Regulation 18 Consultation

PINKHAM WAY ALLIANCE

Submission to Haringey Draft Local Plan – Regulation 18 Consultation
October 10th – December 19th 2025

SUMMARY OF MAIN POINTS
• The Council has allocated the Pinkham Way site for industrial/employment/waste use. However, in doing so it has disregarded a raft of material planning evidence, as well as important recommendations from the North London Waste Plan Inspector. We consider that these omissions leave the Local Plan ‘not justified’ and ‘not positively prepared’. In other words, it is unsound.
• In 2021, the Waste Plan Inspector redrafted parts of that plan in order to make it sound. Part of the redraft was a comprehensive summary of the planning and environmental constraints on Pinkham Way. The Plan is now adopted and is part of Haringey’s Local Plan.
• Quite correctly, the Council has used points from the Inspector’s work to inform the Pinkham Way allocation. Importantly, it has also omitted significant inconvenient aspects.
• In his November 2021 Report, the Inspector expressly handed to the Council two fundamental local issues for the Council to address in this Local Plan. It has addressed neither.
• First, the validity of the anomalous dual designation – Grade 1 Site for Nature Conservation (SINC) and Employment Land – that has bedevilled the whole issue since 2011.
• The Employment part has existed for most of the 60 years since the sewage works closed. The Council never offers any evidence of suitability. Its previous existence seems enough justification for continuance. After 60 years of producing nothing, it should be removed.
• Second – whether the site, entirely reclaimed by nature, should still be regarded as Previously Developed Land.
• National planning guidance states that sites such as Pinkham Way, with no visible signs of its previous use in terms of above-ground structures, and heavily vegetated, should be regarded as having reverted to greenfield land.
• The Waste Plan evidence cites this guidance, and advises elsewhere that the heavy vegetation means that, in terms of water absorption capacity, the site acts as greenfield land. Haringey has disregarded all this.
• It has also disregarded the decades of public use of the site as open space for informal recreation since Barnet took ownership in 1963. This use is the only use that has ever materialised on the site since then.
• In 1988, Haringey, as planning authority (the site is in Haringey), and Barnet, as planning applicant, together endorsed this use as public open space, and facilitated its continuance, in a routine planning decision for the construction of a local Community Centre in the area neighbouring the site, known as ‘The Freehold’. The long usage, and its acknowledgement by local authorities, created important rights for local residents.
• Since closure, the only functioning planning designation has been for nature conservation. Haringey first designated it as a site of Local Importance in 1979, upgrading it to Borough Importance in 1998.
• The Council’s SINC Review in 2021 concluded that Pinkham Way had the potential to be upgraded further, to London-wide, or Metropolitan, Importance. This mirrors the 2015 opinion of Natural England that Pinkham Way was already such a site.
• The London Plan states that such sites are the highest priority for protection.
• The Council has ignored this important up-to-date evidence.
PWA’s conclusions are:
• Pinkham Way is an open greenfield site of considerable ecological importance, in spite of long-term neglect by both landowners. It long ago lost any characteristics of being Previously Developed Land. The Council should protect it as such.
• The London Nature Recovery Strategy includes Pinkham Way; it is a fine long-term project for Biodiversity Net Gain, and the Council should include it in a ‘Habitat Bank’ of Haringey sites. This would generate long-term cross-boundary community involvement that would meet relevant environmental objectives for both Haringey and Barnet.
• In 60 years, various employment designations have generated no employment, nor any buildings, services or utilities that could support it.
• Haringey has continued to offer no evidence of suitability for employment; in its attempts to sustain a patently unsound designation, it has ignored carefully targeted comments and clear guidance from two previous Local Plan Inspectors, as well as that already mentioned above.
• Its equivocal attitude to protecting a valuable open green space of ecological importance, linking other spaces to north and south, creates a precedent that weakens overall Council policies to protect similar open spaces and nature conservation sites throughout the Borough.

Pinkham Way Alliance
November 2025