Updated 11th March 2020

Action page

The Whitewebbs petition has been a great success

4212 people signed but not all were valid under the council rules – duplicates, people who did not give their full addresses, people who do not live or work in the Borough – special thanks to our Australian supporter. Many people signed who now live elsewhere but have fond memories of the park. Despite this we we very comfortably exceeded the 3124 signature threshold for making our case to a full Council meeting.

See report of meeting in the Enfield Independent

Click to see article

The council has claimed that very few people are  concerned by the threat to Whitewebbs Park. The meeting on the 2nd November and the large turnout at the Green belt Forum proved this to be wrong

Thanks to everyone who has helped the campaign so far – the letters to councillors, the distribution of leaflets, the display of posters in windows, the collectors and signers of the petition, the spreading of the word to neighbours and friends ……………. everybody.

The next stages:

The Council has issued its latest update on “The Marketing of Whitewebbs Golf Course” note how they don’t like reminding us that the ancient woodland is included in this proposal. The full text is below with my comments and observations in Red and/or bold and underlined. A pdf version can be downloaded from the link at the end of the document. Please read it. There are important revisions to the assurances that have been given.
We will be given the opportunity to present our case (in five minutes exactly) to a full Council meeting on Wednesday 26th February at 7.00 p.m. at the Civic Centre. Please come along and support

Note – this document has been updated following the presentation of the petition to a full council meeting on 26th February
The document is long but it is important.

Overview   Marketing of Whitewebbs Park Golf Course February 2020 edition

Update on Marketing of Whitewebbs Park Golf Course.

(Note – no mention of  the Ancient Woodland – again)

Between August and October 2019, Enfield Council carried out a marketing exercise of Whitewebbs Park Golf Course. During this time, experienced leisure providers were invited to submit expressions of interest for the future management of Whitewebbs Park Golf Course and adjacent land, including woodland.

The council’s aim of leasing Whitewebbs Park Golf Course is for the park to be rejuvenated and to be used in a way that benefits the wider local community.

Which part of the local community does not benefit from Whitewebbs Park? Please be specific.

Before the marketing was launched, we engaged directly with stakeholders of the park who helped us develop the stated ambitions and the scoring criteria for the bid assessment. Stakeholders also suggested ideas for future leisure uses for the park, which were included within the marketing documents.

Requirements of bidders

Bidders for the lease were required to demonstrate a wide and inclusive benefit to the community, which were in line with planning policies and met with the council’s criteria. The criteria included:

  • retention or enhancement of public access Is this a case of Either / Or?
  • maintenance of woodland and open areas
  • provision of a range of activities
  • provision of refreshments and welfare facilities
  • community engagement.   

 If “Community Engagement” is an important criteria then, surely, this engagement should take place before leases are signed, not after (when it can be ignored)

Response from bidders

The council had an excellent response, receiving eighteen high-quality submissions. These proposed a wide variety of leisure and environmentally sustainable uses of the park, including golf, rewilding and woodland pursuits.

As of March 2nd  what is there to prevent publication of the bids?

None of the proposals involve clearing the site to create a landfill, as has been suggested by some parties.

.

Review by the council

The submitted bids have been reviewed and the council has received advice from independent planning specialists for each proposed use. This advice, along with community and stakeholder feedback, has influenced how the council has approached the second stage of marketing.

What community and stakeholder feedback has been taken into account?

Also, in response to feedback from residents, the requirements have been strengthened to ensure public access and facilities will be enhanced and the valued green space and woodland at Whitewebbs will be fully protected via both the bid evaluation and planning process. Any uses that don’t meet these criteria will not be considered.

At the Green Belt Forum great concern was expressed by Councillors’ and the public about the Council’s willingness and ability to enforce rigorously the terms of any leases awarded. It was admitted that the council’s record in this area was poor.

This document  makes no reference as to how the terms of leases will be monitored and rigorously enforced.

Decision on a preferred bid

We will confirm the preferred bidder by April 2020. Local ward members will be invited to observe the final presentation.

It was made clear at the Green Belt Forum that Stakeholders would be consulted before  a “preferred bidder “ was selected.

Organisations were invited  by Mark Bradbury and Ian Barnes to register with Mark Bradbury in order that they could be included in the process. In a written reply Mark Bradbury stated that “Once we know the number of stakeholders and indeed the number of bids we expect to receive we will firm up the arrangements”   (for stakeholder consultation). You now appear to have written stakeholders out of the process.

Following the announcement of the preferred bidder, a public drop-in event will be arranged. The preferred bidder will be available to share their proposals and answer questions about them.

This is a “fait accompli” not a democratic consultation. This definition of fait accompli sums up the situation – a thing that has already happened or been decided before those affected hear about it, leaving them with no option but to accept it.

The proposals and an online information page will also be made available, to provide accessibility to residents unable to attend the drop-in session. A final decision about going ahead with the preferred bidder will then be made, in consultation with cabinet members.

So, the decision will be made by an officer in consultation with one or more cabinet members without any meaningful discussion with residents , park users, stakeholders or even the council, based on criteria that have been kept secret

Afterwards, the council will work towards agreeing the lease terms with the preferred bidder. Upon signing a time-limited agreement, the bidder will then be expected to submit all relevant planning applications. The lease will not be signed until the bidder has secured the required planning permission for their proposed use.

Further information

Plans to lease Whitewebbs Park Golf Course

Whitewebbs Park Golf Course is currently being marketed by Enfield Council. The aim of the council isn’t to sell the park, but award a 25-year lease. The lease might include some surrounding land including woodland, depending on the suitability of any proposals.

As was admitted, by councillors and officers, at the recent (January 2020) Green Belt Forum the Council has a very poor record of lease management, particularly with regard to enforcement of lease terms. This Council cannot be relied upon to protect Whitewebbs Park  with leases.

Current progress with the marketing process

On 19 December 2019, the council began the second stage of the marketing of Whitewebbs. This means we have gone back to all bidders with enhanced criteria and a mandatory requirement to undergo a planning pre-application submission. This has given them a chance to provide more detailed final submissions to the council.

As was admitted, by councillors and officers, at the recent (January 2020) Green Belt Forum the Council has a very poor record of lease management, particularly with regard to enforcement of lease terms. This Council cannot be relied upon to protect Whitewebbs Park  with leases.

Bidders must make their final submissions by 2 March 2020. All submissions that meet the council’s requirements will be assessed and scored, based on the published scoring matrix.

The scoring guide published is far too vague to have any real meaning.

Requirements of bidders

All submissions will be subject to assessment and scoring.

We have also specified that:

  • all bidders must obtain pre-planning application advice from the council’s Planning Team, for their proposed future use of the park. Without this advice, bids will not be considered.
  • all bids are required to consist of leisure activities. Non-leisure proposals will not be considered.

Any proposals that don’t meet the council’s strict criteria will not be considered.

Assessment of submissions

Submissions will be evaluated and scored by a panel of council officers, which will consist of experts representing planning, property, commercial, parks, leisure and finance, with legal represented in an advisory capacity. This is to make sure of a balanced and fully informed evaluation outcome. The final decision will be made following public engagement as outlined below, and in consultation with Cabinet members.

There is no longer  mention of stakeholder consultation and input. Both Mark Bradbury and the Deputy Leader  Ian Barnes have assured us that stakeholders would be consulted before final bidders. What they have not done, despite requests, is to describe the consultation process. Many organisations have registered or requested registration as “Stakeholders”. I respectfully suggest that many of the officers above  are not as “fully informed” about the park as those who walk it several times a week.

It is a disgrace, or a gross oversight, that you have not included any environmental, arboricultural, botanical or zoological experts in your panel which seems to consist solely of finance and property people.

65% of the score relates to the bid meeting the criteria, the relevant experience of the bidders and the viability of the proposal. Only 35% of the score relates to the rent or premium offered.

Changes to how the park or facilities will be used

Rather than reducing access to the park, the council wants to award a lease to a leisure provider who will offer a wider and more inclusive benefit to the local community, in line with planning policies.

Local people will see an improvement in facilities and no loss of activities such as dog walking, bike riding, horse riding and cafe provision, for example. In fact, the intention is to increase use of the park to more of the community after the investment.

Ordinary walkers and runners will be excluded?  

Bidders were required to show a wide and inclusive benefit to the local community, in line with planning policies and that met with the council’s criteria, which were:

  • enhancement of public access What is meant by “enhancement” -too vague a term 
  • maintenance of woodland and open areas What is included in maintenance? again too vague a term
  • a more inclusive range of activities. What does “inclusive” mean in this context? Without context it is meaningless.
  • better provision of refreshments and welfare facilities
  • community engagement.      
  • the future of Whitewebbs Park

We will know the future use of the park after the final bids have been evaluated and a preferred bidder chosen. We expect this to be around April 2020.

All community engagement to date has come from the community with no initiatives from the council.

There is no provision in this document for meaningfull community consultation whatsoever

Many of the proposals received in the first marketing round included keeping golf facilities; some propose reducing the course to 9-holes; some propose adding driving ranges or other complementary facilities.

Other proposals didn’t include golf, but do propose other leisure uses or re-wilding of the landscape, nature or wildlife reserves and other outdoor and woodland pursuits.

Why the council is leasing Whitewebbs Park Golf Course

Since 2014/15 the council has worked to greatly increase revenue and reduce expenditure at Whitewebbs Park, including the golf course. This has included improving the online profile and accessibility for the course, as well as running more marketing campaigns for the golf course.  

However, the golf course has operated at a loss for several years and, in the last few years, the number of rounds played has dropped significantly in line with national trends. Enfield and the surrounding area is well served by golf courses, so as well as inviting proposals from experienced golf course operators it’s appropriate to also consider other leisure uses.

The financial model set by the Council for the golf course ensures that it runs at a loss. No golf course can operate on green fees alone. The old social golf club and the  Beggars Hollow café, both of which have strong golfer links, pay £20,000 a year rent to the council. This is not set against park or golf course costs. Enhanced provision in Beggars Hollow of a really good café , community function room(s) and a bar  would generate  a large income  which would cover golf course and park costs.With a 25 year lease  on such a project there would be no cost to the Council. There is, also, a question as to the contribution the carvery should be making to the park’s upkeep. It certainly benefits from the setting.

Why the park woodland has been included in the marketing

The council has given bidders the opportunity to include some or all the land adjacent to the golf course, including the woodland, as part of their bids. The inclusion of the entire site was to maximise interest from a wide variety of leisure providers.

If a lease was agreed which included the woodland, this would only be considered if the use was appropriate, enhanced public access, and ensured the maintenance of the woodland and public rights of way and bridleways.

What is meant by enhanced public access? There is a need to improve wheelchair / buggy access from the renovated path to Forty Hall to the Beggars Hollow car park. The paved pathway through the golf course could be extended to give wheelchair  access to the lake area and adjacent woodland

Developments would have to take into account  the hazards of conflicting  modes of access e.g. fast wheeled traffic and pedestrian traffic on narrow woodland paths.

Consideration would have to be given to the potential ecological damage that could be caused by  “enhanced “ access. It would be foolish to destroy the ancient woodland and its ecology by putting in pedestrian motorways.  There is an overwhelming case for an EIS by a respected body such as the Woodland Trust before any such scheme is proposed, let alone agreed to.

There are no “Rights of Way” in the park. There are permissive footpaths that have been in use for the last nine decades.  A map of footpaths recognised by the Council has been requested but has yet to be supplied. Only the north-south sections of the bridleway are shown on OS and council maps. 

A map showing most of the footpaths in use has been submitted to the council. Essentially, by nine decades of custom and use, the public has had full and free access to the whole park and woodland. Anything less than this would constitute a reduction in access.

Much as we might want to decrease road traffic the car is the principal means of access to this park. Whitewebbs is a “Metropolitan” park serving a very large part of Enfield. Public transport is virtually non existent and only those close to the park are within walking distance. Roads in the area are very busy and narrow, unsuited to safe recreational cycling. If there is to be increased access to and usage of the park adequate free parking must be included.  

Bidders are not required to include the entire park within their bids, and any future uses would need to comply with planning, including compliance with all requirements of its ancient woodland status.

Potential of soil importation at Whitewebbs

The council is not seeking to award a lease to change Whitewebbs Park Golf Course to a landfill.

We are aware that if golf use was to be kept, bidders are likely to want to remodel or modify the course and make it more attractive to the golf market. Golf course remodelling typically includes importing soil to assist in landscaping of the course.

Any development, including remodelling of landscape or changes of use to the site, will be subject to planning permission and will need to comply with national and local planning polices, which seek to protect green and open spaces. Any soil importation would require an applicant to show that soil importation would not lead to an unacceptable environmental or ecological impact

The council has not revised downwards the potential amount of landscaping material that could be used. It was this figure that caused so much alarm. (the equivalent of 17,000 lorry loads of “soil”) Does the council have any upper limit in mind?

There is also the issue of who will monitor the quality of any use of landscaping material

For any proposal that requires planning consent, a lease will not be entered until a planning consent has been granted. As part of our assessment we would consider the scale, suitability and impact of those proposals in the context of delivering a viable and acceptable proposal. Any proposal based simply on importing soil would not be considered as acceptable.

We have not received any submission which proposes to change the park into a landfill.

Protecting the greenspace and open amenity at Whitewebbs

There is no loss of green or amenity space proposed at Whitewebbs. In fact, the council is seeking for it to be enhanced by any future lessee.

This document does include any significant reference to the protection of the ecology and biodiversity of the park. There is huge concern about this yet  it has, apparently, been dropped from the criteria.  (See comments about your panel of experts plus all your generalised comments about environmental protection in earlier statements)

Before any bid is assessed it is essential that we have an up to date survey of the ecology and biodiversity of the woodland and park. Without this there is no baseline for assessing the bids and no possibility of assessing the performance of any lessee in maintaining the quality of the natural environment. Any surveys conducted before the end of April, at the earliest, would fail to show the extent of biodiversity. The survey should include the wetland area between the King and Tinker pub and the golf parking area. For many species a later survey would be required.(Many species, including bats, newts and butterflies do not  come out of hibernation until the warm weather)

Protecting the greenspace and open amenity at Whitewebbs

There is no loss of green or amenity space proposed at Whitewebbs. In fact, the council is seeking for it to be enhanced by any future lessee.

Public input over preferred bidders

Once a preferred bidder has been chosen, the council will arrange for a public engagement day to take place. At this event, the preferred bidder will be available to share their proposals and answer questions about them. As part of any planning process, there will be the usual statutory consultation period where the local community will have the opportunity to comment. 

See Fait Accompli above

No public or Stakeholder input before “Preferred Bidder” thereafter  public input restricted to Q & A session with preferred bidder. Note that the only public input will be at the planning stage where the community would be up against teams of highly paid planners and lawyers.

Have potential bidders been made aware of the contents of the Whitewebbs petition  and the amount of support it has received?

Bidders criteria

Before launching the second stage of marketing, information and requirements for bidders were enhanced.

Five qualifying requirements have been detailed to bidders and any bids that don’t meet with all these requirements will not be considered. The five qualifying requirements are:

  • Lease term of 25 years, to be contracted out of Sections 24-28 of Landlord & Tenant Act 1954

The acceptable proposed use must, be outdoor leisure or sport led, Proposals with no element of leisure use will not be considered

This could allow anything provided there was an outdoor facility included e.g. casino with 5 a side pitches outside.

  • All bidders had to submit a pre-application planning advice request by 27 January 2020 the outcome of the pre-app advice will form a key part of the evaluation
  • Any bids that include imported material for landscaping will be required to demonstrate that for the importation is essential for a viable leisure/sport led business following completion of the importation
  • The preferred bidder(s) will be required to engage with the public once selected and bids(? Plural?) must provide a comprehensive communication plan.

(On current experience I don’t think that the council would recognise a comprehensive communication plan if it saw one!)

All qualifying bids will be evaluated by a panel of appropriately qualified council officers, using a predetermined scoring matrix. The scoring matrix sets out the five following scoring categories and the weightings each category is given to the overall evaluation score:

  1. Meeting the Council’s Objectives (detailed below) – 30%
  2. Pre-application Planning Advice – 10%
  3. The applicant’s experience in comparable leisure uses – 10%
  4. The Applicant’s Financial Standing and Business Plan – 15%
  5. Rent/Premium Offered – 35%

At the heart of this marketing process remains the Council’s objectives for Whitewebbs Park Golf Course. Applicants are required to demonstrate how these objectives are met within their bid submission.

  1. Enhancement of Public Access – LBE is seeking a proposal that will enhance the existing level of public access and maintain all current public rights of way going forward.

(There are no “Rights of Way*”, only permissive footpaths sanctioned by 90 years of use. The public have had  free, unfettered access to the whole park  for 8 decades. What exactly is meant by “enhance”? – all existing paths renovated and signposted or just one selected path improved)
This use of “Rights of Way”  has only recently crept into the assurances – the original statement was  “As part of any agreement, the Council will require the current level of public access across the park to be maintained.”

2. Community Engagement – all bids should detail how the tenant proposes to engage with the community and stakeholders. LBE wish the applicant to provide a comprehensive communication plan which, as a minimum, should include details of using social media and a website to provide details of their plans for Whitewebbs and provide updates (in partnership with LBE). The new tenant will be required to provide digital and traditional platforms for engagement with the local community that allows for feedback.

This just means a website and a notice board

3. Maintenance of Woodland & Open Areas – the property provides an important habitat and open space for wildlife and local residents. Applicants must explain how these areas will be enhanced and managed in their proposals, detailing clearly where there will be improvements.

(Benign neglect has worked well so far, with a bit of path strimming. )

4. Range of Activities – the acceptable proposed use must be outdoor leisure or sport led. Proposals with no element of outdoor leisure use will not be considered.

(see comment above under qualifying requirements)

5. Provision of Refreshments and Welfare Facilities – all submissions must include provision of refreshments and welfare facilities to all users of the park, not just users of the proposal.

( A vending machine and a pay to use automatic toilet? We need a detailed requirement)

Stakeholder engagement

The following stakeholders were engaged prior to the marketing exercise and their views taken into account in developing the criteria and marketing materials:

  • The Friends of Whitewebbs Park
  • The Friends of Hilly Fields
  • The Greenbelt Forum,
  • Whitewebbs Golf Club
  • Whitewebbs Golf Club Users
  • Ward Councillors

We have committed to engaging more widely with stakeholder groups before making a decision* and the following stakeholders have been added to the list: BUT – the promise was to include stakeholders before preferred bidder status was decided.  Others have applied for stakeholder status and are yet to be included in the list.

At the Council meeting 26th February the Leader of the Council  said that the 18 bids would be reduced to 6. At that point there would be engagement with stakeholders. This would be in the May / June period. This conflicts with the above statement – *note that “preferred bidder” identification is not the “decision”.  If this marketing update document is correct then stakeholders and the public will be consulted (or engaged) after the  choice of one bidder. There is no provision for informing us of who else bid and what the bids were.

  • Woodland Trust
  • Enfield Scouts
  • Butterfly Conservation Hertfordshire & Middlesex
  • Enfield Age UK
  • North London & South Herts Ramblers Association
  • Enfield Sport

Golf club finances

The following is an extract from the Council’s accounts for the golf club. The figure is different from that published in the marketing literature as a new operator may not take on existing assets and will be responsible for accounting for their investment and overhead projections in their business plan.

The accounts are pretty meaningless as there is no detail  included other than broad headings.  For example: Accountants use tax rules to determine allowable depreciation in their cost and profit calculations. But these depreciation allowances need not reflect the actual wear and tear on the equipment or buildings.”

The financial model for the golf course, relying on green fees for income is not one that would be used by a business minded golf club where income is drawn from a variety of sources – bar, café, function room hire as well as golf fees.

25th November 2019

Many thanks to everybody who has written to councillors. If you have received a reply it will probably be the now standard one very similar to the one sent to me. I have reproduced it below with my comments added in red.

Dear Sean,

Cllr Yusuf has asked me to address your concerns. The following has also been published on our website.

The Council has carried out a marketing exercise to assess interest in investing in Whitewebbs to ensure the future viability of the golf course and/or deliver alternative leisure proposals.

Most of the concerns expressed by park users and the community are based upon the content of the marketing material. Apart from the Frank Knight prospectus and the advertisements in the  golf business press we have had no concrete information from the Council save for general assurances  unsupported by the release of the actual bidding criteria. It did not inspire confidence that the term “inert material” was used. Clearly someone did not show due diligence in the preparation of the marketing literature.


The Council has now received 18 expressions of interest. Our agents are currently assessing these against the criteria.

The proposals include a number that propose retention of golf; some propose reducing the course to 9-holes; some propose adding driving ranges or other complementary facilities.

Other proposals do not include golf but propose other leisure uses and/or re-wilding of the landscape, nature or wildlife reserves and other woodland pursuits.

None of the proposals involve clearing the site to create a landfill as has been suggested by some parties.

Nobody, so far as I am aware,  has suggested  that the golf course should become a landfill site. Concern that the golf course could have up to 200,000 cubic metres of “inert material” used for “landscaping” did cause major concern. Given the experience of many other golf clubs it is well known that “landscaping” while financially beneficial can have environmental and financial consequences that do not always reflect well upon the various contractors and industries involved.



Some of the proposals would involve the import of soil to remodel the golf course, for example, and as part of our assessment we would consider the scale, suitability and impact of those proposals in the context of delivering a viable and acceptable proposal. Any proposal based simply on importing soil would not be considered acceptable.


1. Had the revised edition of the Knight Frank prospectus not repeated  the potential for up to 200,000 cubic metres of material (“soil “ requires a very clear definition) people’s concerns  might have been moderated. As it is the Council  continues to use this figure in the marketing material and it is easy to show that about 17,000     20 tonne lorry loads  could be involved.

2. The inclusion of this figure is a clear indication to potential bidders that proposals involving such a vast amount of material would not be dismissed out of hand by the Council or its planning process – if not why is it there?

3. There is no confidence in the contractors’, developers’ or Council’s ability to monitor effectively the quality and nature of 17,000 20 tonne truckloads of material.


The next stage is to assess the proposals and take planning advice on some of them. We will then go back to bidders (after the General Election in December 2019) with enhanced criteria and a number of additional questions (which we will share openly) to enable them to submit final proposals and for us to eliminate any that do not meet the criteria.


Upon what will the enhanced criteria and additional questions be based? How many park users has the Council consulted? I can produce the records of a very well attended  open community meeting and 130 (and rising) detailed survey returns. These are on the website and a copy of the initial  results were sent to Councillor Yusuf. I am happy to send you the updated version.


The intention is to draw up a short list. We will engage with members and stakeholders at that stage before selecting a preferred partner.
Please define “stakeholders”.

Any preferred proposal is likely to require planning consent and we will ensure there is wide consultation prior to an application being lodged.

“Wide consultation” requires  definition if there is to be confidence in the process.

We will be issuing a more detailed communication following the General Election about the process and how we will engage with residents, no decisions will be made in the meantime.

Regards

Mark

Mark Bradbury MRICS, FRSA, FIoEE

Director of Property and Economy

Enfield Council

Silver Street

Enfield

EN1 3XY

There are a number of issues that need to be addressed:

1. The proposed inclusion of the 140 acres of ancient woodland and the meadowland in the leasing proposal. Perhaps more than anything this has puzzled  and annoyed  the community of park users Note that the community of park users is not just those who visit the park now – it includes people who will use the park in different ways and with varying frequency at different stages in their lives.

2.Access – it is not enough to say that current levels of access will be maintained. The results of the survey indicate the importance given to car parking at Beggars Hollow. People come from all over the Borough to enjoy Whitewebbs Park. (It is a “Metropolitan Park, not a local park) Today, a cold winter Sunday,  there were 62 cars  in the car park at 4.30 p.m. We are monitoring car park usage.  We need to know that free car parking on a sufficient scale will continue if the Council really means to retain current levels of access).  We also need to know that we will be free to roam  throughout the woodland and the meadow as we do now and that walkers and cyclists can continue to use the  tarmac path through the golf course, if current levels of access are to be maintained. (as indicated in various council documents)

3.The suggestion that up to 200,000 cubic metres of material  could be used to landscape the golf course. This is your( i.e. L.B.E.) figure not anybody else’s. The current golf course, now nearly 90 years old, blends in well with the landscape. It is rich in flora and a home to many forms of wildlife.  The community is rightly concerned  about the potential  construction traffic, the environmental damage, the diesel fumes, the mess and the congestion on our roads and the climatic impact.

4.Maintenance of facilities. There was very strong support for the provision of good all weather, all user, café facilities in Beggars Hollow. Toilets are also an essential. It should be noted that  these facilities are also used by Hilly Fields visitors.