The Friends of Trent Country Park thank you for the opportunity to respond to the Blue and Green Strategy Consultation. We have completed the survey referring you to this more detailed document. This submission represents the views of the Friends and our supporters, some of whom may also submit individually.
In general the Blue and Green Strategy appears ambitious with some good goals – but there are also major issues. We will restrict our comments to park-related issues but we are in agreement with other civic organisations, such as The Consortium of Friends of Enfield Parks, Enfield RoadWatch and The Enfield Society, about wider issues with the strategy that need to be addressed.
We hope that this mostly positive effort will not turn into another study gathering dust on the Civic Centre shelves, along with previous parks and open spaces studies from the past 20 years. Issues of particular concern are:
- Staffing – The Council’s parks staff are already stretched to maintain the existing portfolio of parks and open spaces and have been unable to keep up with habitat maintenance, such as that recommended in the Trent Country Park Habitat Survey 2017. The Council has been without a Biodiversity Officer for some time and what environmental expertise remains is scattered in different departments. How does the Council plan to follow the advice in the appendices about habitat improvement and maintenance and install and manage all the new green and blue assets without more specific expertise and staff in general? Volunteers cannot and will not fill the gaps.
- Funding – We have concerns that reliance on development fees and levies to fund the projects and hire the necessary staff will result in the de-designation of some Green Belt sites for development and Green Belt swaps from west to east, despite protection in the new London Plan.
- Events in the parks have become a very controversial issue, especially very large-scale events such as Elrow in Trent Park, which caused havoc locally and probably made very little money for the Council. It is hard to support this goal as part of the strategy without a better definition of the type, size and location of the proposed future events and a definition of terms like ‘active management’ of parks. Given the importance of the borough’s parks and green spaces during this Covid year, it is to be hoped that any events will have public health and welfare and protection of our environmental assets as primary factors, rather than attracting the largest number of people for events that have nothing to do with green open spaces.
- Increased community engagement – The consultation documents call for more public engagement in decision-making and design. Too often there is only nominal public engagement and a poor track record of public input being factored into final decisions. A commitment to improve this record should be written into the strategy. There is a wish list of projects, such as Enfield Sports Village, with no evidence that local stakeholders have been consulted. Community input seems to be lacking in general at this stage.
- The emphasis on ‘fairer distribution’ and equality is positive unless in practice it means levelling down across the borough. References to no net loss of green space and the possibility of selling council land to developers and agencies suggest taking green space away from the west to fund projects in the east, which would not be acceptable. A more detailed focus on greening the east of the borough is needed in the strategy with specific projects and timelines. There is a lot of green space on the eastern side of the borough and there are some simple solutions for linking to Epping Forest and the Lee Valley, which should be listed and targeted. There should also be an exploration of innovative ideas such as Tiny Forests in the east. And there should be a project to introduce water sports in the east of the borough.
- Borough-wide strategy projects – All the projects are valuable, subject to appropriate local stakeholder consultation. However, initial funding and design and long-term maintenance could be an issue with most of them, especially given the Council’s reduced staffing and expertise in certain areas.
- With regard to Enfield Chase Restoration, it is an eye-catching project for the many and varied benefits it will bring, but it will require long-term management, which cannot come only from volunteers. The parks team will need full-time experts added to their roster. It appears that most of the Council’s farms are designated as future parkland as part of the Chase Restoration project. More information is needed about this – for instance, given the latest research about the importance of natural forest regeneration for carbon sequestration, will these areas be re-wilded and allowed to regenerate naturally? What scientific expertise will be brought in to oversee the project long-term and keep up with scientific advances?
Finally a few comments about the supporting appendices: –
- The Biodiversity Action Plan Review looks rigorous with some solid criticisms [such as data collection and sharing, maintenance, in-house expertise, etc.] and detailed guidance for future management and policy. However, there is no evidence that the Trent Country Park Habitat Survey 2017 forms part of the evidence base.
- The Blue and Green Infrastructure Audit looks thorough except for the complete omission of the Council’s farms or any overview of privately-owned farmland.
- The SINC Review recommends the status quo with a couple of additions and appears sound.
We will look forward to a final strategy that incorporates our suggestions.