Whitewebbs Blog

Feryal Clark’s tweet

“I have also had many emails regarding the Whitewebbs Golf Course. I was pleased to see the Council have now issued a press release on the future of Whitewebbs Golf Course after misinformation was spreading online about the site being used for housing or landfill. Following years of making a financial loss, despite measures to improve its situation, the council are exploring options for the Golf Course. With the pandemic also putting significant pressure on the Council, they can no longer justify using taxpayers’ money to keep the Golf Course running. They are undertaking a procurement process to determine the future of the Golf course. I was pleased to see that the council had made it clear they want applications to meet the needs of the local community and any proposed use of the site to increase community access to Whitewebbs for walking, recreation, leisure, and other uses.”

Dear Feryal Clark

I was unhappy to see the text of your recent tweet (above) regarding Whitewebbs Golf Course.

I remember noting at a hustings meeting for the general election that you had been badly briefed about the necessity to continue leasing out the golf course at Whitewebbs. This was untrue and  that was confirmed at a public meeting by the Director of Property and Economy.

I realise that you are extremely busy  and have to rely on others for information upon which to base your statements.

Your recent tweet indicates that the briefing from whoever has been limited, partial and misleading.

The story is long and complicated so I will try to keep it as short as possible.

Promised Consultation – none

1. There has been no meaningful Council consultation with the public, certainly none initiated by the Council.
   1. Early pre- marketing discussions with the Green Belt Forum indicated that only the golf course was to be “marketed”. This was changed  at the last minute to be golf course, parkland and ancient woodland.
   1. Public notification in the park was limited to one A4 poster  on a seldom used noticeboard in the 240 acre park.
2. Assurance have been given about consultation. This one from Mark Bradbury December 9, 2019 at 3:09 pm
   1. “The next stage is to assess the proposals and take planning advice on some of them. We will then go back to bidders 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. The intention is to draw up a short list. We will engage with members and stakeholders at that stage before selecting a preferred partner.”
3. All the initiatives for public discussion have come from users and supporters of the park. At a well attended Green Belt Forum unsuccessful attempts were made to limit discussion. At the meeting senior officers and councillors conceded that the scheme had been mishandled and that there would be consultations with “stakeholder “ groups.
   1. “Once all bids are in the Council will engage with public Stakeholder Groups (The Woodland Group had been added to this list and Mark Bradbury encouraged other stakeholder groups to come forward)) to obtain their views and input. Local residents are also encouraged to share what they would like to see at Whitewebbs so that this can inform the decision-making process.”
   1. The Chair thanked Mark for his interesting update along with residents for their engagement, comments and input. He suggested that if procurement rules allowed, the preferred bidders be asked to present their proposals to the public Stakeholder Groups to allow an informed decision to be made. Minutes of Green Belt Forum
4. Subsequently the Green Belt Forum was abandoned and replaced by an existing group principally concerned with the built environment. The recommendation from the Chair was  not followed up.
5. The park supporters organised a petition which gained more than enough signatures for us to address a council meeting. The Leader of the Council agreed to consultation with stakeholder groups at the short listing stage for bidders. This was recorded a little ambiguously in the minutes.
6. We were encouraged by the Deputy Leader to recruit stakeholders and these were registered with the Council.  They represent park users, youth organisations, the woodland and  various environmental and wildlife organisations of good standing.
7. To the best of our knowledge there has been no consultation with the stakeholder groups. Individuals and the Friends of Whitewebbs have written to Mark Bradbury about concerns as information has dribbled out but this is not consultation.

Moving goal posts – attempts have been made to make alterations to the marketing process.

1. Access – “current level of public access across the park to be maintained”. At one point this was revised  to “rights of way” of which there are none save for two sections of the bridleway. After a challenge Mark Bradbury assured us that access by all the formal and informal pathways would be retained. This has yet to be made explicit on the Council website. Clear maps and standards of maintenance are required.
2. Status of the Park.  Whitewebbs Park was bought  for the people of Enfield by an enlightened council in 1931. One hundred or so acres were subsequently laid out as a public golf course. The golf course was part of the park. The Council in its latest publications asserts that the 140 acres of ancient woodland  and park areas are part of the golf course (or adjacent land as it was dismissively referred to in the marketing material). The OS map shows all 240 acres as Whitewebbs Park Country Park.

Golf Course

1. There is much debate and scepticism  about the accounts presented. It is apparent that all sorts of costs  can be assigned to match a particular viewpoint. Depreciation and central costs can be adjusted  at will. The business model for the course has been kept as unviable by past and current administrations. No course survives on “green fees” (the charge for playing a game). Bar takings, function room hire, shop and café /restaurant all contribute to a viable business model. Whitewebbs has to manage on green fees, a small shop and a vending machine.
2. This course provides affordable play for the average earner and less well off. There are concessions for pensioners and significantly lower rates for off peak times. Players do not have to pay expensive membership fees.
3. There is a Golf Club but it is a relic of the past. It is a private social club with no role in the running of the course. It rents the old club house at the southern end of the course. The vast majority of golf rounds are played by  “pay and play” members of the general public.

Effects of closing the course taken from  Portfolio report on closing the golf course. 10^th March

Environment and climate change  considerations.

1. “..will reduce vehicle trips” If you close a local golf course so that  golfers have to drive further to other courses how on earth  does that decrease carbon emissions? Who came up with that idea?
2. Contrary to the view of those who have never visited the course, the land is a diverse mix of grasses, hedgerows,  shrubs, wild flowers, water courses and a wide variety of tree species. Birds abound, including hawks and other predators as well as flying insects. Sometimes during the day but more often at night foxes, deer and smaller mammals abound. There are bat colonies on the course and around the margins. The open spaces are their feeding ground. The course provides biological corridors between  Forty Hall and Whitewebbs Woods. While we fully support the planting of more trees in appropriate areas there is a strong  case for a mix of woodland and open areas when encouraging biodiversity.

Workforce implications

1. Let us not forget that it takes skill and experience to maintain a golf course. The skill, pride and livelihood of the groundstaff are at risk.

Equalities impact of the closure

1. Let us be absolutely clear about this course. It is not a club with membership fees. It is a good course, not up to championship standards, but good enough for the workaday player. It survives on green fees, no bar or function rooms. The fees are low compared with others in the area. There are substantial concessions for the senior citizens. Off peak twilight times offer the less well off the opportunity to play at very reasonable rates.
2. This Council has, without consultation and on uncertain figures, stopped the less advantaged on pensions, student loans and low income from having 3 hours of healthy, sociable, mind mending physical activity. Those on £100,000+ salaries will be fine if they want to play, not the ordinary citizen.

Alternative courses

1. The Officers blithely assert “There are several other courses in the borough …… that offer opportunities for golfers and prospective golfers to enjoy the sport.” This is a nonsense. The demand for golf in the area is high and capacity has fallen. Trent Park (A public  course) has abandoned all concessionary rates. I understand that there is a month long waiting list for tee off times already.  The private clubs that offer a limited amount of pay and play (peak periods reserved for £1400+ a year members) charge £35 to £50 a round and can require that you go round in a foursome, so you need well-off friends. Currently, I believe, the golf clubs are not permitting pay and play as demand from members is so high.

Throwing away money

1. The timing of the closure is  mystifying. After the first lockdown period income from the golf course went up 80% on the previous year, month for month. This was dismissed as “ a temporary situation where existing golfers made up for lost rounds during lockdown.” No evidence to support  this statement was provided. It is  now clear, however, that this is not a temporary situation. We are in a second post lockdown period where the vast majority will be holidaying at home. It is also likely that we will not be back to “normal” for months if not years. Patterns of work and leisure have changed, perhaps for good. Based on last year’s figures the golf course could expect a cash income of £200,000 to £300,000+ over the next 6 months. Is the Council so flush with money that this can be disregarded?
2. At the very least  the excess of cash income over wages and running costs could be used to upgrade paths and facilities in the rest of the park.
3. There are clear reasons for keeping the course open at least until winter, why then is this pre-emptive  move being made?
   
   
   

The golf course has been an integral part of the park  and of the “Marketing “ process. This decision to close it has been made in isolation from consideration of the future of the whole park without any consultation whatsoever. We were also told that no decisions would be made about the park until after the “Blue and Green” strategy  consultation process was complete.

Mark Bradbury’s letter to Chase Ward

I was very surprised to see that Mark Bradbury had written to all households in  the Chase ward just before the  election Purdah period. I have no doubt that you have seen it so these  are just a few comments. Some are repeats of what is above.

It appears to be a re-iteration of points, denying things that have not been issues such as landfill and housing. Nobody has referred to land fill, except  Council officers since just after the botched marketing process began.  It arose as an issue because the marketing material referred to the possibility of using  200,000 cu metres of “inert material” (almost any old building rubbish) for landscaping.  While the inert material has been changed to “soil” there has been no absolute denial that this quantity of landscaping material could be permitted – approx 17000 lorry loads. There have been all sorts of  social media allegations but these stem from the wall of secrecy surrounding this long and drawn out process.  The council has no-one to blame but itself.  It keeps the issue alive by  constant denials  – perhaps a case of “   … doth protest too much”

Freehold / Leasehold. Once the land has gone whether by  freehold or leasehold it has gone from public control.

 This Council, by its own admission, has an appalling record of not enforcing the terms of leases.(Green Belt Forum) Those responsible for drawing up the leases  and approving them will be long gone by the time the lease is up for renewal. No accountability.

“The woodlands will continue to be protected” and the rest of the park?

The Golf Course has made a loss – This depends on how the Council assigns overheads, central costs and depreciation. The business model for the golf course which is unlike other golf courses  ensures a “loss”. What is the income from the Carvery lease, the café lease, the social club lease?  How could these be better managed to generate income for the park.

Mark Bradbury makes a political point  comparing the cost of social workers and care costs with his notional costs of the golf course. Has he costed  in the health benefits both mental and physical of the 25,000 rounds of golf played  on the course every year. The activity probably greatly reduces the need for social workers and care costs.

The maths of the comparison need a closer look. His £1 Million cost of 22  full-time social workers is over 1 year. But the 1 million “loss” is over 5 years. This suggests that a full-time social worker costs the Council (salary/Employers NIC/all other costs) £9,900 per year.  This equates to each social worker being paid less than £5 per hour, an amount far below the minimum wage.

The closure of the golf course is going to cost  Enfield  £200,000 to £300,000 plus this year in cash green fees at a time when other courses will be jam packed  and the demand for golf is at a high. Look at the figures  for the post lockdown period last year – income up 80%

The point about 135 golf club members is totally irrelevant and misleading. Whitewebbs is not a membership  club charging over £1000 a year for membership. It is a public pay and play course for ordinary people who don’t want the rigmarole of posh private clubs. Costs of playing are substantially lower than at neighbouring clubs offering pay and play.

What alternate leisure activities on this site are going to generate income? Jogging?

Sean Wilkinson

Chair of the Friends of Whitewebbs park

Mark Bradbury – the Director of property and economy , has distributed a letter regarding Whitewebbs to all the homes in Chase Ward, an unusual event.

If you have not seen a copy, click the download button.

Commentary

We understand that Mark Bradbury, the Director of Property  and Economy has  distributed a letter to every house in the Chase ward about Whitewebbs Park  today.

This is a commentary on the points in his letter.

It appears to be a re-iteration of points, denying things that have not been issues

Freehold / Leasehold. Once the land has gone whether by  freehold or leasehold it has gone from public control.

 This Council, by its own admission, has an appalling record of not enforcing the terms of leases.(Green Belt Forum) Those responsible for drawing up the leases  and approving them will be long gone by the time the lease is up for renewal. No accountability.

“The woodlands will continue to be protected” and the rest of the park?

The Golf Course has made a loss – This depends on how the Council assigns overheads, central costs and depreciation. The business model for the golf course which is unlike other golf courses  ensures a “loss”. What is the income from the Carvery lease, the café lease, the social club lease?  How could these be better managed to generate income for the park.

Mark Bradbury makes a political point  comparing the cost of social workers and care costs with his notional costs of the golf course. Has he costed  in the health benefits both mental and physical of the 25,000 rounds of golf played  on the course every year. The activity probably greatly reduces the need for social workers and care costs.

The maths of the comparison need a closer look. His £1 Million cost of 22  full-time social workers is over 1 year. But the 1 million “loss” is over 5 years. This suggests that a full-time social worker costs the Council (salary/Employers NIC/all other costs) £9,900 per year.  This equates to each social worker being paid less than £5 per hour, an amount far below the minimum wage.

The closure of the golf course is going to cost  Enfield  £200,000 to £300,000 plus this year in cash green fees at a time when other courses will be jam packed  and the demand for golf is at a high. Look at the figures  for the post lockdown period last year – income up 80%

The point about 135 golf club members is totally irrelevant and misleading. It is not a membership  club charging over £1000 a year for membership. It is a public pay and play course for ordinary people who don’t want the rigmarole of posh private clubs. Costs of playing are substantially lower than at neighbouring clubs offering pay and play.

What alternate leisure activities on this site are going to generate income? Jogging?

Trent Park course is next to a tube station and on several bus routes. It has function rooms and a busy bar. Whitewebbs has one occasional bus and that goes nowhere near the golf course office.

Yet again the letter denies landfill but ignores the 200,000 cu metres of potential “landscaping” that is envisaged in the marketing material.

The letter, in its most significant omission, fails to mention the commitment to a meaningful consultation process with the “stakeholders”. These groups represent users, walkers, youth groups, woodland management and many respected specialist environmental groups.

The whole process has been characterised by inadequate and misleading information. The process is conducted secretly in the name of  commercial confidentiality. Attempts have been made to minimise the access promise.  If the council is concerned about “scaremongering and misinformation” it only has to look at its own performance in this “marketing “ exercise to see the cause.

Commentary – statement extracts in italics

Whitewebbs Golf Course has been making a financial loss for a number of years despite the introduction of measures designed to increase income and reduce costs at the site. Since 2014/15 the golf club has lost more than £1.1million.
The Friends of Whitewebbs Park  have supplied detailed figures to Mark Bradbury (August 2020) that reflect a very different position.  These show that the course had an operating surplus of £487,486 over the last 5 years. It also fails to take into account the upsurge in use last year which increased income by 80%.
Since 2010 Enfield Council has been forced to find £193 million of savings because of government funding cuts and increasing pressure on services. At a time of national crisis when our priority is protecting all of our communities and providing support for our most vulnerable residents, it would be irresponsible of Enfield Council to continue to use tax-payers money to subsidise an activity that is well provided for elsewhere across the borough.
What is actually irresponsible is closing a facility three weeks before it hits its biggest cash-generating period. The money spent on maintaining the golf course during the various lockdowns has already been spent and cannot be unspent. However, keeping the course open now will earn an estimated £200k – £300k over the summer months.  Closing it throws away the opportunity to make those earnings whilst saving very little: the staff will still need to be paid if they are redeployed or paid redundancy if they are not.
Enfield has six full length courses and a pitch and putt course available for golfers.
These are at private clubs which may have more expensive green fees or membership rules that will exclude less well-off members of the community.  It also has the potential to increase pollution by forcing players to drive further to play. But what is certain is that it drives income away from LBE and into other organisations.
In reality the Whitewebbs Golf Course has been closed for much of the last year and Enfield Council is currently in a process to determine the future of the site. 
Yes – but it was also open and very well used for the months of the year when it was legally allowed to be so.  The upswing in income generated was significant.
This decision was taken and published in March 2019.* Unfortunately, this process has been delayed because the coronavirus pandemic has affected the immediate priorities of the Council and the applicants.
The decision to close the golf course with immediate effect was NOT taken in March 2019.  The linked document clearly shows this.  Its recommendations read:
2. Recommendations: It is recommended that the Cabinet Member for Property & Assets:
2.1 Agrees to the proposed marketing and disposal process described within this report, for Whitewebbs Park Golf Course
2.2 Delegates the authority to the director of Property & Economy to instruct the director of Law and Governance to draw up legal agreements for a suitable property transaction for Whitewebbs Park Golf Course
The document then details the possibility of TUPE regulations being applied to golf course staff if transferred to the successful applicant, which pre-supposes the possibility of the successful applicant keeping the golf course operational.
Later in the document, there is also a detailed timing plan with 19 points. None of these points are “Closure of the Golf Course”. Given that according to this timing plan, the lease should have been awarded in December 2019 (clearly pre-pandemic), you can see that those responsible have missed every milestone.
The first mention of immediate closure of the golf course is in KD5177 of 10th March 2021.
Enfield Council has consistently been clear that among other considerations, applicants must meet the needs of the wider community and any proposed future use of the site must increase community access to Whitewebbs for walking, recreation, leisure and other uses.
True.  However the process has been conducted in a very secretive way and with some important, self-admitted, errors. As residents, stakeholders and Park users, we are yet to be consulted  on the shortlist, so no-one knows what is happening.
Any suggestion that the site will be used for housing or landfill are utter nonsense and scaremongering.
We do however know that the marketing materials made much of the capacity of the golf course alone being for 200,000 m3 of inert material (later changed to soil). The original use of the term ‘inert material’ suggests one thing: unwanted soil and subsoil from building sites. Yes, it was altered to soil – but the damage to everyone’s confidence in the project had been done. No-one I know has suggested it would be used for landfill.  For lack of firm information there are rumours of housing, hotel development ………………..
Enfield Council will be in a position to announce the next steps in the very near future. In the meantime whilst the course will be closed to golf, the site will remain open for walking, jogging and other recreational use. Please see above for why keeping the golf course open would have been a more sensible course of action.

Comments are in Bold Italics

Please note Part 2 report is now confidential appendix.

PL 20.087 P KD5177 Part 1

London Borough of Enfield

Portfolio Report

Report of: Mark Bradbury – Director of Property & Economy

Doug Wilkinson – Director of Environment &

Operational Services

Subject: Whitewebbs Park Golf Course

Cabinet Member: Cllr Caliskan – Leader of the Council

Cllr Dogan – Cabinet Member for Environment &

Sustainability

Executive Director: Sarah Cary – Place

Ward: Chase

Key Decision: KD5177

Purpose of Report

1. This report details the reasons for marketing Whitewebbs Park Golf Club

(WPGC) due the ongoing cost of operating the course and recommends that the

golf course provision remains closed pending the announcement of next steps on

the leasing of the site.

This is a major change to the park and is being proposed without consultation with the park stakeholders

2. Whitewebbs Golf Course has been run at a significant cost to the Council

for several years despite measures to reduce costs and attract more

income. Continuing to absorb those costs is not financially sustainable

especially when there is alternative provision for golf in the borough.

The financial analysis included in the report is flawed, as has previously been explained and should be challenged. (in summary, the financial analysis includes all sorts of debatable costs that give entirely the wrong impression of the actual operating costs);

3. A robust marketing process to secure a tenant for Whitewebbs Golf

Course; setting out clear requirements around the experience and

financial standing of bidders and detailed requirements around securing

enhanced public access; maintenance of woodland and open areas; a

wider range of leisure activities; provision of refreshment and welfare

facilities and public engagement; has been carried out. Conclusion of the

process has been delayed due to both the council and some bidders

prioritising other matters during the pandemic however it is expected that

the Council will be able to announce next steps later this spring.

Such public engagement as there has been due solely to the efforts of the community. Right from the start we have been fed misleading information and forums for discussion have been closed down (Green Belt Forum, for example). Even a Senior Council official admitted  publicly that the process was mishandled. Has the Council conveniently forgotten the massive response to the petition?
Since the process started there has been a massive change in circumstances which the marketing process has failed to recognise.

We have been told that no decisions will be made until after the “Blue and Green” consultation has been done.  We are not aware of the results of this consultation. Friends of Whitewebbs, along with many others submitted detailed  responses.

4. The golf course has been closed since 4th January and the Government’s

Roadmap out of Lockdown currently indicates that it could reopen from

28th March.

PL 20.087 P KD5177 Part 1

Proposal

5. In view of the ongoing cost to the Council of operating the course and the

expected announcement regarding the leasing of the site it is

recommended that: –

i) The Director of Environment & Operational Services is authorised to

close the golf course with immediate effect.

Reason for Proposal(s)

4. Year on year WPGC has been run at a significant cost to the Authority. Since

2014/15 the service has reduced its annual expenditure by approx. £208k and

During this time, significant measures have been taken to improve the online

profile and accessibility of the golf course, whilst, new marketing campaigns have

been undertaken. Despite these measures, the number rounds of golf played has

continually fallen and annual income has fallen consistently since 2016/17

The figures for the post lockdown period indicated a month for month increase in income of over 80% compared with the previous year. £187,520 as opposed to £103,504 for the equivalent four months of the previous year. This was real money coming in. An income of between £200,000 and £300,000 could be expected over the next six months. Again, this would be real income. Is the Council so flush with money that it can disregard real cash income?

5. Portfolio decision KD4849 in March 2019 delegated authority to re-market

WPGC, taking a more flexible approach in order achieve a sustainable future that

optimises delivery of the Council’s Corporate Objectives. On 11 April 2019, the

Overview & Scrutiny Committee agreed to confirm the decision.

6. Following a two phased marketing process, 6 bids were received and evaluated.

The evaluation process identified a clear highest scoring bid which most closely

met the Council’s requirements.
At this stage the Council had promised to consult “Stakeholders”. Stakeholders  represent a wide range of interests – Friends, wildlife organisations, sports, youth groups, golfers, all approved and recognised by the Council.This has not been done

7. Shortly following the evaluation process the implications of managing the Global

COVID19 Pandemic meant that the priorities of both the Council and many of the

bidders changed and progression of the marketing process was deferred. At this

stage one of the bids was withdrawn.

9. Officers have recently been able to progress the evaluation process and it is

expected that an announcement regarding next steps should be made shortly.

10. Closing the course whilst this is finalised will reduce ongoing operational losses.

There are many courses in Enfield and the surrounding area, many of which will

welcome new members and players. Pay and play golf is available at both Crews

Hill and Trent Park courses.
How does closing the course to reduce operational costs when closure takes place at the period of peak income work. This is like closing Hamleys Toy Store for the two months before Christmas.

While there are other golf courses last year demonstrated that there was not the capacity to meet demand. Golfers reported great difficulty in obtaining a playing slot. Private courses put their prices up, Whitewebbs did not  but raised its income  by selling more of its premium priced slots.

Relevance to the Council’s Corporate Plan

13. Financial resilience and good governance

Closure of the course will ensure that we target resources smartly and reinvest

income wisely to deliver excellent value for money in all that we do.
As has been pointed out on many occasions the business model for Whitewebbs is very poor. The café has been kept small thereby limiting the rent that can be charged and the  old Golf Club is let out at a very low rate. No golf course survives on green fees. It would be good to have seen some smart and wise investment in Whitewebbs under all administrations.

Background

14. Whitewebbs Park Golf Course (WPGC), is an 18-hole course located at

the northern border of Enfield. The golf course requires significant

investment to bring it to modern standards.

15. The site has two basic club houses, one of which (Southern Clubhouse) is

leased as a private members club and is dilapidated; a pro shop and a

mobile catering concession. The property has significant challenges,

PL 20.087 P KD5177 Part 1

including, but not limited to, Green Belt planning designation and licensing

restrictions

16. WPGC includes Whitewebbs Woods, and pockets of parkland adjacent to

the golf course. Whitewebbs Woods is deemed ancient woodland and is

classed as a Site of Metropolitan Importance for Nature Conservation

This is completely misleading. Whitewebbs Park was purchased by the then Local Authority in 1931. Subsequently a golf course of just over 100 acres was constructed leaving  about 140 acres of woodland /parkland. Whitewebbs Park contains the golf course. The golf course does not contain the park and woodland. Please remember the anger and offence caused by your initial marketing material which dismissed the ancient woodland as “adjacent land”.

17. Whitewebbs House is located within the grounds of the WPGC site but is

separated from the property titles and is not subject to this report.

Whitewebbs House was leased to Whitbread PLC in 1998.
What responsibilities does the lessee have for maintaining the grounds of Whitewebbs House. The fencing is in a disgraceful state and the grounds are neglected. Is this another case of poor lease enforcement or was the lease poorly constructed?

18. The Authority manages and maintains the entire WPGC site. The site’s

revenue streams including, green fees, golf membership, equipment hire,

retail sales and a license income from a mobile catering concession.

17. Employment at the site is made up of pro shop staff and grounds

maintenance staff. The Authority currently employs the following at

WPGC:

· Golf Development Officer

· Golf Shop Service Assistants x 2

· Assistant Greenkeepers x 2

The Greenkeepers not only support the golf course but make a contribution to the wellbeing and enjoyment of all visitors. The course is  beautiful and a major contributor to the biodiversity of the whole park.

18. Year on year WPGC has been run at a significant cost to the Authority.

Since 2014/15 the service has reduced its annual expenditure by approx.

£208k. During this time, significant measures have been taken to improve

the online profile and accessibility for the golf course, whilst, new

marketing campaigns have been undertaken. Despite these measures,

rounds of golf played has continually fallen and annual income has fallen

by approx.

 £49k between 2016/17 and 2019/20.

See the comment above re the council’s accounting

19. Due to the Covid-19 pandemic, WPGC was closed from mid-March 2020

until 2nd June 2020 and again on 4th January 2021 and 28th March 2021.

During these golf course closures, the maintenance schedule continued,

so the site operational expenditure costs have generally continued to be

incurred. Whilst there was an increase in bookings during the summer this

was considered a temporary situation where existing golfers made up for

lost rounds during lockdown, it is expected that the overall net cost of

WPGC for the 2020/21 Will remain similar to those of the previous years

(shown in paragraph 18).

Main Considerations for the Council

20. Whitewebbs Golf Course has been run for several years at a cost to the Council.

Closure of the course will reduce those costs and release funding to meet

Council priorities.

PL 20.087 P KD5177 Part 1

21. There are several other courses in the borough, including three owned by the

Council, and more in the surrounding area that offer opportunities for golfers and

prospective golfers to enjoy or take up the sport.

Whitewebbs is a public course where anyone can play.  It is not a Club where you have to pay a high annual fee, wear the right fashionable gear or respect the club captain’s parking space.  Other courses exist but they are further away (more traffic, more pollution) and it will become more difficult for players to get a playing slot.  Prices will be higher.

Safeguarding Implications

22. It is not considered that there are any safeguarding implications arising from

these decisions.

Public Health Implications

23. Closing the course and allowing greater public access to this site will encourage

physical activity and provide added exposure to the natural environment which

will also improve mental health. Enfield is well served with golf courses so it is

not considered that there will be a significant impact on participation in this sport.

“Closing the course ………… will encourage physical activity”  Radical thinking indeed.
Has a study been made of the capacity of the available courses? If not, “well-served” is meaningless.
The Friends of Whitewebbs have put forward a number of practical and affordable suggestions to council officials to improve public access to the parkland. It has also submitted proposals as part of the “Blue and Green strategy” consultation. All parks are under increased pressure  as a result of the changes in people’s work life patterns caused by the pandemic. There is a need, recognised by the Blue and Green paper to take this into account.
If the Council does not need the potential income from the golf course this year, perhaps it could be used to make improvements to the park – paths, signage, drainage, fencing

Equalities Impact of the Proposal

24. A scoping assessment has concluded that an equalities impact assessment is

neither relevant nor proportionate for the approval of this report.

Equal opportunities – “A scoping assessment (whatever that is) concluded that an equalities assessment is neither relevant  ……..” This is one of a very limited number of public courses in the area. No membership qualifications, low fees, anyone can play. Since when has open to all not been relevant to equal opportunities?

Environmental and Climate Change Considerations

25. In the short term, the proposals are likely to reduce vehicle trips which will have a

positive impact on carbon emissions given that transport (predominantly fossil

fuel- based road transport) is accountable for 39% of the borough wide total (as

measured in 2018).

No it won’t – golfers will be expected to travel further by car to all those courses which you seem to think will have spare capacity.

26. Going forward, there are opportunities to look at the role the site can play in

contributing to the Council’s Climate Action Plan ambitions for additional tree

planting and an increase in the quality of the biodiversity offered in the borough.

It should be noted that the environmental and climate change implications of

specific proposals will be considered as part of related decision-making reports.

There appears to be a mistaken view, probably from those who have never visited the park, that the golf course is a barren waste of grass monoculture devoid of any biological activity. Nothing could be further from the truth. It is very similar in character to Crews Hill golf course which has SINC (Site of importance for Nature Conservation).  Even a cursory glance at Google Earth would show the mix of trees, hedgerows, thickets and water courses present. It provides biological corridors connecting Whitewebbs Woods with Forty Hall. Studies have identified large amounts of bat activity on the course and around  the wooded margins. It is a mature landscape with a mix of vegetation and animal life. Woodland is not the only habitat for animal life.  Traditional forests, like Enfield Chase, are a mix of trees and open spaces not  closely packed trees

Risks that may arise if the proposed decision and related work is not taken

27. If the Authority was to continue the operation of the golf course it would continue

to be at a significant cost to the Council.

See comments about  accounting above

Risks that may arise if the proposed decision is taken and actions that will be

taken to manage these risks

28. Closure of the Golf Course may reduce participation in the sport but as detailed

in the report there are numerous courses nearby many of which will welcome

new players and members to help ensure their ongoing viability. At least two of

these, Crews Hill and Trent Park Golf Courses offer competitively priced pay and

play options.

See above for comments on this assertion

Financial Implications

29. The report recommends that the golf course provision remains closed. The

closure of the Golf course will still require some maintenance of the area pending

the decision on leasing the site, these costs will be met from the existing Parks

and Open Space maintenance budgets.

See above for comments on loss of real income   £200,000 to £300,000

PL 20.087 P KD5177 Part 1

30. Due to the Covid-19 pandemic, WPGC was closed from mid-March 2020

until 2nd June 2020 and again on 4th January 2021 and 28th March 2021.

During these golf course closures, the maintenance schedule continued,

so the site operational expenditure costs have generally continued to be

incurred. Whilst there was an increase in bookings during the summer this

was considered a temporary situation where existing golfers made up for

lost rounds during lockdown, it is expected that the overall net cost of

WPGC for the 2020/21 Will remain similar to those of the previous years

(shown in paragraph 18).
The assertion that  “Whilst there was an increase in bookings during the summer this

was considered a temporary situation where existing golfers made up for lost rounds during lockdown,” needs  support from evidence. Those of us who visit the park daily saw and met many players new to the course who could not get a slot elsewhere. The new players were pleasantly surprised by the quality of the course – a credit to the greenkeepers.

Legal Implications

31. There is no statutory legal duty to consult on the proposed closure of Whitewebbs

Park Golf Club.

32. There is a however a public law duty to consider. Specifically, a duty may arise

because parties to be consulted have a legitimate expectation of consultation,

which results either from a promise or from an established practice of consultation.

32. The Council is required as a best value authority under section 3 of the Local

Government Act 1999 to make arrangements to secure continuous improvement

in the way in which its functions are exercised, having regard to a combination of

economy, efficiency and effectiveness. This report indicates that continuing to run

at a loss is not financially sustainable for the Council and the benefits of the

proposals need to be balanced against the loss of community interests.

33. The Council also has a general power of competence under section 1(1) of the

Localism Act 2011 to do anything that individuals may do, provided it is not

prohibited by legislation. A local authority may exercise the general power of

competence for its own purpose, for a commercial purpose and/or for the benefit

of others.

34. Public law principles will apply to the decisions made by the Council, including the

Council’s duty to take account of its fiduciary duty and to act prudently with public

monies entrusted to it. The Council is also under a general duty to act reasonably

and show that its decisions are made after having given due and proper

consideration to all relevant factors.

Whatever the legal requirements the Council has agreed to consult with stakeholders before any significant decisions are made. The Blue and Green  strategy paper recognises that  only a partnership of the local authority and the Friends and user groups will produce affordable positive outcomes. Consultation is a two way process if it is to work for the benefit of all. Imposition by a particular interest group is not consultation.

Workforce Implications

35. There are currently 5 staff directly employed by LBE at WPGC.

Business Development Officer-Golf

Golf Course Shop Assistants x 2

Assistant Greenkeepers x 2

36. Under the proposed changes to the site due to there being potential

redundancies a separate restructuring report will need to be produced and the

Council’s Principles of Managing Re-organisations will be applied. This would

include consultation with staff and trade unions in accordance with statutory

regulations and Council guidelines.

37. The Council will seek suitable alternative employment for staff to avoid/minimise

redundancies. If redeployment proves unsuccessful, a redundancy payment and

early retirement benefits will be payable as appropriate to eligible employees in

accordance with the Council’s current policy.

PL 20.087 P KD5177 Part 1

Property Implications

38. This report has been written with input from the Strategic Property Services

team. Property implications are therefore embedded within the body of this

report.

Other Options Considered

39. To continue to operate the golf course. Continuing to run this at a loss is not

financially sustainable in a competitive market with many other courses in the

surrounding area several which are struggling to be viable

Conclusions

40. The Council operates Whitewebbs Park Golf Course (WPGC) but this is at a cost

to the Council. A robust marketing exercise has been carried out and an

announcement on next steps is expected in the near future.

41. In the meantime, the course has been closed since 4th January due to the latest

lockdown. Under the current Government Roadmap out of Lockdown it is

possible that the course could be reopened from 28th March. In view of the

ongoing cost to the council of operating the course and the alternate provision

available in the borough it is recommended that the course is not reopened.

Report Author: Mark Bradbury

Director of Property & Economy

Date of report 10 March 2021

Dead foxes in and around Whitewebbs Park early 2021. The following email was sent to various councillors

Dear Councillors
I and others are very concerned about the possibility that foxes are being  killed in the area of the green belt that includes Whitewebbs Park. There is one known case of a fox being shot and injured  and subsequently being found dead on the golf course. I saw the animal myself. Other foxes  have been found dead without sign of injury. Many of us have heard the sound of shotguns being fired, mostly to the north east of Beggars Hollow. The paths are now so muddy in that area that access and close monitoring is difficult.
This statement was received from one of our members:

“I have become concerned with the number of dead foxes I am finding around the Forty hall estate and whitewebbs. Only one had been shot (inhumanely not a clean kill which is illegal)the others have looked in good physical condition well fed and no mange. In the last 5 months I have found 6 with another 2 reported on Saturday 23rd January by a fellow dog walker. Two had been hidden under some old fence panels behind the Tottenham training ground. I suspect they are being poisoned. Poisoning foxes is illegal and also poses a problem to dog walkers as foxes will cache food for later use which could also attract the attention of our dogs. The met police wildlife unit are now involved but in order to get the toxicity testing done we now need each find to be recorded with date approximate location and if possible a photograph. I know that foxes get very mixed reactions but if you feel that you would like to help please let us know of any finds especially in Archers wood and surrounding field area. Thank you.”

I have a photo of one young fox recently found dead with no signs of external injuries in Whitewebbs.
The Council is a proud  proponent of Biodiversity in Enfield and while foxes are not universally popular with farmers they, as native mammals,  have as much a part to play in the biodiversity of the green belt of Enfield as any other animal. 
Has the Council or other authority permitted or licenced the use of firearms, including shotguns, in the area south of the M25 and between Theobald’s Park Road and Bulls Cross?Has the Council licensed the use of poison for the control of foxes in the area, or any other part of Enfield for that matter? Is the Council aware of any action by any individuals or organisations to eradicate or control foxes in the area?
As you are only too well aware we have no knowledge of who is bidding for leases to manage and develop leisure activities in Whitewebbs Park.  Could we have your assurance that no individual or organisation that has been responsible for the deliberate killing by poison, shooting or other means of foxes in the green belt of Enfield will be considered  as a bidder ? We also ask that the Council require that bidders give a signed  affidavit that they have not and will not engage in any such activities, recognising that any such activity would invalidate their bid and any lease granted.
This issue has raised a great deal of interest and I would welcome a response from you that can be disseminated to our members and other interested parties.
Yours sincerely
Sean Wilkinson Chair of the Friends of Whitewebbs Park

Reply from Cllr Ian Barnes

Thanks for your email Sean. I see that Cllr Yusuf is looking into it so I’ll leave in his capable hands.
Best wishes,

Councillor Ian Barnes
Deputy Leader of the Council

Correspondence with Councillor Hass Yusuf

Hello Sean – good to hear from you and hope you are well.
I will make an official enquiry on your behalf, but I doubt very much that fox culling is on the Council’s agenda. Clearly we cannot let this disgraceful matter to continue.
As you know biodiversity is very much something that the Council protects and encourages.
As for gun-shot noises that could possibly be because of clay pigeon shooting nearby? I know former councillor Vicki Pite had some casework involving that issue.
Whoever is awarded the Whitewebbs licence will have to strictly adhere to Council policy.
I will get back to you as soon as I hear anything.
All the best,
Hass
Cllr Hass Yusuf Chase Ward

Dear Hass
Thanks for your prompt reply. I am sure  that it was not clay pigeon shooting – wrong direction and  just a few shots. One of the people who reported it to me is familiar with shooting practice.
I am grateful to you for taking an immediate interest.
Best wishes
Sean

No problem Sean – like yourself I do take the environment and biodiversity very seriously. Foxes play an important part in our green spaces – and even urban areas – by keeping rats at bay I hear!
I wish I could give you an update on the Whitewebbs lease, but I too have no further information. But I would like it resolved so we can scrutinise and move forward.
Once I get some answers to your questions I’ll let you know. I have sent off the enquiry.
All the best,
Hass

Whitewebbs – footpaths and access   June 2020

At the beginning of the marketing of Whitewebbs Park process we, the public, were promised that “the Council will require that the current level of public access across the park will be maintained.”

As time went on this promise appeared to become diluted and was reduced to an assurance that “rights of way” would be protected. Apart from the North South sections of the bridleway there are no “rights of way” in the park.

Earlier this year  I submitted a map showing the current  footpath pattern and heard little back from the Council other than an acknowledgement. No doubt the Covid 19 crisis has pre-occupied the time available to officers.  Follow up letters with support from Cllr Pite produced a very encouraging response from Mark Bradbury. (see below)

This will be very welcome news to all users of the park. During the period of “lockdown” we have seen a massive increase in the number of people using the park. Since the car park was re-opened we have had many visitors from all over the borough. The park has never been busier both in the woodland and  on the golf course.

Letter from Mark Bradbury June 2nd 2020

Classification: OFFICIAL

Sean,

My apologies for the slight delay in responding. As you say these are challenging times.

Please be assured that no decisions have been made nor will they ‘slip through’. I am aware that there may be rumours but can assure you they are just rumours.

The process has been on pause for obvious reasons and the bidders made aware. We are now beginning to look at how we now proceed to the next steps in a way that takes account of restrictions on holding meeting or events. We will communicate this through the website in due course and I will be in touch to arrange a meeting with you/the Friends as a stakeholder before any decision is made.

As regards public access the position remains as per the marketing literature ie

Retention or enhancement of public access

There are a number of footpaths and permissive footpaths running through the property, mostly through the woodland area. LBE is seeking a proposal that will, at a minimum, retain this level of public access.

I have now had the opportunity to review the plan you sent through showing footpaths and bridleways across the site. As you acknowledge most of these are not shown on ordnance survey maps as they focus on public rights of way and bridleways.

As you also acknowledge some of the informal paths will vary either seasonally or over time. Also a number of the bids propose additional planting and/or rewilding so it is possible that some informal routes may need adjustment to reflect this, so whilst I cannot confirm that every informal path shown on your plan (attached) will be maintained exactly as set out on that plan, we will not select a preferred bidder unless their proposal maintains or enhances the level of public access provided by them. All Public Rights of Way, Bridleways and Permissive paths will also be retained or enhanced.

I hope that gives you both clarity and reassurance.

I am aware that you have also written to ward councillors advising of use of the course in the last couple of weeks by golfers. Safety of our staff and customers was our priority but you will be please to note that the course reopened on Saturday and more details are here https://new.enfield.gov.uk/whitewebbsgolf/coronavirus-covid-19-update/

I hope my response give your reassurance that no decisions have been made and that we remain committed to the requirements in the original brief including those around the retention or enhancement of public access, maintenance of woodland and open areas and the provision of refreshments and welfare facilities.

Best wishes

Mark

Mark Bradbury MRICS, FRSA, FIoEE

Director of Property and Economy

Enfield Council

We the undersigned:

1. call upon the Council to avoid any measures or developments that will in any way restrict the citizens of Enfield from freely enjoying full access to the woodlands, amenities, current physical activities, golf and the open spaces of Whitewebbs Park.

 2. ask that the Council restrict developments and landholding in the park to those that will maintain full use of the park by ordinary citizens and to those that will not damage or radically change the atmosphere, usage and environment of the park.

3. ask that no development will be permitted that will have an adverse effect on the climate and air quality of Enfield through construction work and traffic generation.

4. Ask that nothing be done that will adversely affect the ancient woodland and biodiversity of the whole park.

5. ask that there be full public consultation with all interested park users before any proposals are agreed and implemented.

On Sunday 12th January, after less than a week, we have 2122 signatures on the on line version and an additional 100 on the paper version. Enfield will only “count” those from people living or working in Enfield but additional support will be appreciated and valued. Please leave comments.
The link for the online petition can be found on the petition page of this web site.

The proposals for  Whitewebbs Park – a commercially flawed and damaging proposal.

1. A council document KD Num:4849 gives the reasons for marketing a 25 year lease for the Whitewebbs Golf Course.  The extent of the Golf Course is clearly  delimited on the maps prepared by Enfield’s Asset Information Team. There is a clear line between the golf course and the rest of Whitewebbs Park. There is no mention in  KD Num:4849 of the rest of the park.  I have not seen the justification for including the woodland area in this leasing proposal.
2. While the golf course can be described as a commercial venture the recreational woodland can not. It is a park, just like Forty Hall, Broomfield, Arnos, Grovelands, Trent and all the others in the borough and no one is planning to privatise the management and development of these, to my knowledge.
3. Regrettably, businesses are not geared up  to manage recreational, publicly accessible  woodland. Business in the UK is geared up for short term profits especially when working within a 25 year lease. Short term commercial benefit will always override long term  community benefit. Otherwise, there would be no need for the National Trust, the Woodland Trust, National Parks, the Forestry Commission, tree preservation orders and municipal parks. Dare one refer to what is happening on a far vaster scale in the Amazon? Whitewebbs  Park is registered by the Forestry Commission as “Ancient and semi natural woodland”
   Any company taking over Whitewebbs Woods would take out the valuable timber, calling it “thinning” or “forestry management” and leave the land to fend for itself. There are at least  25 trees in Whitewebbs marked discreetly with  blue paint. They are all tall straight oaks close to the bridleway and, therefore, accessible  by vehicle. This may be a coincidence but mature tall straight oak trees are commercially valuable. They could repeat the process in 200 years time. It takes about 50 years of careful management for deciduous woodland to start making a financial return.  On a 25 year lease  it is going to be no more than asset stripping.  Of course, some vandal might want to replace the ancient woodland with Christmas tree production.
   It may be argued that  lease conditions  will be strict but the officers and councillors responsible for drawing up these documents will probably be long gone before the lease is even half way through its life. The same could be true of the company owners / directors who agreed the deal. The lease details must be published and accessible if the park is to be protected .
4. The Golf Course, while it is a valuable aid to  both mental and physical fitness, could be described as a business. Business advisors I have contacted tell me that a 25 year lease is too short a period for there to be sound development and long term investment. Long term capital investment is most unlikely, particularly in the uncertain world of sports facilities. Golf is  suffering more than most with many courses closing. A brief survey of  golf courses for sale in the south of England shows that they can be purchased, with full facilities such as  function rooms, dining capability, changing rooms, showers, bars and parking for less than a four bedroomed house in some parts of Enfield.
   Short term profits will be the order of the day – landscaping with landfill (who is going to check every one of 17,500  20 tonne trucks?) There will be enormous pressure, salami style, for some release of  “just a few acres” for housing land. Once the short term profits have been made, distributed to share holders and consultants, we will be left with a golf course no better, possibly worse, than before and the development company will have quietly gone into voluntary liquidation.
   Whitewebbs Park and Golf Course are not going to be generators of huge sums of money, at least not for the Council and the ratepayers.
5. Whitewebbs is accessible only by car for the vast majority of potential users. Yes, there is an hourly bus service but not on Sundays. The assertion in the Knight Frank prospectus that Crews Hill and Gordon Hill stations provide suitable access points is surely a joke. If the park and any new sports facilities generate many more visitors the green space they have come to enjoy will have to be covered  by a lot more tarmac for car parking.
6. In summer that park is beautiful, in winter it is used by the hardiest – dedicated golfers, keen runners and dog walkers. The land is muddy, paths are waterlogged and the Beggars Hollow car park is icy. To many of us it is still beautiful.
7. Developers could replace golf with a range of other activities – a massive investment would be required but Enfield is actually well supplied with easily accessible facilities. Playing fields, formal and informal abound, there are  multi use /  basketball courts in Tuckers (North Enfield Recreation ground) the Town Park and others, there are free to use tennis courts; school playing fields can be and are hired; netball courts, athletics tracks, swimming pools, fitness facilities and of course the private commercial centres such as David Lloyds are all readily accessible. All these are close to population centres and easy to get to by public transport. It may be that indoor facilities for younger people are not adequate but the difficult to get to Whitewebbs is not the place for them. There is little commercial point in  setting up another  “Go Ape” in the borough and the park is unsuited to massive  music events and shows.
8. What should happen at Whitewebbs? In the park we have well over 100 acres of mature woodland, we have an adequate golf course with an average of over 25000 rounds of golf played annually, we have the Toby Carvery, we have a golf club that has some sort of relationship with the course but is a private club and occupies a building  in a poorish state, we have some public toilets, a bridleway for riders, car parking and a slightly upgraded version of a burger van for refreshments. The refreshment facility pays a rental of £10,000 p.a. and is on a very short lease. No sensible business person is going to invest heavily in good  facilities when on a short lease, it is unreasonable to expect that.  Despite its shortcomings the café is a vital part of the Whitewebbs community. Hundreds use it every week to meet up, socialise, relax and refresh themselves after a walk or half way round the golf course.
   The golf club and the Toby Carvery are  part of the park and I don’t know what contribution they make to the council’s budget. They are users of the park, even it is just enjoying the setting and ambience. To disregard any financial contribution they make is unfair to the park, just as it would be to exclude the rental for the café  from the park accounts.
   The figures in the Knight Frank prospectus  show that the Golf Course runs at a small loss. Every Golf Club includes income from function hire, catering and bar sales in their overall income. The golf course is trying hard to  build business and lower costs in a very competitive market. The figures show  that the losses are small, equivalent to a cup of coffee or tea per round. Weather conditions and equipment purchase affect income and expenditure. Setting the modest café rental against the losses would have  made the course break even for two of the last three years. The café is on land designated as part of the golf course. It is unreasonable to expect the Golf Course to break even within these restrictions.
   A way forward would be  to offer a 25 year lease to an enterprising and enthusiastic café owner  who would provide good facilities for all users of the park. With the right lease terms, he or she would invest in the business, pay  a much higher rent (or percentage of takings) to the Council. A community hub or hall could be provided, catering for a wide range of activities, children’s parties, puppy training, wildlife clubs, art exhibitions, Golf Club functions ……….. . There could be pop up shops for special events. The more attractive the facility, the more people will use it, the greater will be the income. Providing a children’s play area would attract many more families.
9. Whitewebbs Park and the Golf Course are important to the physical wellbeing of us all. We are all being reminded of what we have to do  to preserve and protect our planet. Whitewebbs is important to the physical and mental well being of the Enfield citizens who use the park. It is a place where the very young can experience nature and where the more mature can rebuild themselves with fresh air, tranquility and calm social interaction with friends and new acquaintances.
10. Please check the comments page to see the views of others who have added their views to the site. Please add your comments and please spread the word  through social media, personal contact and by contacting your ward councillors.

This correction to the prospectus issued by  their agents, Knight Frank, has been made.

 

The Council will consider bids that involve landscaping projects within Whitewebbs, which involves importing soil onto the land and is an approach often used for golf course developments.   The wording ‘inert material’ within the marketing materials was incorrectly used and we would like to thank the individual for bringing this to our attention. The wording should have referred to ‘soil’ or ‘specified soil and aggregates’. Soil is not classified as ‘inert material’, as it contains nutrients, whilst ‘inert material’ indicates waste/landfill, which would not be permitted by the Environment Agency.  Any proposed landscaping scheme will need to demonstrate that it complies with strict CL:AIRE (Contaminated Land: Applications in Real Environments) or Environment Agency permits requirements.

To clarify further, any landscaping scheme would be subject to planning approval and any granted permission is likely to be subject to conditions to mitigate any impact of the scheme. As Whitewebbs is within the greenbelt the application would need to demonstrate how the scheme will not negatively impact the local environment, including the type of materials used in a scheme and a construction management plan.

We have taken action to clarify the Council’s position, by updating and re-issuing the marking details with the more detailed specification in line with Environment Agency requirements.

 

It would be  really helpful to have some expert views on the implications of this change.

Commercially, this could be significant for a Whitewebbs developer. Inert material is building waste that developers will pay a high price to get rid off. Landscaping with it can generate a very high income for  the landscaper.

Soil, specified soil and aggregates could be a different matter. Topsoil as any gardener or farmer knows is a valuable commodity. Clean aggregates are valuable materials for construction projects, road builders  and the like. Neither topsoil or clean aggregates are given away. There are many grades of soil,  complex definitions of contamination and an abundance of regulations such as those alluded to in the Council’s correction. See the links below:

http://topscape.co.uk/portfolio-item/unearthing-the-truth-about-topsoil/

https://www.urbanregen.co.uk/technical/Permitting-Exemptions-WRAP-CL.AIRE-CoP.pdf

It really would be great if some knowledgeable person could provide some guidance on the implications of this correction.

I suspect that, if implemented effectively, any developer would be faced with a  very high net cost for landscaping rather than a very high net profit.

Sean