previously developed sites…..whether redundant or in continuing use….. which would not have greater impact on the openness of the greenbelt and the purpose of including that within it than the existing development.’ The essential thrust of this paragraph is retained in the draft NPPF (2018) at paragraph 144.

16. References are included under paragraph 81 to the role of local planning authorities to ‘plan positively to enhance the beneficial uses of green belt such as looking for opportunities to provide access, outdoor sport and recreation to retain landscapes visual amenity or to improve derelict land’. The Authority’s PDF is the means by which Broxbourne can through partnership with the Authority ‘plan positively’ for those degraded areas of the green belt which lie within the Regional Park.

17. Linked to the NPPF the Government issued national guidance on ‘Planning Policy for traveller sites’ in August 2015. This sets out at paragraph 4 several aims for Traveller sites which include ’that plan making and decision taking should protect the green belt from inappropriate development’ and further that ‘plan making and decision making should aim to reduce the number of unauthorised developments and make enforcement more effective’. Furthermore, the guidance identifies that ‘local planning authorities should have due regard to the protection of local amenity and environment’.

18. This advice also seeks to ensure that traveller sites are sustainable, economically, socially and environmentally and that they are not located in areas at high risk of flooding.

19. Underpinning the whole Local Plan process is a requirement that plans submitted for formal examination are ‘sound’ (Paragraph 182 NPPF) and meet requirements of being, positively prepared, justified, effective and consistent with national policy. These headings are retained under paragraph 35 of the 2018 draft although their descriptors have been amended.

CROSS RAIL 2

20. For the last three years officers from the both the Authority and the Council have been involved in a series of discussions with Transport for London (TfL) and Network Rail (the Cross Rail 2 team) on the emerging proposals for the Cross Rail 2 project. The draft plan makes several references to this project although formal decisions remain with Government which is developing its business case. In advance of the final delivery of the scheme, anticipated by the early 2030’s, Network Rail have embarked on a series of surface level rail crossing closures replacing these with overhead head ramped pedestrian/cycle crossings. As yet this closure programme has not affected road crossings.

21. There are a few locations along the route where replacement road bridges will be required on completion of the ‘crossing programme’. However it is understood that these will be completed as part of the Cross Rail 2 project and could include new road bridges over the lines at Windmill Lane and Wharf Road.

MATTER 7 GYPSIES AND TRAVELLER AND TRAVELLING SHOWPEOPLE ACCOMMODATION

22. The Authority objects most strongly to draft Policy GT1 which references expansion of an area of land within the Regional Park at Wharf Road as an authorised site for Gypsies and Travellers.

23. Supporting text to this Policy refers to ‘…the situation at Wharf Road has become very complex with substantial subletting of caravans to individuals with no long term connection to the Borough’ para 16.6. Further references are made that the Council is seeking to work with the ‘established’ community and the Authority to create an authorised site. This would entail the “relocation of a straggle of plots along the River Lee onto land currently owned by the Authority in the central area where most of the unauthorised plots are currently located. This would create a central integrated site that can then be authorised, licensed and properly serviced with roads, water, electricity and drainage”. The text continues that this proposal ‘…… will also entail the discontinuance of subletting.’

24. The Authority has from inception sought to purchase land at this site to secure its integration into the Parklands. The Council’s proposals will run counter to this long held ambition and frustrate the implementation of an important policy which has been retained in successive versions of the Authority’s adopted Plans, supported by considerable expenditure.

SITE CONTEXT AND HISTORY

25. Wharf Road lies wholly within the Regional Park, forming part of the northern section of the River Lee Country Park (RLCP) and is designated as Green Belt. The site is bounded on the west by the London Cambridge rail line and to the east by the River Lee Navigation. The northern part of the site merges into an area known as Silvermeads, a County wildlife site with high ecological values including a significant water vole population. To the south lies extensive parkland reclaimed over the last 40 years from former gravel workings which are now an attractive and popular visitor destination. These areas are of high landscape and ecological value comprising Turnford and Cheshunt Pits SSSI which also forms part of the Lee Valley Special Protection Area and Ramsar Site.

26. A varied landscape quality exists across the area with significant and abrupt changes in quality where non-Park related uses and unauthorised residential development occur with attractive remnants of an earlier riverine landscape. The Gypsy and Traveller plots are characterised by high screen walls and fences with extensive areas of hardstanding some of which has encroached onto adjacent areas of open land.

27. Access to the Wharf Road site is limited. The nearest cross valley road, Old Nazeing Road is 1100m to the north and the east west track adjacent to Turnford Brook is 1900m to the south. There are few entry points to the site – Wharf Road level crossing and the Lee Navigation towpath extending north and south, which carries the Lea Valley Walk and forms the principle pedestrian and cycle route link to the rest of the RLCP and Broxbourne station in the north. The lack of bridging points and relatively long drive and walk times creates a sense of remoteness and disconnection from surrounding communities and their services.

28. The area was developed incrementally for holiday chalets in the 1920s and 1930s. Over the years various other uses developed mostly unauthorised, including allotments, nurseries, boarding kennels and a waste transfer site. By the late 1970s the area consisted of between 69 to 75 plots in various ownerships. Information contained in the Authority’s committee reports from the early 1980s show that public health, housing and planning concerns were already being raised by Broxbourne Borough Council. They were concerned about the poor condition of the ‘accommodation’ and lack of planning permissions for these structures, the lack of water supply and mains drainage/sewage disposal and the increase in unauthorised activities. At that time it was noted that these conditions had existed for at least twenty years, therefore originating before the establishment of the Regional Park and Park Authority.

THE LEE VALLEY REGIONAL PARK PLAN AND AUTHORITY’S MANAGEMENT AND PURCHASING POLICY

Authority Plans and Policies from 1967 to the late 1980s

29. The removal of the leisure plots at Wharf Road and their replacement with open space was identified as a priority task during the first few months of the Authority’s existence. The Authority acquired its first plot in October 1967. The prevalence of groups of chalets and caravans, lining the banks of the Navigation was recognised in the 1969 Park Plan. At that time the plots appeared to be used mainly at weekends but the Plan noted that many of the chalets “leave much to be desired for aesthetic and other reasons” and that ‘radical improvements’ were needed (para 3.12). The 1969 Plan of Proposals designated the Wharf Road area as “Open Space Parkland”, (the same designation afforded to Carthagena) and landscape proposals included tree planting/screening on parts of the parkland. The Authority continued to acquire land and plots on an ‘opportunity’ basis.

30. By the time of the Park Plan review in the early 1980’s 22 plots or nurseries had been acquired. The explanatory text in the 1986 Park Plan noted the presence at Wharf Road of a “collection of nurseries, some in a rundown condition, chalet plots, and some other uses which do not make a positive contribution to the Park either in recreational or aesthetic terms.” (para 2.19). Paragraph 4.3.33 ‘Holiday Accommodation’ pointed out that as the holiday chalets and recreational plots at Wharf Road had ceased to “serve a genuinely recreational function” and their appearance was doing little to enhance the Park, they should be “redeveloped for informal public recreation”. The 1986 Park Plan therefore proposed the following:

“3.10 Wharf Road, Wormley ACQUISITION AND CLEARANCE OF ALL STRUCTURES TO CREATE A LANDSCAPED AREA FOR INFORMAL RECREATION. The Authority will seek to acquire, if necessary by compulsory purchase, all property which is not already publicly owned. Following clearance of all structures, the opportunity may exist for the extraction of gravel and the creation of additional water areas. The site will be landscaped as part of a valley wide scheme of improvements and linked with the Country Sports Centre.”

31. A progress report on the Wharf Road Area in 1988 (D.428) noted that the Authority had acquired 15 chalets, 28 caravan plots, 11 nurseries, 30 garden allotments in one site and 4.2 hectares of former sewage works land. Various nurseries and other structures were demolished and grassed over to provide an area for informal recreation and a small car park was provided for use by anglers and general visitors at the southern edge of the site. Pending implementation of the longer term proposals for the wider area 8 chalets and 24 caravan plots were still being let on short term holiday recreational licenses.

Landscape works during the 1990s and the Park Plan 2000

32. The mid 1990s saw two phases of landscape and access improvements, mainly on land immediately south of Wharf Road but which also included minor enhancement works to create an informal picnic area on two plots (68 and 69) immediately north of Wharf Road. These had been compulsorily purchased by the Authority in 1994. Access improvements sought to link this area with the rest of the Park and in particular with the newly formed RLCP (June 1992) to the south and east.

33. The Park Plan Proposals (2000), the adopted plan, (Appendix C2) includes the Wharf Road area within the northern part of Section Three ‘Broxbourne to Waltham Abbey – An area of restored river valley floodplain for informal recreation based on the high quality countryside and heritage value.’ This Proposal confirmed the Authority’s approach to incorporate Wharf Road into an extended River Lee Country Park. Explanatory text notes the need to restore the environmental quality and accessibility of land in the north of this section to complement the high quality landscape and visitor enjoyment of the rest of the RLCP. Specific proposals for Wharf Road are found under Proposal 3.1 “Area for informal recreation and nature conservation with an emphasis on quiet recreation within a wooded, grassland and water environment.” Proposal 3.1i) states:

“At Wharf Road the Authority to continue to purchase land and buildings to assemble an integrated recreational open space”.

Proposals also show Wharf Road within a “Landscape Enhancement Area” in Policy LS (Landscape Strategy) where areas of weak or unrecognisable character are to be strengthened through a series of measures, for example, protection of positive landscape features, resistance to development that would harm their attractiveness or their potential to be improved or enhanced and design and management schemes to improve landscape quality.

Park Development Framework and Wharf Road Environmental Strategy

34. Given the challenging circumstances of the Wharf Road site the Authority agreed a draft Environmental Strategy for its renewal and integration into River Lee Country Park in 2013. This is included at Appendix D. The intention is that this document will form part of the adopted Area Proposals, (Proposal 6.A.4.1 please refer to Appendix E). Consultation involving the delivery by hand of letters to each plot did not result in any objections from the Gypsy and Traveller community at the site following both consultation events in 2015 and earlier this year.

35. Key aspects of the Wharf Road proposals can be summarised as follows:

 Planting of native wet woodland to provide enhanced screening of visually intrusive uses  Thinning of other vegetation to improve visibility into the site from the Navigation  Creation of a major new pedestrian spine parallel with the Broxbourne Ditch corridor;  Extension of existing path network and new access point for Silvermeade access  New scrapes and additional ecological interventions;  Management works to Broxbourne ditch including desilting and tree works to reduce shading, to improve habitat for water voles and  Potential for short or long rotation coppice on the sites currently occupied by commercial premises.

36. If these proposals are adopted as part of the PDF their implementation could involve considerable expenditure either through the purchase of sites on the open market or through the use of compulsory purchase. However the draft proposals include rough costings for the individual masterplan proposals at Wharf Road, although specific timescales are not included. This allows for individual projects to be undertaken as and when resources allow. As with any new area brought into the Park for public recreational use there will be increased revenue costs resulting from additional management activities. The Environmental Strategy proposes that these costs could be in the large part addressed by the short-rotation coppice proposal or some other suitable leasehold activity. Capital cost allowances and estimates (2013 figs) are as follows:  Planting and other works to aid visual integration approx. £75,000  Access improvements approx. £350,000  Ecological enhancement approx. £215,000 and  Additional signage £10,000.

37. Today the Authority owns 49 out of 69 plots amounting to around 80% of the site area, following a programme over the last 50 years of purchasing sites consistent with its adopted planning policies. During the last 10 years it has purchased 3 plots, the site of the ‘Forge’ and a former waste transfer site of Dents. Appendix F identifies that the Authority has spent £1.5M and Appendix G identifies the extent of the Authority’s ownership.

38. Twenty plots are currently owned and occupied by the Gypsy/Traveller community although due to the extent of subletting these do not function as such.

39. There have been problems of unlawful planning use and illegal activities which through either separate actions or joint work with the Council have been tackled with varying degrees of success. In recent years the nature of the unauthorised activities has intensified and a joint interagency team was established by the Council at the end of 2015 to tackle some of these. In 2015, officers from Broxbourne Council, (Community Safety, Environmental Health, and Planning), the local police and the Authority (including ‘Parkguard’) met to discuss an escalation in the number of people living at the site and the impact this was beginning to have on the area. This increase resulted from the subletting of the site to migrant communities. The extent of these issues undermines the purported role of the site as a Gypsy and Traveller site.

40. This aspect of the site history is relevant to the Authority’s case given that the Council has indicated that the site would be ‘self managing’.

APPLICATION OF THE PRINCIPLES OF ‘SOUNDNESS’ TO DRAFT POLICY GT1

41. The purpose of this section is to identify why the draft policy for this site remains unsound. The successful delivery of the Policy links to a ‘fresh’ approach involving the designation of a dedicated area within the wider site for ‘authorised plots’. Furthermore, there are specific references to management issues in the operation of the site including ‘subletting’ which will be resolved through this draft Policy.

42. To achieve this policy the Authority would have to voluntarily agree to a series of land swops involving the exchange of plots to remove the ‘riverside’ plots. This approach has several flaws.

43. Firstly, there is an issue of principle for the Authority having to give up land required for Park purposes; this runs counter to its statutory requirements. There would be limited gain for the Authority agreeing to this which would not be to its strategic advantage. Members have contemplated this proposition when they agreed the Authority’s objection to successive drafts of the Local Plan. Without the consent of the Authority, as landowner and with no indication of the views of the individual plot holders as to whether they would acquiesce to this proposal it remains ‘unsound’. It is not ‘effective’ i.e. capable of being delivered over the plan period.

44. The site lies within the green belt and although it has developed on a ‘piece meal basis’ through the ‘fusion’ of individual applications over time the creation of an authorised site in the green belt would run counter to both the NPPF(2012) and the specific guidance for Traveller sites published in 2015. It is ‘unsound’ being inconsistent with national policy.

45. The policy fails on other grounds of soundness including the proposed location of the ‘consolidated site’ within Flood Zone 3. This is an unacceptable location for the site. Mitigation to address this would involve a scheme of land works which could prove prohibitively costly and require additional land.

46. Paragraph 16.6 of the draft Plan states that the successful delivery of the Policy will address the issue of sub-letting. There is no evidence for this.

47. Evidence included in Appendix H identifies that during the last 5 years there have been 19 incursions into the Authority’s land from occupants of plots which lie adjacent. In supporting papers presented by the Council with both draft Plans there have been references to the new site being ‘self-managing’. Whilst it is not normal to refer to issues of management in the context of planning policies the successful management of the site is questionable in the light of the legacy of ‘incursions’ into Authority land. This approach would only serve to exacerbate the current intolerable situation and lead to further costs in officer time and legal fees.

48. As an alternative the Authority consider that the Council should explore other sites required to accommodate the additional pitches identified in its ‘Needs Assessment’. It is understood that various alternatives sites failed because of the ‘costs’ of land purchase.

49. However, in the long term the issue of costs may be addressed through the intervention of the Cross Rail 2 project. It is understood that the Cross Rail team have considered the possibility of a new road bridge to replace the surface level crossing at Wharf Road required to service the site. The costs of this would be considerable. It is the Authority’s contention that the moneys allocated for this could be better spent on purchasing a site in a location outside the Regional Park which is better served by amenities in line with national guidance issued in August 2015. This would negate the need for a new road bridge.

CONCLUSION

50. In respect of GT1, the policy is unsound on several grounds as it runs counter to green belt and flood risk policies. It cannot deliver on its purported advantages. Furthermore, the essential thrust of the policy would run counter to the statutory purpose of the Authority as a public body which is seeking to integrate this area into the Regional Park through land purchase and the delivery of its plan making policies and proposals.

APPENDICES

A – AUTHORITY REPORTS AND MINUTES B – EXTRACTS FROM LEE VALLEY REGIONAL PARK ACT 1966 C1 & C2 – PARK PLAN 2000 EXTRACTS D – WHARF ENVIRONMENTAL STRATEGY 2013 E – AREA 6 DRAFT PROPOSALS 2015 EXTRACT F – WHARF ROAD AQUISITIONS G - PLAN OF AUTHORITY OWNERSHIP H – WHARF ROAD INCURSIONS

LEE VALLEY REGIONAL PARK AUTHORITY

UPPER LEE VALLEY REGENERATION & PLANNING COMMITTEE MINUTES 22 SEPTEMBER 2016

Members Present: David Andrews (Chairman) Gordon Nicholson Syd Stavrou (Vice Chairman) Paul Osborn John Bevan Mary Sartin Valerie Metcalfe

Apologies Received From: Malcolm Cowan, Linda Haysey, Heather Johnson

Officers Present: Stephen Wilkinson - Head of Planning & Strategic Partnerships Beryl Foster - Assistant Director of Legal & Property Lindsey Johnson - Committee Services Officer

Also Present: Martin Paine - Planning Policy Manager, Broxbourne Borough Council

Part I

183 DECLARATIONS OF INTEREST

Name Agenda Nature of Interest Prejudicial Item No.

Gordon 6 & 7 Member for Broxbourne Borough Council Non- Nicholson and Trustee of Herts Young Mariners Pecuniary Base

184 MINUTES OF LAST MEETING

THAT the Minutes of the meeting held on 16 June 2016 be approved and signed.

185 PUBLIC SPEAKING

No requests from the public to speak or present petitions had been received for this meeting.

186 EPPING FOREST DISTRICT COUNCIL DRAFT LOCAL PLAN

Members were advised that this item would be deferred until December.

187 BROXBOURNE BOROUGH COUNCIL EMERGING LOCAL PLAN

Martin Paine, Planning Policy Manager at Broxbourne Borough Council gave a presentation on Broxbourne’s Emerging Local Plan, key points included:

• The plan will last from 2016-2033; in that period 7000 new homes will be built, with 6- 7000 new jobs and 31 Traveller pitches. UPPER LEE VALLEY REGENERATION & PLANNING COMMITTEE MINUTES 22 SEPTEMBER 2016

• The Council has identified Brookfield, Cheshunt Lakeside, Park Plaza and Rosedale Park as ‘new strategic sites’. • The Council looks to support the development of an ‘adrenaline hub’ at Lee Valley White Water Centre. • The Broxbourne Leisure Pool Development Brief will be updated to include the potential for residential development to enable wider development of the site. • The Council will look to put in place a reclamation scheme for the Spitalbrook area. • The Council would like to relocate Gypsy/Traveller families at Wharf Road into a central area owned by the Authority which could then be authorised, licenced and properly serviced.

The Head of Planning & Strategic Partnerships informed Members that many of the pitches at Wharf Road were illegal but the cost of enforcement and eviction is prohibitive in dealing with the issue effectively. Wharf Road has many issues, including sub-letting to Eastern Europeans, assaults and the safeguarding of children. The Authority’s view is that a self- managed site at Wharf Road would not work.

A Member suggested that if the sites were being sub-let then the site was no longer a Gypsy/Traveller site, therefore it should be de-designated and suggested the possibility of the Authority issuing a CPO to evict the Gypsy/Traveller families, suggesting that if this were mentioned in the public domain the site would become less appealing to Gypsy/Traveller families in the future.

Martin Paine reminded Members that there was no alternative site for the legitimate Gypsy/Travellers at Wharf Road and that the matter would need to continue to be discussed carefully.

Martin Paine continued his presentation:

• The ‘safeguarding direction’ to be issued by TfL/Network Rail to the Council in 2017 to provide space for new tracks. • The strategic site of Cheshunt Lakeside will have 1000 new homes and businesses, a new primary school, relocation of network rail depot and flood risk assessment. • Cross Rail 2 are ‘cautiously supportive’ of the Council’s Waltham Cross Area Action Plan. • The Council are working with Network Rail to identify reasonable alternative crossings for users in support of level crossing closures.

The Head of Planning & Strategic Partnerships informed Members that our objection to the closure of Wharf Road level crossing might be that it prevents public access into the Park and operational management, however new gateways into the Park could be created at train stations instead. Network Rail will be conducing public consultations for 10 weeks from October, where they will be asked to come and present to Members.

A Member asked whether there would be a new train station at Turnford. Martin Paine responded, stating that it was an aspiration of Broxbourne to do this, but it was a long term project.

UPPER LEE VALLEY REGENERATION & PLANNING COMMITTEE MINUTES 22 SEPTEMBER 2016

Martin Paine concluded his presentation:

• The second draft plan will be in December, with submission in March 2017, examination in the summer of 2017 and hopefully adoption by the end of 2017. • The next steps include continued testing of deliverance; further technical work around transport strategy and cycling strategy; considering consultation responses which will be published in a report; and producing a revised plan.

Valerie Metcalfe and Syd Stavrou left during the next item.

188 BROXBOURNE DRAFT LOCAL PLAN REGULATION 18 Paper ULV/113/16 CONSULTATION DOCUMENT

The Head of Planning & Strategic Partnerships informed Members that the area of land that Broxbourne have identified for relocating Gypsy/Traveller families at Wharf Road is owned by the Authority and that this land use would not be compatible for the Park.

A Member asked about residential moorings. The Head of Planning & Strategic Partnerships responded, stating that officers are working with Canal & River Trust to develop a mooring strategy but that we don’t envisage them being in the Park.

The Head of Planning & Strategic Partnerships informed Members that we would not wish to make a case with Network Rail for a replacement road to Wharf Road to replace the one lost by closure of the level crossing as it would only serve the Gypsy/Travellers and we could manage with other roads in less controversial positions.

Members again discussed the possibility of mentioning a CPO for Wharf Road Gypsy/Traveller plots, but decided that for the moment it was best to wait and continue to work with Broxbourne to find a solution for this site.

With an abstention from John Bevan and Gordon Nicholson, Members approved the following recommendation:

(1) the comments set out in Appendix A to Paper ULV/113/16 as the Authority’s formal response to Broxbourne Borough Council’s draft Local Plan was approved with the following amendments to the letter:

(a) the Authority believes that self-management of the Wharf Road Gypsy/Traveller site would not work due to the many issues experienced there; and

(b) the Authority would like to see new entrances and services for the Park at each train station.

UPPER LEE VALLEY REGENERATION & PLANNING COMMITTEE MINUTES 22 SEPTEMBER 2016

______Chairman

______

Date

The meeting started at 12.26pm and ended at 1.30pm.

LEE VALLEY REGIONAL PARK AUTHORITY

REGENERATION & PLANNING COMMITTEE MINUTES 14 DECEMBER 2017

Members Present: Chris Kennedy (Vice Chairman) Paul Osborn John Bevan (Deputy for Peray Ahmet) Mary Sartin Valerie Metcalfe

Apologies Received From: David Andrews, Peray Ahmet, Christine Hamilton, Denise Jones, Gordon Nicholson, Syd Stavrou

In Attendance: Frances Button, Lyne White (Deputy for Ken Ayling)

Officers Present: Shaun Dawson - Chief Executive Stephen Wilkinson - Head of Planning & Strategic Partnerships Beryl Foster - Assistant Director of Legal & Property Marigold Wilberforce - Property Surveyor Nick Powell - Property Surveyor Lindsey Johnson - Committee Services Officer

Also Present: Doug Cooper - Broxbourne Borough Council 3 x Members of the Public

Part I

16 DECLARATIONS OF INTEREST

Name Agenda Nature of Interest Prejudicial Item No. Chris Kennedy 4 & 7 He personally knows the public speaker & Non- he is a Member for London Borough of Pecuniary Hackney

17 MINUTES OF LAST MEETING

THAT the Minutes of the Regeneration & Planning Committee meeting held on 9 November 2017 be approved and signed.

18 PUBLIC SPEAKING

Abigail Woodman had requested to speak regarding the next agenda item, key points included:

• I have read London Borough of Waltham Forest’s new Local Plan where is says it is considering a policy to resist inappropriate loss of Green Belt, MoL and open spaces. Why do you feel therefore that it is appropriate to nominate MoL in the call for sites? • The Executive Committee claims no official decision has been made. Are you hoping to get protections on land chipped away and present decision makers with a fait accompli? REGENERATION & PLANNING COMMITTEE MINUTES 14 DECEMBER 2017

• What extent have you taken account that local people have had the Waterworks registered as an asset of community value? • What is point of having ‘environmental implications’ on your committee reports, if you abdicate responsibility for analysing the environmental impact of the decisions you are being asked to make?

The Chairman of the Committee thanked Abigail for speaker and said that a written response to her questions would be sent shortly.

The Chairman of the Authority stated that the Authority can suggest sites which could be developed for non-Park related purposes and it would be up to the Council m to decide whether the site was acceptable for development or not.

19 CONSULTATION BY LONDON BOROUGH OF WALTHAM Paper RP/11/17 FOREST ON THE REGULATION 18 DRAFT LOCAL PLAN

Revised plans were tabled.

The Head of Planning & Strategic Partnerships introduced the report stating that in our letter to London Borough of Waltham Forest we have requested that the Authority be given greater recognition in delivering leisure needs to the borough. The letter also identifies 3 sites in their ‘call for sites’, which are the Waterworks facilities building and car park; part of the former golf course and the western edge of the Ice Centre car park. It should be noted that in the Park Development Framework we have described the area as a landscape conservation site, and around Lea Bridge Road where we would like to improve and upgrade the ‘offer’ in the area with new pedestrian and walking facilities. It also states that we would like to make the Waterworks a centre for ‘environmental’ learning. Following the earlier consultation in the year the London Borough of Waltham Forest has already identified the Waterworks as a regeneration opportunity. Any money made from the sale of sites would be reinvested in parklands or new venues. This letter will be amended to refer to the de-designation of these sites from MoL.

The Chairman asked why there was an additional map showing land in the south as he thought that it was decided at the Additional Authority meeting in January not to include it, the Head of Planning & Strategic Partnerships responded stating that he was showing Members all available options. Members agreed to stick with the decision from January involving just the ‘reduced’ area including the Waterworks building and car park to the north.

(1) the comments included in the draft letter at Appendix A to Paper RP/11/17 was approved.

Frances Button left the meeting.

20 BROXBOURNE PRE SUBMISSION LOCAL PLAN REGULATION Paper RP/09/17 19 CONSULTATION DOCUMENT

The Head of Planning & Strategic Partnerships introduced the report stating that the Authority holds a lot of land in the Borough of Broxbourne and our main concerns with the Local Plan is around Wharf Road.

REGENERATION & PLANNING COMMITTEE MINUTES 14 DECEMBER 2017

Doug Cooper from Broxbourne Borough Council spoke to Members, key points included:

• We have in the past tried to enforce unlawful Gypsy/Traveller encampments, however, at a public enquiry 2 years ago with sites subject to appeal, the inspector found they were lawful. • Planning legislation cannot control this site. The Caravans Act can control it, we have written to all Gypsy/Travellers inviting them to submit planning applications or certificates of lawful development. • Of 16 plots, 13 are now lawful or about to become so through extended planning conditions. • We recommended in our Local Plan that a permanent site should be established there as 75% of it is legal. • You are correct in stating in your draft letter that our plan is ‘unsound’ as we can’t deliver our Local Plan without your consent where Wharf Road is concerned. If you agree to a permanent Gypsy/Traveller site, we could work with you and the travellers to deliver that site. If not we go into examination with a policy that is unsound. • At the LPI there are 2 options, 1 we resort to status quo, with a scatter of plots where others may become lawful and deal with plots through the Caravans Act. Option 2, we would seek a CPO to deliver policy, which we don’t want to do. • I think you are still seeking relocation of Gypsy/Travellers from Wharf Road, we don’t have anywhere else to site them. • There is significant subletting, we will not be able to control that subletting, but with a proper site it might be possible. • I think an inspector will want to keep them at Wharf Road because so many of them are lawful. • If you do pursue on unsoundness you will need a deliverable alternative site.

The Chairman of the Authority stated that there have been meetings between Broxbourne and the Authority to try to resolve the situation. At present the Authority is still not convinced that a self-managed site at Wharf Road will work and are concerned that the situation there will be worse rather than better.

Members agreed that the letter would be sent with an addition to the section on Wharf Road saying that we are reserving our position pending further discussions with Broxbourne.

It was agreed that another meeting would be arranged as soon as possible between Broxbourne Borough Council and the Authority to discuss this matter further.

(1) the comments as set out in Appendix A to Paper RP/09/17 was the Authority’s formal response to the consultation by Broxbourne Borough Council on the Pre-Submission Local Plan with the following amendment:

(a) the section on Wharf Road conclude stating that the Authority is reserving its position pending further discussion with Broxbourne Borough Council; and

(2) a meeting would be set up between the Authority and Broxbourne Borough Council to discuss further issues at Wharf Road was approved. REGENERATION & PLANNING COMMITTEE MINUTES 14 DECEMBER 2017

21 CONSULTATION BY THE LONDON BOROUGH OF HACKNEY Paper RP/10/17 ON THE DRAFT (REGULATION 18) LOCAL PLAN 2033 ‘HACKNEY A PLACE FOR EVERYONE’

The Head of Planning & Strategic Partnerships introduced the report.

The Chairman stated that he had been involved in the creation of this Local Plan and felt that the letter reflected a measured response from the Authority.

(1) the draft comments included in Appendix A to Paper RP/10/17 as the Authority’s formal response to the London Borough of Hackney’s consultation on the draft (Regulation 18) Local Plan 2033 was approved.

______Chairman

______Date

The meeting started at 1pm and ended at 1.35pm. LEE VALLEY REGIONAL PARK AUTHORITY