Formal Objection, Freedom of Information Request and Request for Licence Suspension and Review
June 3, 2026
The Permitting and Compliance Team
Environment Agency
Copy to: Cllr Alessandro Georgiou, London Borough of Enfield Cllr Joanne Laban ; Cllr Andrew Thorp Cllr Edward Smith | Enfield RoadWatch Action Group | The Enfield Society | Feryal Clark MP
Permit Number: EPR/LB3300UN
Site: Holly Hill Farm, 303 The Ridgeway, Enfield, EN2 8AN (Grid Ref: TL2901600242)
Operator: Jackson Remediation Limited / Stockley Environmental Ltd
Date: 3 June 2026
Dear Sir or Madam:
RE: Formal Objection, Freedom of Information Request and Request for Licence Suspension and Review — Environmental Permit EPR/LB3300UN — Enfield Bund Soil Management Area, Holly Hill Farm, 303 The Ridgeway, Enfield EN2 8AN — Metropolitan Green Belt, Enfield Chase — Urgent Review in Light of Change in Enfield Council Leadership and Withdrawal from New Towns Programme
1. Introduction and Standing
I write on behalf of the Open Woods Community Project ('Open Woods'), a community-led environmental monitoring initiative conducting biodiversity and ecological surveys across the Metropolitan Green Belt in and around Enfield Chase, London Borough of Enfield. Open Woods gathers and publishes evidence of the natural environment of this protected landscape for the benefit of the local community and for future generations.
This letter constitutes: (a) a formal objection to the continued operation of activities under Environmental Permit EPR/LB3300UN at Holly Hill Farm, 303 The Ridgeway, Enfield EN2 8AN; (b) a formal request under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004; and (c) a formal request that the Environment Agency immediately review and suspend the permit pending full environmental and planning reassessment.
2. Urgent Context — Change of Enfield Council Leadership and Withdrawal from New Towns Programme
Open Woods writes at a moment of significant and urgent political change directly relevant to this permit. Following local elections on 7 May 2026, the London Borough of Enfield has a new administration. The Conservative Party won 31 seats (Labour 27, Greens 5), and Councillor Alessandro Georgiou was elected Council Leader on 27 May 2026, forming a minority Conservative administration supported on this issue by the Greens group.
On 28 May 2026 — just six days before this letter — Council Leader Georgiou formally wrote to the Minister for Housing and Planning, Matthew Pennycook, to withdraw Enfield Council from the Government's New Towns Programme, bringing to an immediate end the Council's support for up to 21,000 homes on 884 hectares of Metropolitan Green Belt land at Crews Hill, Chase Park and Vicarage Farm. In doing so, Cllr Georgiou stated:
"We have been elected on a clear mandate to protect Enfield's Green Belt, and today we are honouring that commitment by formally withdrawing from the New Town process. This does not mean stepping back from the challenge of delivering homes and jobs. We are committed to working with government to meet housing need, but in a way that protects our precious green spaces"
This decision was reported to reflect the democratic will of of the Enfield electorate, who voted for parties that explicitly committed in their 2026 manifestos to opposing the New Town proposals. Crews Hill had been identified by the Government as one of three sites to be fast-tracked within this Parliament.
This decisive change in the Council's position has direct and urgent implications for Environmental Permit EPR/LB3300UN. The Holly Hill Farm site at 303 The Ridgeway has been identified by the Enfield RoadWatch Action Group as one of the parcels of Green Belt land previously earmarked under the former administration for 11 hectares of industrial use and distribution east of Junction 24 of the M25 — development directly associated with the broader Green Belt allocation programme that the new Council has now repudiated. Open Woods submits that the new Council's position now demands that the Environment Agency urgently reassess whether operations under this permit remain appropriate, consistent with the planning status of this Metropolitan Green Belt land, and whether the permit was issued on assumptions about future development that have now been fundamentally undermined.
3. The Site and the Permit
Environmental Permit EPR/LB3300UN (Pre-EA Permit Ref: 404338), issued on 7 December 2018, authorises the operation of the Enfield Bund Soil Management Area at Holly Hill Farm, 303 The Ridgeway, Enfield EN2 8AN (Grid Reference TL2901600242), in the Whitewebbs Ward, operated by Jackson Remediation Limited with Stockley Environmental Ltd undertaking associated remediation and soil management works.
The site lies within the Metropolitan Green Belt and the Enfield Chase Heritage Area of Special Character. Open Woods has become aware, through direct field observation, that construction and remediation activity at this site has materially expanded and that the footprint and impacts of the site raise serious questions of environmental compliance and ecological harm.
4. Evidence of Environmental Impact — Open Woods Field Survey, 31 May 2026
On 31 May 2026, Open Woods co-founders conducted a monitored survey walk along the public right of way from Rectory Farm to the M25, directly passing Holly Hill Farm. The following was observed and published in the Open Woods field report of that date:
Construction site footprint and public safety: A large construction site was observed at Holly Hill Farm with earthworks and construction debris on and adjacent to the public right of way, making the path unsafe for walkers and unsafe for children. Path diversions around the site were poorly signposted, with negligible signage across the 6km route — only a single useful sign was recorded throughout.
Alarmingly high air quality readings: Air quality monitoring conducted during the survey recorded readings described as alarmingly high for Metropolitan Green Belt land. This strongly indicates that construction and remediation activities at the site are generating airborne particulate matter or emissions at levels inconsistent with the protected character of this landscape and requiring formal investigation under the permit conditions.
Biodiversity — diverse bird life including Skylark: A significant variety of bird species wasrecorded in close proximity to the construction site, including Skylarks - a Red List species of highest conservation concern under the UK Biodiversity Action Plan, not previously heard in this corridor. The presence of Red List species nesting and foraging adjacent to active industrial works engages statutory protections under the Wildlife and Countryside Act 1981 (as amended) and raises urgent questions about the adequacy of ecological protection under the permit.
Social weaving larvae spread: An alarming spread of social weaving moth larvae silk tents was recorded across Rectory Lane and near East Lodge Farm, likely promoted by the recent heatwave and potentially exacerbated by disruption to the vegetation structure caused by construction activity.
Dried-up watercourses: Natural streams in the vicinity of the site, including Turkey Brook, had dried up at the time of survey, raising questions about the hydrological impacts of site operations on local watercourses.
Fly-tipping and debris: Significant fly-tipping was recorded along the path after Tingey Tops. The demarcation of the construction operator's maintenance responsibilities relative to the public right of way and private land boundaries was not clear. Internet high fibre cables and construction materials were observed as part of fly tipping and litter evidence gathered.
Shotgun shells: Three empty shotgun shells were found at Holly Hill Farm with no apparent explanation.
The full field report, including photographs, biodiversity dashboards and air quality readings, is published at:
Open Woods Field Report — 31 May 2026: https://www.openwoods.org/reports/rectory-farm-to-windrush-may-31-2026
5. Green Belt Legitimacy — Permit Review Required
The former Enfield Council administration proposed the Holly Hill Farm area east of Junction 24 of the M25 for 11 hectares of industrial use and distribution as part of a broader Green Belt release programme. The new Council administration has now explicitly and publicly repudiated that programme. Open Woods submits that this creates an urgent requirement for the Environment Agency to satisfy itself that:
Operations under EPR/LB3300UN are confined to genuine soil remediation and waste management and do not amount to, or facilitate, ground preparation for industrial development on Metropolitan Green Belt land;
Any planning permissions associated with or enabling the current scope of operations at the site remain valid and consistent with the Metropolitan Green Belt designation and the new Council's adopted policy position;
The environmental assumptions underpinning the original grant of the permit in December 2018 remain sound, in particular any assumptions about the future land use trajectory of the site.
If operations under this permit were in any way predicated on, or have the practical effect of conditioning, the land for the industrial development that the new Council has now definitively opposed, then the permit requires immediate review.
6. Legal Framework
Environmental Permitting (England and Wales) Regulations 2016 (SI 2016/1154): the Environment Agency must ensure permit conditions are proportionate, adequate and enforced, and that permitted activities do not cause significant environmental harm.
Environment Act 2021: legally binding biodiversity targets; duty under s.40 NERC Act 2006 on all public authorities, including the Environment Agency, to conserve and enhance biodiversity.
Wildlife and Countryside Act 1981 (as amended): protection of all wild birds, nests and eggs;Skylark is a Red List species of high conservation priority.
Conservation of Habitats and Species Regulations 2017: precautionary principle applies where there is risk of harm to protected or priority species and habitats.
Water Resources Act 1991 and UK Water Framework Directive: protection of Turkey Brook and local watercourses from pollution or flow interference.
National Planning Policy Framework 2024, paragraph 153: substantial weight must be given to harm to the Green Belt; development not justified by recognised exceptions must be prevented.
Environmental Information Regulations 2004 (SI 2004/3391): right of access to environmental information within 20 working days.
Freedom of Information Act 2000: right of access to information held by public authorities within 20 working days.
7. Freedom of Information and Environmental Information Requests
Pursuant to the Freedom of Information Act 2000 and the Environmental Information Regulations 2004, Open Woods formally requests the following information from the Environment Agency within 20 working days:
A full copy of Environmental Permit EPR/LB3300UN and all conditions, schedules, management plans and associated documents, including the original permit application, any variations since issue, and the current permit conditions in force;
The Environmental Impact Assessment, environmental risk assessment, ecological survey reports,habitat assessments and biodiversity surveys submitted in support of the original permit application and any subsequent variations;
All compliance reports, monitoring data, inspection records and environmental sampling results submitted by the operator under permit conditions since 7 December 2018;
Records of all Environment Agency site inspections, audits and regulatory visits to Holly Hill Farm, The Ridgeway since permit issue, including any enforcement actions, warnings, notices or correspondence with the operator;
Any air quality, dust or particulate emissions monitoring data held by or submitted to the Environment Agency in relation to site operations;
Any hydrological impact assessment of site operations on Turkey Brook and other local watercourses;
All correspondence between the Environment Agency and Jackson Remediation Limited and/or Stockley Environmental Ltd regarding the scope, compliance and environmental performance of operations;
All correspondence between the Environment Agency and the London Borough of Enfield (both the former and current administrations) regarding planning permission, Green Belt to Grey Belt status, or the future land use of the Holly Hill Farm site;
Any assessment by the Environment Agency of the planning status of the land and whether operations under the permit are consistent with the Metropolitan Green Belt designation.
8. Formal Requests — Suspension and Review
Open Woods formally requests that the Environment Agency:
Immediately suspend or pause authorisation for further construction, earthworks and remediation activity at Holly Hill Farm under permit EPR/LB3300UN, pending a full review in light of the change in Council leadership and the ecological evidence now on record;
Conduct an urgent inspection of the site, with specific attention to air quality, hydrological impacts on Turkey Brook, proximity of Red List bird species habitats to active works, and conditions of the adjacent public right of way;
Review permit EPR/LB3300UN in full in light of the Open Woods 31 May 2026 field report evidence, the new Council's repudiation of Green Belt development at this location, and the question of whether operations are facilitating development on Metropolitan Green Belt land;
Formally engage with the new Enfield Council leadership to confirm the current planning status of the site and whether any consents associated with site operations remain valid in light of the Council's new policy position;
Exercise the Environment Agency's powers under the Environmental Permitting (England and Wales) Regulations 2016 to vary, suspend or revoke the permit if it is established that conditions are inadequate, or that operations are enabling development on Green Belt land inconsistent with the new Council's mandate;
Provide a formal written response within 20 working days confirming the steps to be taken that we may share with the local community.
9. Additional Context
Further information about the campaign to protect Enfield Chase and the implications for the Holly Hill Farm site:
Enfield RoadWatch Action Group: https://enfieldroadwatch.co.uk/supporters/
Enfield Council — Withdrawal from New Towns Process (28 May 2026): https://www.enfield.gov.uk/news-and-events/2026/enfield-withdraws-from-new-town-process-following-change-in-leadership
Yours faithfully,
Helen Moulinos
Co-founder, Open Woods Community Project
Enfield Chase, London Borough of Enfield | www.openwoods.org
