COPY OF A LETTER SENT TO BRAINTREE DISTRICT COUNCIL RE: PLANNING APPLICATION 17/00017/FUL
7th February 2017
FAO: Ms Katie Towner
Braintree District Council
Planning Application 17/00017/FUL
Land South of Hudsons Hill, Hedingham Road, Wethersfield
We have received notification of the planning application listed above. We have also received requests for Wethersfield Parish Council (WPC) to respond with any comments by 8th February.
As this timescale of the request from WPC is not in accordance with the statutory consultation period prescribed in the The Town and Country Planning (Development Management Procedure) (England) Order 2015, we will respond herewith with our initial comments by the 8th February as requested but we reserve the right to modify or add to our comments until the prescribed period of 21 days from the date that the site notice was erected, which was 27th January 2017. This will allow WPC to carry out its duty to receive representations from parishioners. This is particularly relevant in this instance as we are holding a public consultation meeting on 13th February where we expect local views will be expressed on this application and other local planning issues.
We have been puzzled why there have been specific requests for comments on this application to be received in a shorter time than the statutory framework defines as we can see no reason for such special treatment of this application and we would be grateful for an explanation for this at your earliest opportunity.
References to recent Draft Local Planning Process
We note that this application is presented with significant reference to the recent draft local plan process and representation made to the (Braintree District Council) BDC planning subcommittee that WPC “supported” the inclusion of this site in the draft local plan and consequently is supportive of this application.
We have made representations to BDC that WPC’s position was fundamentally misrepresented (by the same party who is the applicant in this case) to the BDC’s subcommittee. We will be making further representations to BDC ahead of a final decision on the draft local plan to correct this misrepresentation and its affect upon the subcommittee’s decision.
For absolute clarity, we state that WPC resolved in November to offer no objection to the inclusion of this site in the draft local plan. This in no way offered any kind of “support” for its inclusion. This was also on the proviso that this would be subject to full public consultation, as this site had been submitted to the local draft planning process at the very end of the consultation period and parishioners in Wethersfield had had virtually no time to comment to either BDC or WPC.
Consequently, WPC has never offered any direct or implied support for this application at any time. Much like the submissions to BDC’s planning subcommittee, by the applicant, we feel that this application misrepresents WPC’s position.
A public consultation meeting has been arranged in Wethersfield on 13th February which will gather views on the local draft plan proposals and no doubt on this application.
Provisional Comments on the Application
WPC has considered the application within the prevailing planning framework for Braintree district i.e. the current development plan, the 2005 Local Plan and Core Strategy 2011.
With reference to our comments re the draft local plan process above, we regard any reference to the draft local plan process as irrelevant and invalid with regards to this application.
WPC opposes the application on the following grounds:
1. Village Development Boundary
The proposed development site lies outside the defined and defended built up development envelope of the village of Wethersfield. The eastern boundary of the application site is some 150 metres beyond the east of the adopted development boundary separated by the village playing field. Therefore, it is not a natural extension to the development of Wethersfield, as it would extend the built development area into an open farmland between the recreation ground and a farmstead of buildings at Parsonage Farm, not in accordance with the development boundary amendment methodology.
Furthermore, the Site Allocations and Development Management Plan 2014 as amended, in effect a review of housing sites and settlement boundaries, did not make any further proposals in respect of the Wethersfield boundary or identify the application site as a development opportunity.
2. Conservation Area
The site lies within the Parish conservation area and we can see no reason presented that proposed development will do anything to protect or enhance the conserved area in terms of character and landscape.
3. National Planning Policy Framework
The site is in contravention of the National Planning Policy Framework as this requires BDC to assess sites on the basis of:
lesser environmental value, in accessible locations, close to public transport, services and job opportunities, recognising the intrinsic character and beauty of the countryside, conserving heritage assets and to respond to local character and history and reflect their surroundings, and be well integrated into the natural, built and historic environment.
This proposal is not presented with any arguments as to how it complies with these requirements and in our view, fails in all regards.
4. Highways and Access
The proposed access to the highway is deemed to be dangerous and unsuitable for additional vehicular access. This proposed development would involve a new vehicular entrance onto Hudson’s Hill close to the brow of the hill only just inside the speed limited section.
5. Topography and Landscape
The topography and landscape of the proposed site means that it would stand high on a hill top overlooking the village and could be seen throughout most of the village and would disrupt the protected character of the historic market village of Wethersfield. Wethersfield has highly attractive landscapes of the open countryside around the village. It has been well protected by the WPC and BDC for decades and hardly any new development has been permitted outside settlement boundaries other than where supportive of open land and consistent with the landscape character. The views from and towards the village are of a special quality and need to be protected. The proposed development is in contravention of a policy of defending the development area boundary that has been pursued by BDC and WPC for many years. We can see no argument to set any precedent in this case.
6. Local Views and Housing Need
In 2015/16 WPC carried out a survey of local views. With regards to housing, parishioner’s views were; “Whilst a majority of respondents were satisfied with the housing provision within the parish, a significant minority felt there was a need for more housing suitable for first time buyers and also within the social housing sector.” This proposed development makes no contribution to meeting this need.
7. Village Amenity
The proposed site borders a recreational and sports field which benefits greatly from having neighbouring open land in terms of reduced liability of any potential encroachment of sports activity (cricket balls etc.). Any development of this site might lead to restrictions of recreational activity which would mean reduced amenity generally within the village.
8. Community Contribution
The proposal brings no additional value to the village in terms of planning gain, enhanced facilities or amenity, or any employment opportunities and can only increase demand upon local public amenities with no proposals as to how this would be alleviated.
As previously stated this is a provisional submission from WPC and we reserve the right to submit additional comments within the statutory timing window.
On behalf of Wethersfield Parish Council
Alison Lucas (Mrs)
Clerk to Wethersfield Parish Council
cc Ms Tessa Lambert – Braintree District Council
Cllr Peter Schwier – Braintree District Council
Cllr Peter Tattersley – Braintree District Council