COPY OF LETTER SENT TO BDC Re: REMOVAL OF SITES WETH624 AND WETH636 FROM LOCAL PLAN
24th February 2017
FAO: Cllr Lynette Bowers-Flint
Braintree District Council Local Plan Sub-Committee
Braintree District Council
Proposed development sites WETH624 and WETH636, Wethersfield
We are writing to formally request that the decisions made at the Local Plan Sub-Committee meeting on 28th November 2016 with regards to the inclusion of sites WETH636 and WETH624 in the Draft Local Plan be reconsidered. We make this request following the opportunity for full consultation with residents and a better perspective on the impact of potential development of these sites since our original submission on the Braintree District Draft Plan.
Our reasons to reconsider the decisions:-
1. Public consultation
Sites WETH636 and WETH624 were submitted for consideration for inclusion in the Draft Local Plan on the last day of the consultation period in August 2016. This provided no time for the Parish Council, or Wethersfield parishioners, to consider or make representations about the implications of these sites during the consultation period. The Parish Council met on the 16thNovember 2016, when, in order to meet the deadline for submission of sites for the Draft Local Plan, it agreed to offer no objection to the inclusion of these two sites, with the caveat that this position would be subject to later full public consultation.
On 13thFebruary 2017, the Parish Council convened an extraordinary meeting to hear views on these sites (together with WETH414 which had been included in the earlier Draft Plan). The meeting was attended by approximately 100 residents, with the overwhelming consensus being that sites WETH636 and WETH624 should not be included in the Local Plan based on several genuine concerns as detailed below. Although discussed, there was minimal opposition to the inclusion of WETH414.
2. Misrepresentation to the Local Plan Sub-Committee meeting of 28thNovember
The Parish Council has previously expressed its concern that its decision not to object to the inclusion of WETH636 and WETH624 was significantly misrepresented by the promoter/landowner's agent at the Local Plan Sub-Committee meeting on 28thNovember 2016 as "full support". WPC has observed from the Sub-Committee meeting transcripts that the issue of alleged "full support from WPC" was instrumental in the
decision-making discussion including overturning the planning officer's recommendation with regards to WETH636.
The Parish Council is deeply concerned by this clear misrepresentation of its position and believes that on this issue alone the decision of the Sub-Committee should be reviewed. The strength of feeling concerning the misrepresentation of the Parish Council's support and the lack of opportunity for its views to be considered prompted a significant number of residents to form a community protest group to object to the inclusion of WETH636 and WETH624 in the Local Plan. At the extraordinary meeting held on 13thFebruary, the Parish Council duly considered these views.
3. Objections to the inclusions of WETH636 and WETH624
Whilst the Parish Council continues to have no objection to the inclusion of WETH414 in the Draft Local Plan, and acknowledges that this site has been subject to prior public consultation, it has now had sufficient time to consider the planning issues in relation to WETH636 and WETH624 and following full public consultation concludes that these sites should be withdrawn from the Draft Local Plan on multiple grounds as follows:
The sites lie within the parish conservation area which has been protected from inappropriate development for decades. It is considered that any development on the proposed sites would detract, rather than enhance the conserved area in terms of character and landscape.
National Planning Policy Framework
The Parish Council concludes that the inclusion of these sites would be in contravention of the National Planning Policy Framework as to include them would not fulfil any of the key criteria for consideration e.g. increased environmental value, inaccessible locations, close to public transport, services and job opportunities, recognising the intrinsic character and beauty of the countryside and conserving heritage assets.
Highways and Access
It would be problematic to provide acceptable and safe access and egress to the adjacent roads.
Topography and landscape and proximity to heritage assets
The topography and landscape of the proposed sites would disrupt the protected character of the historic market village of Wethersfield. Wethersfield has highly attractive landscapes of the open countryside around the village. Both sites would be in close proximity to the long established historic settlement and would be highly visible and out of character alongside many listed buildings within the conservation area.
We note that in a recent full planning application on the site of WETH636 under the existing local planning framework, Essex County Council's Historic Buildings consultant opposed development on this site because of the 'adverse impact this would have upon the character and appearance of the conservation area contrary to local and national heritage and design policies.” This objection remains valid.
WETH636 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 could lead to restrictions of some recreational activities which would mean reduced amenity generally within the village.
WETH624 carries the main foul water sewer directly through the centre of the site.
Following an opportunity for public consultation and an acknowledgement of the genuine concerns raised by residents, reinforced by its own consideration of adverse planning issues, Wethersfield Parish Council resolved at its meeting held on 15th February 2017 to seek immediate withdrawal of the sites WETH636 and WETH624 from the Draft Local Plan.
Given the planning issues as stated above, coupled with the extraordinary circumstances of a limited consultation period resulting from the late submission of the two sites for inclusion in the Draft Local Plan, further compounded by the misrepresentation of Wethersfield Parish Council's support to the Local Plan Sub-Committee, Wethersfield Parish Council invites the Local Plan Sub-committee to reconsider its decisions regarding sites WETH636 and WETH624 prior to the submission of the Draft Local Plan to the Full Council.
We look forward to receiving confirmation of your consideration of this matter on a future Local Plan Sub-Committee agenda.
On behalf of Wethersfield Parish Council
Alison Lucas (Mrs)
Clerk to Wethersfield Parish Council
cc Ms Emma Goodings, Planning Policy Manager, Braintree District Council
Cllr Peter Schwier, Ward Councillor, Braintree District Council
Cllr Peter Tattersley, Ward Councillor, Braintree District Council