Planning Application Comments / Objections

Some were sent in by way of the planning portal, others were submitted as letters and emails.

These are copies of submissions by objectors. Personal details have been removed, other than that they are unedited.

Comments Details
Commenter Type: Member of the Public
Stance: Customer objects to the Planning Application
Reasons for comment: – Affect local ecology

  • Conflict with local plan
  • General dislike of proposal
  • Inadequate access
  • Inadequate parking provision
  • Inadequate public transport provisions
  • Increase danger of flooding
  • Increase of pollution
  • Information missing from plans
  • Loss of parking
  • More open space needed on development
  • Noise nuisance
  • Not enough info given on application
  • Other – give details
  • Out of keeping with character of area
  • Over development
    Comments: I object to this planning application because:
  1. Whitewebbs park is a crucial and valuable public green space.
  2. The proposed development is incongruous with the existing landscape and introduces an industrialised form of leisure into a natural area to which there is currently public access. This is quite different from when the golf course was landscaped which had far less impact on the park and anyway has been open to the public and since closure of the course it has rewilded to become a more natural landscape.

The proposed construction of the pitches will fundamentally alter the park’s landscape. The levelling of approximately 40 acres of land for the pitches will create a major transformation and will amount to a permanent change.

  1. The high fencing that will enclose the area will drastically alter the landscape, making it akin to a constructed development. The fencing and earth barriers (bunds) will obstruct views across the park, particularly the crucial southward views from Whitewebbs Lane, as noted in the Local Plan. The tree planting programme will further obstruct the views and those trees planted on top of the bunds will in effect increase the height of the bunds.
  2. The application will negatively impact protected views. The proposed tree planting will alter the park’s character and obstruct the open, expansive views from Beggars Hollow car park northwards. While previous work by the applicant may seem unrelated, it is pertinent to reference the fencing and surroundings of the existing training ground, as it provides context for the potential impact on the park’s landscape.
  3. The proposal contradicts the draft Enfield Local Plan’s policy BG6 on safeguarding the Green Belt and historic landscape/features. The proposal also conflicts with the London Plan policies G2 and G4, which aim to protect the Green Belt and ensure open spaces, particularly green spaces, remain publicly accessible. While the applicants argue that the proposed change is only to 18% of the leased area, it is 50% of the open space the rest being woodland.
  4. At a time when both Enfield and the London Mayor have set goals to enhance and expand wild spaces and habitats for nature, this proposal will destroy essential natural space, replacing it with engineered surfaces. It will also significantly impact the surrounding environment due to increased light (from floodlighting) and noise. There will be a loss and deterioration of veteran and notable trees, and potentially ancient woodland, which are irreplaceable habitats that need protection.
  5. The character of the area surrounding the lake will be severely impacted by the proposed access road for the Carvery. Increased traffic will disrupt the area’s tranquility, disturb wildlife and nesting birds, and pose a hazard to pedestrians. These factors collectively contribute to a substantial and negative transformation of the park’s landscape and environment.
  6. Public access to the new facility will be highly restricted, and removing the car park at the North end will further limit accessibility in particular to those who access the park from that end.
  7. The application includes a consultation to which there were 118 feedback responses. The Friends of Whitewebbs survey had Just over 750 respondents, and therefore should be included in the Planning Committee’s consideration of this proposal.

Whitewebbs should remain a public park with full public access, preserved for the mental and physical well-being of the community, offering opportunities for exercise, relaxation, and connection with nature.

Dear Enfield Council,

This is my objection to the planning application “24/00987/FUL”.

There are many points stated in Tottenham Hotspur’s (THFC) plan that I feel are unsound when referencing the National Planning Policy Framework, Sites of Importance for Nature Conservation (SINCs) and Metropolitan Green Belt laws.

  1. Changes to the Landscape and Character of the Land
    There will be a significant change in landscape to approximately 50% of the former golf course. THFC will build 2 metre high fences, which will impact on the openness and character of the park. Dense tree plantations and hedges both around these fences and across the park will further harm the feel and design of the park as it was intended. These proposals will obscure panoramic views from Whitewebbs Lane looking south and south west; views from the current footpath through the centre of the former golf course looking north and north east; dense tree planting will obscure views from the south of the park, near the café, looking north west. The metal fences will not be in keeping with the natural character of the Green Belt land. Obscuring views and the impact this has had are also already evident in their current training grounds – THFC have blocked the view from Whitewebbs Lane with similar approximately 2 metre high fences and hedges. For these reasons, I believe the plan is unsound as THFC will destroy view Important Local View “6. Whitewebbs Lane” which is protected in Policy DE5 of Enfield Council’s Local Plan.

In addition to obscuring views, the 21 metre tall floodlights THFC propose will be out of keeping with the character of the land too.

THFC propose to level out the land, which changes the character and landscape of the Park.

They will build attenuation ponds, which are also out of keeping with the natural landscape.

In and around the lake and north eastern Whitewebbs Woods area will also be seriously reconstructed (see point 6).

  1. Rescheduling of Land
    The disposal plans for Whitewebbs are not consistent with the “statutory purpose” of the land, which is to be held as open space land on trust for the public (a purpose for which it was acquired using public funds when it was purchased in 1931 by Enfield Council using public money). The lease and plan will extinguish public rights to access these facilities, and therefore is unsound: see NPPF para. 154 (b).

This planning application is not in line with Enfield Council’s current draft Local Plan (see NPPF para.: 006 Reference ID: 21b-006-20190315), as in this plan, Table C1.184 Design Principle A states that development on the site (i.e. Whitewebbs Former Golf Course) “must maximise publicly accessible space”. Since there will be a loss of approximately 50% of the open Green Belt space in Whitewebbs Park, THFC’s planning application is unsound. THFC also fail to take into account NPPF para. 103 – neither section (a), (b) or (c) are met for this planning application.

  1. Change of Use for Private Usage
    Whitewebbs is intended for recreational and leisure use already and should not be rescheduled for private use by professional elite athletes. It should be kept open to the public it was intended for. The proposal also focuses sole for the commercial benefit of one corporation (i.e. THFC) – any community benefit promised in these proposals would be peripheral. For the same reasons as my second point, this planning application is unsound: see NPPF para. 154 (b). THFC also fail to take into account NPPF para. 102 – there is no need for extra private sporting facilities in the borough.
  2. Physical and Public Accessibility
    Even if the proposed training facility allowed public access, it would be inaccessible to most of the borough and people in Enfield to enjoy sport, because it is situated in the very north of the borough and has little to no transport infrastructure, therefore requiring a car to be able to visit.

The park is already being used for leisure and sporting activities (walking, running, cycling). For this reason, the planning application is unsound: see NPPF para 104 – THFC will in turn extinguish public rights to their lease area, not enhancing public access.

There is no provision for parking at the Northern end of the park. If the current car park near Whitewebbs Road were to be removed, this will diminish access to the park from the North.

Attenuation ponds further reduce public access to the Park.

  1. Health and Wellbeing
    This planning application focuses solely on the health and wellbeing of a tiny proportion of the young female generation (since it will be a women’s training centre), many of whom will not even be from Enfield. Most of the public will not be able to practice or engage in sport in this setting. This is an inappropriate strategy: the planning application is not in line with NPPF para. 96 (c).
  2. Harm to Whitewebbs Lake and Consequent Traffic
    In THFC’s proposals, Whitewebbs Lake’s character will be drastically altered, such as destruction to the surrounding woodland to create what THFC calls “restoring the historic carriageway” in order to reroute the access road to the Toby Carvery. The harm to wildlife both habitat and sound pollution wise will be devastating.

By creating a new access road, there will be greatly inflated numbers of cars passing through the woodland. The noise and brightness (i.e. car headlights) of this traffic will disturb wildlife and will create pollution. Since there is little to no public transport infrastructure around the area of Whitewebbs, this will require athletes to use their car. This does not “Promote Sustainable Transport” between para(s). 108-117 in the NPPF.

  1. Biodiversity, Wildlife and Habitat Loss, plus Historic Parkland Restoration Model
    “Restored Historic Parkland”: the proposals and photos on p. 77 in THFC’s “SECTION EIGHT: DESIGN RESPONSE – LANDSCAPING” document suggests no benefit to the Park. Except for intense and unnecessary tree planting which will alter the character of the Park, they are stating what is already there.

Despite THFC promising the creation of wildflower meadows, there will not be enough compensation at Whitewebbs for currently present open and diverse grassland. 50% of this grassland will be lost to monoculture football pitches and astroturf. Open grassland is vital for butterflies, spiders, bees, small mammals and an abundance of insects such as beetles, and with THFC’s tree planting proposals, this is not recognised (NPPF para. 180 (b)).

The destruction of this grassland and trees also creates an added risk of flooding. While THFC propose to create attenuation ponds, I do not believe this to be the answer. Not only does it harm the natural landscape, it creates the need for displacing large amounts of earth, in turn harming the soil. From RHS: “Digging damages soil structure by destroying natural drainage channels made by worms, disturbing fungal networks, and releasing carbon that’s locked in the soil”. Attenuation ponds will take up 2 areas of active meadowland, which is already draining well. There is little ecological benefit of these, since the adjacent beaver flooding project, promise of the Dickenson Meadow project, and the existing wetland in the wooded margins are solving flooding in a natural fashion.

Sand bunkers will also be destroyed, which are home to rare and unique examples of mining bee habitats. They also house ant colonies and other important insect life.

The issue of felling 137 trees is unsound under Green Belt character protection framework (see point 1 and NPPF para. 180 (b)). THFC will also fell an additional 70 “Category U” trees – the argument for felling these trees because of “good arboricultural management” is flawed, since dead and/or decaying trees are vital for the ecosystem, housing an abundance of insects, birds and wildlife.

Floodlights as part of THFC’s proposals will not only have an impact on the character of the Park (see my first point); they will have a great impact on bats, owls, moths and other nocturnal wildlife, along with sleeping wildlife too.

While THFC might talk about “biodiversity net gain” in their proposals, “Biodiversity offsetting is wrong because it is based on an allegedly false ontological assumption that loss of natural value can be compensated for by creating at least equally valuable units of nature”. – Karlsson M, Edvardsson Björnberg K. Ethics and biodiversity offsetting. Conserv Biol. 2021;35(2):578-586. doi:10.1111/cobi.13603.

Any Green Belt destruction is out of keeping with the Mayor of London’s (Sadiq Khan) London Plan 2021 policy G2 para. 8.2.1. This planning application will harm and destroy the Green Belt as it was intended, and therefore does not ensure “continued protection for London’s Green Belt” – note THFC acknowledge in para. 8.56.4 of their “Planning Statement” document that their proposed developments in regard to Green Belt will have “moderate harm in respect of Whitewebbs Park”.

  1. Alternative Sites not Exhausted
    There are other sites that could be used for a professional women’s football facility. An obvious example is using a couple of THFC’s current 17 pitches. Not to use these pitches, or focus on non-Green Belt sites is unsound: see NPPF para. 186 (a).
  2. Inappropriate Use of Green Belt
    This is not an appropriate use of Green Belt Land when compared to other options – i.e. maintaining the full accessibility of this Green Belt land for public use. I do not agree with THFC’s arguments around Green Belt exceptional circumstances. How is this an appropriate strategy/use when taking away a large area of land from the public, rescheduling the land as an elite professional training centre, spoiling the important view from Whitewebbs Lane, and importantly damaging wildlife and biodiversity?
  3. Heritage
    THFC must restore the Grade II listed North Lodge building on Whitewebbs Road. THFC has neglected this building since purchasing it.

Comments Details
Commenter Type: Member of the Public
Stance: Customer objects to the Planning Application
Reasons for comment: – Affect local ecology

  • General dislike of proposal
  • Inadequate access
  • Inadequate parking provision
  • Increase of pollution
  • Loss of parking
  • Noise nuisance
  • Other – give details
  • Out of keeping with character of area
  • Over development
  • Strain on existing community facilities
    Comments: This is public land situated within the greenbelt which should remain as greenbelt land. This park land was left to the people of Enfield in 1931 who are the beneficiaries of this public green space in line with the original lease documents regarding Whitewebbs Park and public land use issued close to 100 years ago. The original intention was to provide open space for the enjoyment of physical activity and access to nature; this was essential during Covid and the park remains increasingly busy as a consequence. The proposed changes will significant limit public access to the north of the park due to the removal of the existing car park area which Spurs alleges attracts anti social behaviour. This means there will be no provision for public parking at the northern end of the park, which is meant to be for the people of Enfield as the actual intended beneficiaries if the access changes. Traffic that is generated along the proposed access road as a result of this change to accessing the Toby Carvery restaurant by car will disturb the wildlife, particularly in the lake area as well as the peace and quiet for any people using the area. It will be dangerous to pedestrians and will disturb nesting birds of which there are many species including bats. There will be an increase in traffic if the whole proposal to change the use of the northern end of the park gets approval. Whitewebbs Lane already experiences significant traffic delays and congestion particularly when there are issues with accidents or hold ups at junctions 24 and 25 on the M25 which regularly create traffic issues and havoc in this part of the borough often bringing it to a complete standstill. The borough is meant to be reduced carbon emissions which are already compromised by current traffic congestion in this area so any new development which encourages an increase in traffic to Whitewebbs Lane is going to increase carbon emissions in the borough. When we have experienced heavy rainfall Whitewebbs Lane is prone to considerably flooding causing additional traffic congestion and impacting upon carbon emissions due to traffic jams as a result of road flooding. A change of access road in this area to accommodate a new Spurs training facility will have a significant and negative impact for all of the above reasons.

Ecological perspectives.

This development sits between 3 Sites of Metropolitan Importance for Nature Conservation (M011, M141 and M155). Had Enfield Council done a competent SINC review (using GIGL data & endorsed by the GLA Review Board) the site would undoubtably have been designated a SINC and afforded protection. It is inexplicable that such a large area of trees and grassland sitting between three Met SINCs was not designated, if only as a wildlife corridor. The developer’s EIA (para 4.2.2) identifies multiple Habitats of Principle Importance and highly protected species (grass snake, Great Crested Newts & 10 bat species). These would have been flagged had LUC consulted GIGL data as is a basic requirement of any ecological assessment in London. Whitewebbs clearly merits SINC designation in its own right, even more so situated as it is in the middle of 3 Met SINCs. The Cuffley Brook, which runs through the site, is itself a priority habitat. As if the situation could not be more absurd the site also abuts Enfield’s much publicised beaver enclosure containing the first beavers to be reintroduced in London!

Failure to designate the Whitewebbs site is a breach of the council’s duty to protect biodiversity under the Environment Act, a breach of the London Plan and Enfield’s Local Plan. It renders the entire planning process for this development unlawful since it is based on a false designation of the development site at a time when the development was in its preliminary stages. Any planning permission if granted will be vulnerable to legal challenge. The multiple breaches of good practise in the SINC review and the perverse failure to designate, coupled with the timing and financial context of this development appear to suggest deliberate exclusion of the development site from the SINC review specifically to unlawfully facilitate development.

The conclusions of the EIA are perverse. The loss of 16 ha grassland, 0.28 ha woodland and 0.1 ha scrub plus 120 trees cannot result in a 20% gain for biodiversity by levelling the site and covering it with artificial football pitches! The EIA airbrushes the tangible and verifiable losses whilst grossly inflating purely hypothetical benefits. Even worse, we know that the applicant, Tottenham FC, have completely failed to deliver on previous promises to enhance habitat a planning condition of their existing training ground. So we know the promises of biodiversity enhancement are worthless. The EIA is not an ecological assessment but a public relations pitch based on flawed data, a flawed assessment and a misuse of the BNG metric to construct a false gain to mask what will undoubtably be a huge net loss for biodiversity.

Scrub and woodland are regenerating themselves quite happily and whilst wildlife friendly habitat management could benefit parts of the site it cannot mitigate the loss of 16ha of grassland, the woodland, the scrub and 120 trees that are currently a huge wildlife corridor connecting the three adjacent metropolitan SINCs. The loss of connectivity alone represents a huge biodiversity loss in no way remedied by the proposals, so Logika do not even mention it! The EIA is not a scientific or professional document. It is a sales pitch. Logika failed to access non-GIGL data and unilaterally excluded all wildlife records over 10 years old! The EIA is biased toward development resulting in false finding of 20% BNG that bears no relation to reality. The baseline used for the BNG Matrix calculation is flawed due to the weak and unjustifiable data restrictions and adoption of a biased Scope of Assessment.

Logika fail to identify decaying wood habitats within trees planned for removal even though these are noted in the Arb Impact Assessment. Logika have skewed the baseline to minimise the true value of the current habitats and invent a theoretical gain which is absolute nonsense. What they are advocating is destruction of 50% of a site that contains numerous protected species and should currently be a designated SINC.

Veteran trees contain irreplaceable habitats under NPPF and despite claims to the contrary the development threatens these habitats in two ways. Firstly, irreplaceable habitat is listed for removal and secondly veteran trees to be retained cannot be protected as claimed in the AIA.

Many trees listed for felling should not be felled. For example, trees T275 and T269 are large dead oaks listed for felling “if within target of proposed road”. Thanks to their large root plate diameter and decay resistance old dead oaks rarely fall over. Purely on a risk management basis the proposed felling is highly questionable. However, it is extremely likely that these trees contained Cubical Brown Rot which takes decades to develop and is an irreplaceable habitat protected by NPPF. Therefore, even though they are dead, these trees must be retained because the habitat they contain is irreplaceable.

Many of the other trees listed for felling are perfectly ok with existing site use. It is the imposition of a high use/high target value that increases risk management requirements. Most of these trees have significant habitat value (e.g. listed in the tree schedule as cavities, splits, fungi, decay, deadwood, etc.) and this loss of habitat is not recorded in the flawed BNG metric calculation or the ecological impact assessments. It’s not even mentioned. T187 is an example. This is clearly full of veteran tree habitat features and is described as having good epicormic growth. It should therefore be retained as a possible veteran but if designated for felling it should be accounted for not just as a generic tree loss but a habitat loss of veteran tree type habitat. (Note that since this tree is a lime with Soft Rot and not an oak the decaying wood habitat may not meet the NPPF irreplaceable habitat threshold, but it is nonetheless host to numerous of species of fungi and invertebrates, not to mention possible vertebrates like bats or owls, the loss of which is not acknowledged). Horse chestnut T61 is another example of a tree with high habitat value designated for felling but not captured in the BNG calculations. Trees like these, together with many ash listed for removal, are of greater value precisely because of the parkland, open mosaic setting which is ideal for species diversity. Significantly Logika fail to address this habitat on site, mentioning saproxylic species only in relation to the ancient woodland. This exposes an inexcusable mistake in equating ancient woodland rather than open grown trees with high quality saproxylic fauna. Illustrating this point the rare hoverfly and bumblebee mimic Pocota personata was recently recorded (2023) on an ash tree on Whitewebbs former golf course. This is only the third London site to record the species in the last 50 years! Saproxylic species generally require decaying wood in open grown trees where there is more light and heat as compared to closed canopy woodland. They also require flowing shrubs like hawthorn nearby. The impacts on saproxylic species of losing significant volumes of high value decaying wood by removing 120 trees is not even mentioned in the EIA. It is massive loss not accounted for at all.

There are examples where the EIA’s flawed logic and hypocrisy are obvious. In the Scope of Assessment (para the risk of invasive species is discounted (footnote 26) because “none were recorded on site”, yet at para three invasive non-native species are noted within the Whitewebbs woodland (part of the development site) and one is on Sch. 9 WCA. So when a justification to lower the baseline habitat score and threat to the ancient woodland INNS exist, but when the developer might have responsibility to avoid spread they do not. Again at para existing footfall, traffic and dog walking are used to argue that the development impacts will be low but no account is taken for the fact that disturbance will increase dramatically with the proposed intensification of use. These are clear examples of the bias and lack of integrity that pervade the EIA. More significant bias, some of which is outlined above, is less transparent because the arguments and ecology are complex. It is easy to hide behind simple assertions when in fact the authors know, or ought to know, they are misleading or untrue, e.g. dismissal of pollution risk to waterways and neighbouring sites or the ludicrous 20% BNG claim.

Proposed tree removals in the Arb Impact Assessment (AIA) are unnecessary and result from the change of use, not inherent risk. As noted above they also represent significant biodiversity loss not accounted for in the BNG metric because there they are just treated as generic trees, not trees with decay and other habitat features

Returning to veteran trees and irreplaceable habitat. The proposed mitigation for intrusions into tree Root Protection Areas (RPAs) are extremely unlikely to work in such a large-scale landscape alteration scheme. The development proposes huge dislocation and movement of soil. The proximity of proposed retained veteran and Grade A trees to these major earthworks means the proposed RPA protection measures will not work. The scale of protection and supervision required to protect tree roots of multiple trees in close proximity to major earth works rarely results in successful tree retention. Furthermore, veteran trees should have extra-large RPAs (minimum 15 x diameter), a metric not recognised or applied in the AIA mitigation proposals. Instead of following this Natural England guidance on 15 x dia for RPAs the AIA adopts BS5837 12 x and a cap of 707m2. The failure to note and acknowledge this special requirement for veteran trees is particularly concerning given the purported mitigation plans for protection of these trees’ root areas and their irreplaceability. In reality the protection for retain veterans is nothing of the sort and the development risks significant loss of NPPF protected veteran trees.


To Planning Department Enfield Council
Planning Application: 24/00987/FUL – Former Whitewebbs Park Golf Course
The proposed development is out of character for the site and will result in significant change to the landscape in this part of the Green Belt. Around 17.5 hectares of grassland habitat will be destroyed to accommodate the proposed training facility in Planning Application: 24/00987/FUL – Former Whitewebbs Park Golf Course.
The proposals fall within an Area of Special Character (1994 UDP), following recommendation by the Countryside Commission, English Nature, English Heritage and the London Ecology Unit based on its combined landscape, historical and nature conservation interests. The AoSC review 2012 states that; ‘’The Whitewebbs Park and Forty Hall character area is an area of undulating woodland, parkland and pockets of open fields drained by a criss‐cross of watercourses. The area incorporates Whitewebbs Country Park and…parklands of Forty Hall… and much of it is publicly accessible open space. Each area has its own unique character and distinct identity but the boundaries between them are blurred, and the area can be experienced as a single area’’.
The AoSC Review 2012 states that, “The rural parklands of the borough are popular
destinations for recreational visits… valued for the recreation facilities they offer and also for their visual qualities…” The area should be retained for public access. A survey of 750
Whitewebbs Park users notes the 1. Overwhelming support for the park remaining as open
space with full accessibility to all areas. 2. All users recognise the value of the park to public
mental and physical well-being. 3. Even allowing for demographic differences the park is used significantly more by women than men. Reasons for this need to be explored but anecdotal evidence suggests that the open nature of the park and the park community make for a feeling of safety’.
Fencing and Bunds will disrupt the open views across the park and the openness of this part of the Green Belt. Fencing, netting and additional screening trees will interrupt protected views as noted in the recent Draft Local Plan. Views at Whitewebbs should be protected across the parkland. The addition of security points and additional access roads will further impact upon the openness and character of the area. The area is currently open and accessible to all. The inclusion of the new fences, laurel hedging, earth bunds, high netting around pitches, security fencing and security points will disrupt this openness. The requirement for a new entrance shows incompatibility with the current land use and impacts upon the Ancient Woodland. There is likely to be an increased in car journeys following the opening of the site due to the lack of public transport. The current car parking facilities for members of the public will be lost.
The site has a rural setting within the Green Belt that currently has public access to all areas of the parkland, there are no current restrictions on movement by the public across the site. The proposals restrict public access. There are car parking facilities for the public in the north at present, the plans make no allowances for public car access in the north in the future. It is noted in the recent Judicial Review by Judge Mould that…”in my view, it is clear that football academy and training facilities […] are not facilities which, to any significant degree, will be accessible to the public for recreation […] The opportunity for members of the public to access that facility for recreation are likely to be very limited and subsidiary to that principal purpose”.
The training facilities could be located away from the rural location at Whitewebbs. By locating these facilities near user groups and areas with a higher population density this would enable community users to access the facilities in a more sustainable way e.g. Enfield Playing Fields.
There is limited public access by sustainable transport. Turkey Street station is a considerable distance, with a walk-through isolated paths and single lane roads. Bicycle travel is difficult with gradients and curves along single lane roads. The proposals would lead to an increase in car journeys in the local area and this is does not meet sustainable transport targets.
The 2021 Draft Local Enfield Plan designated the area at Whitewebbs for ‘Nature Recovery’.
The proposals for levelling the landscape and pitches will significantly alter the character of this landscape. Other plans for land adjacent to Whitewebbs de-commisoned golf course include planning proposals for a Nature Reserve at Dickenson’s Trough Meadow. These plans were deemed to be suitable for this site and represent, a ‘Nature Recovery’ proposal as outlined originally in the 2021 Draft Local Plan. The area adjacent to Whitewebbs Park de-commissioned golf course was chosen for the London Mayor’s Re-Wild London Fund for the creation of a Beaver Enclosure, licensed by Natural England. Herts and Middlesex Wildlife Trust undertook a Survey for the land that is used for the Enfield Beaver Enclosure in September/November 2021.
This survey states “Surrounding land: sheep and cattle grazed grassland in the south, industrial area in the north and north-east.” The term ‘industrial’ is used to describe the current Training facilities at Hotspur Way, replication of these facilities will result in significant change to the current landscape at Whitewebbs.
Section 175 of National Planning Policy Framework outlines Natural England’s Standing Advice on Ancient Woodland as does The London Plan 2021 Policy G7 Trees and woodlands, states that Boroughs should 1) protect ‘veteran’ trees and ancient woodland where these are not already part of a protected site. Ancient woodland, ancient trees and veteran trees are irreplaceable habitats. Therefore, you should not consider proposed compensation measures as part of your assessment of the merits of the development proposal…you should consider, conserving and enhancing biodiversity, avoiding and reducing the level of impact of the proposed development on ancient woodland and ancient and veteran trees.

Mitigation should include making use of the existing entranceway that is currently present. The new access route proposed to the Toby Carvery, to the west of the lake will result in the loss of veteran trees. Protected species such as the Purple Emperor may be lost from this site with the current plans for tree felling for the new access route. The access road does not allow adequate buffering for the Ancient Woodland. Veteran trees should be protected across Whitewebbs in line with paragraph 180 (c) of the NPPF’.
The proposed new carriageway would see traffic run either side of the lake. The Environmental Impact Assessment submitted does not include any bat records for this woodland lake area.
The Whitewebbs area is home to at least 10 species of bat (Logika 2024). This includes the
records of a Barbastelle bat (Logika 2024). Further surveys should include the lake area. The low number of Myotis sp. recorded (Logika 2024) is linked to the water feeding behaviour. Daubenton bats hunt over the woodland lake in the Summer. The impact of passing cars has not been considered in the mitigation plans for this light sensitive species. Further bat surveys of the site around the woodland lake should be undertaken.
Biodiversity Net Gain documents provided raise several issues. ‘Trading Rules not satisfied
Input Error – trading rules not met –.” “Irreplaceable habitat at baseline – yes – attention
required”. These issues in the spreadsheet make it difficult to assess how a 10% Biodiversity Net Gain has been achieved. This spread sheet with these errors should be remedied before planning consent is given. The Construction Environmental Management Plan for Dickenson’s Meadow by Logika (2022) notes that Point (page 5) “desk study and observation from the adjacent woods and golf course have identified badger, water vole, great crested newt and a range of bats as being
present. It is considered highly likely that other herptiles, breeding birds, hedgehog and range of notable invertebrates are also present on the Site or in its immediate surrounds”. In point of the report, it states that “Badgers are known to be active in the area with signs of activity recorded in 2022 from the decommissioned golf course immediately adjacent to Dickenson’s Meadow. It is likely that badger will use the Site for foraging, although potential for sett building will be limited by the regular winter flooding of the area. Priority habitats and species should be protected at Whitewebbs. Further understanding of how badgers now use the site following the enclosure of Archer’s Wood with its Beaver proof fencing should be undertaken.
The London Plan 2021 Policy G6 Biodiversity and access to nature 3) support the protection and conservation of priority species and habitats that sit outside the SINC network and promote opportunities for enhancing them using Biodiversity Action Plans. The London Plan also states that (Boroughs) 1) use up-to-date information about the natural environment and the relevant procedures to identify SINCs and ecological corridors to identify coherent ecological networks.
A range of priority species are present at Whitewebbs. These include 8 London Priority Butterfly species, and the area supports 28 species of Butterfly, indicating a semi-neutral and relic acid grassland on site. The removal of around 17.5 hectares of this grassland will turn the proposed training area into an ‘industrial’ landscape.
LUC SINC Review 2020 table 2.1 states that “Sites of Metropolitan Importance for Nature
Conservation are those sites which contain the best examples of London’s habitats, sites which contain particularly rare species, rare assemblages of species or important populations of species… They are of the highest priority for protection. The identification and protection of Metropolitan Sites is necessary, not only to support a significant proportion of London’s wildlife, but also to provide opportunities for people to have contact with the natural environment.” The site is adjacent to the ‘Re-Wild London Beaver Project’, a new nature reserve and three sites of Metropolitan Importance for Nature Conservation. The SINC review by LUC 1.3 notes that Priority Habitats “include good quality semi-improved grassland” and “green corridors – a network of natural and semi-natural habitat, which connects wildlife populations in areas.” The loss of this semi-neutral grassland and creation of an ‘industrial’ landscape will also fragment the current green corridor that exists between the three Metropolitan Sites of Importance for Nature Conservation at Whitewebbs Wood, Forty Hall and Hillyfields.
Current mitigation plans for a green corridor along the north of Whitewebbs Lane, between the current and proposed training ground are inadequate and could be expanded. The proposed plans require the use of a public lay by to support with access to the Whitewebbs facility via the Hotspur Way site. Further explorations of this entrance to the site could be explored but has not been. This may avoid damage to Ancient Woodland and Veteran Trees on site. By significantly reducing the number of pitches planned on site, the ecological corridor could be expanded beyond the proposed size. This may allow for retention of priority habitats and suitably sized ecological corridors with buffer zones around the woodland.
The de-commissioned golf course area sits outside of the SINC network, it contains priority
species and is an important ecological network between the three MSINCs locally as noted by Logika (2022) in Point and of the report; “desk study and observation from the adjacent woods and golf course have identified badger, water vole, great crested newt and a range of bats as being present… also present on the Site or in its immediate surrounds” this is in addition to the 8 London Priority Butterfly present. The habitats that support these species are at threat from the proposed developments.

More Comments and Objections

Commenter Type:

Member of the Public


Customer objects to the Planning Application

Reasons for comment:

  • Affect local ecology
  • Conflict with local plan
  • General dislike of proposal
  • Inadequate access
  • Inadequate parking provision
  • Inadequate public transport provisions
  • Increase danger of flooding
  • Increase of pollution
  • Information missing from plans
  • Loss of parking
  • More open space needed on development
  • Noise nuisance
  • Not enough info given on application
  • Other – give details
  • Out of keeping with character of area
  • Over development


I object to the Spurs planning application for the following reasons:

The Spurs plans are not in character with the existing open land which is currently accessible to everyone, and which has been like that for a very long time. The existing landscape would be permanently changed. Previously, as a golf course it was an open landscape as it is now and, importantly, it was a public golf course for the use of everyone who wanted to use it. Access for members of the public who were not playing golf was never restricted. If the Spurs plans go ahead the result will be a massive loss of public access to the open land area of the park – about 50%. That’s about 40 acres which will be enclosed behind their metal fencing and boundaries (similar to those that can be seen at their existing training ground).

Spurs is a premier league football club and thus has as its aim for its football academy and training centre to develop elite professional footballers. If their plans go ahead a massive part of the leased land will not be accessible to the public for leisure/recreation. This point was made by the judgement in the recent judicial review.

The Spurs plans would require the destruction of a huge area that has renatured since the golf course was closed – this has happened with no need of any help or financial input from Enfield Council. This would have an enormously detrimental effect on wildlife and biodiversity which we know is being lost at an alarming rate. There will be an increase in noise, fuel and light pollution (from floodlighting) all of which will be harmful to trees, plants and wildlife.

The Spurs plans would see 25 healthy trees as well as groups of trees removed from the pitch area. In total, 109 trees and six groups of trees would be removed. I wish to point out that when the golf course was constructed (105 acres) in 1931, only 31 trees were removed. Removing trees, particularly older and established trees cannot be justified at this time of climate emergency. A replacement tree planting programme – even if many of the replacement trees are mature – cannot match the benefits of the trees that have been there undisturbed for many years and which provide habitat for so many species.

The application is not in keeping with what is understood by Green Belt land. It is contrary to the Mayor of London’s policies and what is outlined in the Enfield Local Plan (policies G2 and G4 which are about preserving green open spaces and ensuring that those that are accessible to all remain so). The Local Plan (DE5) also states that protecting views is important. The Spurs proposal will result in loss and disruption of important views. For example, southwards from Whitewebbs Lane views will be blocked by the fences and the planting of trees to hide the pitches. Objections have already been made to the Local Plan re the sweeping views northwards from the Café looking towards Whitewebbs Lane. These views are no less important and they should be included. Worryingly, the Spurs planning application has chosen viewpoints from public footpaths that deliberately obscure views across the park.

The character of the currently peaceful area around the lake will be replaced with traffic using the proposed entrance to the carvery. This will transform the lake area into a noisy and more polluted space. All forms of wildlife will be disturbed. This would be an important change in the landscape and the character. It will no longer be a haven for people who need peace and quiet for their mental health.

Whitewebbs is currently a public open space which is there for the benefit of everyone. Under the Spurs proposals the open parkland area would be reduced to approximately half the size it is now. The park is well used. That same number of people and dogs would be in a significantly reduced space, leading to overcrowding issues. It will no longer be a space for relaxation and a place where everyone can go to benefit their mental health, a much needed green space where anyone can go when they need space and peace and quiet.

The Spurs plans are for people to no longer be able to park at the Whitewebbs Lane end of the park. They would abolish the existing car park claiming that that it is used for anti-social behaviour. To be able to park at that end is important for anyone who lives nearer to that entrance or who arrives there from that direction. Re the anti-social behaviour claim, I personally am a very regular user of this car park and I have never seen anti-social behaviour. Anti-social behaviour can of course occur anywhere but to remove a car-park will simply result in it occurring elsewhere in the borough. On the other hand, it would be helpful and not enormously expensive to put up some cameras to deter such behaviour.

The Spurs plans have included only the two North South bridleways as statutory, there is no mention of the East West ones which is concerning. Their plans say that the one on the Eastern side of the park will be used by horse riders, walkers and cyclists with two different surfaces. This has the potential for being dangerous. For everyone’s safety bridle paths should be for horse riders.

Regarding permissive footpaths and bridleways, the maps provided by Spurs are inconsistent. They only mention plans to improve two footpaths within the leased area. Both of these paths are situated so as to lead people away from the pitches.

The Spurs plans describe the extensive reconstruction of the landscape that will be necessary including levelling of the land, fencing and bunds, so much so that the existing character of the area will be changed forever as, after 25 years, it could never return to being what it is now, ie a glorious parkland set in the Green Belt – a jewel which everyone who lives in Enfield can be proud of and which should be nurtured and protected. The existing open and spacious feel of the park would be gone. Very sad and unnecessary when one considers how it was valued by the North Middlesex Joint Town Planning Committee in 1930: “In the opinion of the Joint Committee the estate (Whitewebbs Park) forms part of the most beautiful stretches of the country in Middlesex”.

The planning application includes Spurs’ consultation programme. This was put together from just over 100 respondents and is selective and partial. Friends of Whitewebbs also conducted a survey of their own to which over 750 people replied. The findings of this survey was published on and made available to Spurs. I believe that Friends of Whitewebbs should be allowed to submit this survey and its comments to the Planning Committee.

There are a lot of people who object to Spurs leasing this beautiful public land only to ruin it as described above and make it inaccessible to most people in the area. If Enfield Council are determined to lease out some land to Spurs there would be much less opposition if they were to instead lease out part of the available land situated on the opposite side of Whitewebbs Lane to which the public do not have access.