Persimmon have big Housing Development plans for Canvey Island Green Belt.
However they appear happy to play the Long Game, as they again propose a Stable Block for Horses on the Dutch Village Green Belt on the Cornfields, as their first stage approach to their aims.
Note the new Application number should you care to object.
This will include the “Change of Use of Land” as it is Green Belt.
Their Application stresses the stables will be “Built Development”.
Those wishing to object to the application, can do so on the CPBC website.
For those concerned or wishing to make comment we thought it might be helpful to make public our Grounds for Objection as registered with Castle Point Council, these follow below for you to see, feel free to cherry pick to add to your objections:-
This Proposal for Stables, also more importantly, includes the change of Use of Land.
Therefore, as a whole, it should be considered that the proposal represents inappropriate development in the Green Belt. The NPPF identifies that such development may only be permitted under Very Special Circumstances.
NPPF Paragraph 83 instructs “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.” It can be argued that the “Change of Use of Land” should also only be considered, through the preparation or review of the Local Plan rather than by individual applications.
“All permanent stables and field shelters will require planning permission and, if the land is not in use for the keeping of horses, an application is unlikely to be acceptable.”
The Land has not been used, and is not used, for the keeping of horses. No permanent stables have been erected in the past.
The current security of the site actively discourages and prevents horses from having easy access to the fields.
As CPBC have recognised that a similar Application, 16/0433/FUL, required Very Special Circumstances, despite a Change of Use of Land NOT being necessary to be applied for.
The term Very Special Circumstances implies that a desperate “Need” for this facility must be Obvious and Proven, or that there are very few similar facilities in the area.
It should be noted that there are many similar facilities in the local area.
Most notable of which are the Approved Application for livery, stabling and 2 ménages at Sluice Farm, Haven Road, Canvey Island.
Approval for this considerable facility, Proposal 16/0433/FUL, for stables for 40 horses, was granted by Castle Point Borough Council as recently as 10th January 2017.
Also the long established nearby facilities at Northwick Poultry Farm x 2 yards, Northwick Road Canvey Island.
The Applicant states that “facilities are small scale” indeed accommodating a maximum of 2 horses only. This will have no tangible impact on any suggested unmet need for such facilities, even if such need were proven to exist.
In the light of these points raised, the Very Special Circumstances necessary cannot be considered to have been fulfilled.
Whilst CPBC will be reminded that they are expected to consider only the Application for stables etc, it must be noted that the Applicant themselves goes to repeated lengths to emphasise “of course, as a matter of fact, the construction of such buildings in the Green Belt will give rise to built development upon it” as though some precursor to other types of more extensive development, they being Housing Developers.
The applicant points out “To the south is an extensive area of unmaintained scrubland which separates the site from the residential area to the south (Holland Avenue). This extensive area of scrub would preclude views of the stables from the residential area to the south. It is considered that the development would have no perceivable impact on Green Belt openness when viewed from the residential area to the south.”
This is presuming that this currently unmaintained area will remain so. This should not be assumed, as the area in its present unmaintained condition can be considered a very potential fire hazard to the houses along Holland Avenue. The area of scrubland has been allowed to grow high and against the rear garden fences of Holland Avenue and it would be reasonable to expect that these bushes and brambles should be cleared, thus removing the fire hazard.
Therefore this area of scrub cannot be considered a permanent feature and that the stable block and yard, a permanent Built feature, would then be compromising and impacting upon the Openess of the Green Belt.
The applicant refers to the Purposes of the Green Belt and notes ‘to check the unrestricted sprawl of large built-up areas’;5 By the applicant pointing out that their intention is to construct “buildings in the Green Belt will give rise to built development” they are in effect conceding that they would be harming the Green Belt by means of commencing Sprawl And beginning Encroachment into the countryside adjoining this largely built up area.
The Design document indicates that there would be no hard fencing restricting the movement of Horses outside of the Stable Yard.
The field abutting the proposed Stable Yard contains the Roman Saltern, a scheduled Ancient Monument, 260m south east of Great Russell Head Farm. This monument is scheduled under the Ancient Monuments and Archaeological Areas Act 1979 as amended as it appears to the Secretary of State to be of national importance.
Applicants Design and Access Statement
This field, being the least low-lying, is the driest of the 4 fields making up the site during the wet winter months, whilst much of the other 3 fields remain heavily water-logged during this period.
The temptation to use the field containing the Roman Saltern during wet periods to allow “turning out” or exercise may well lead to potential damage of the archaeological feature and any historical artefacts below ground.
“The use of mobile, temporary horse fencing would allow ‘paddock’ areas to be formed for the grazing / exercising of the horses.”
The potential therefore exists for these fences to be knocked down whether by deliberate or accidental means, allowing horses to escape their confines, and / or riders to be unaware or careless and ride across and around the scheduled Ancient Monument Site.
Therefore the development will most likely lead to an adverse impact on the archaeological features close by.
The Applicant is wrong, and it is misleading to suggest that; “The site currently benefits from a lawful access from Canvey Way.”
The current access is on a busy dual carriageway, Canvey Road. This is towards the end of a 50 mph stretch leading from Waterside Roundabout on which speeds of up to 70mph are not unusual! The access gate is directly ahead of the road as it curves into the approach to the Canvey Road / Roscommon Way roundabout.
The design plans indicate the intention to “set back” the gated entrance 6 metres from the footpath. Whilst this “pull in” may make the actual entry to the field somewhat safer, other Canvey Road field entrances, with similar “pull in”design, have been the subject of serious “Fly Tipping” problems. This has been notably recorded at the entrances to the Canvey West Marsh RSPB site, directly opposite.
The only solution to this Fly Tipping problem the RSPB have found, is to re-position the gates directly close to Canvey Road, the exact opposite of the Applicants Planning Proposal’s intentions.
The use of Canvey Road is planned to become busier, given the planned extension to Charfleets Industrial Estate and the approved Business / Retail Parks, increasing the private vehicle and heavy commercial vehicle use, adding to the potential hazards.
The assessed 6 vehicle movements per day for the proposed site, whilst few, will likely be during the most busy periods of the day, during the early morning commute and the start of the evening Rush Hour.
Adopted Local Plan Policy RE11: STABLES WILL NOT BE PERMITTED WHERE THE EXTENT OF ACTIVITY WOULD GIVE RISE TO AN UNACCEPTABLE LEVEL OF TRAFFIC GENERATION OR WOULD BE LIKELY TO CAUSE DANGER TO OTHER ROAD USERS. (my emphasis).
7 Design and Access Statement 6.12 and 6.13 with accompanying photograph 8 “ “ 6.2, 6.7, 8.8, 9.5
In the event of a Fire in the Stable Block, the Applicants submitted Stable Entrance Plan drawing, appears to indicate an inadequate entrance width for the Fire Service Pumps. The minimum requirement indicated in the London Fire Service document “Fire Service Guidance Note” GN29, between Gateways, is 3.1 metres. Whilst the Applicants Drawing gives no measurement figures, the width restriction appears to be no more than 3.0 metres wide.
The access would prove a very tight “turn-in” for a Fire Service pump, and mean blocking Canvey Road should the gate be locked, whilst access is gained.
Currently the field gate is locked and historically when fires have “broken out” or been started in the field proposed for the Stable Block or an adjacent field, the fire Service pump has had serious issues gaining access, due to the narrow locked gate and the general ground conditions.
The proposed entrance, given its position and layout, must be considered a critical feature and unsuitable for purpose.
The proposed site for the Stable block is very close to Canvey Road pedestrian pavement, adjacent to the “old” original Canvey Road, thereby hidden from view of vehicles passing by.
The RSPB site and West Canvey Marsh opposite have suffered from vandalism.
The Stable Block would likely act as a “magnet” for vandals being, unlit, housing unattended animals over night, out of sight of passers-by view thereby “secret”, and of wooden construction, containing feed and bedding, all potential fire hazards.
Historically young children “play” in the field, making dens etc, directly behind the gardens of Holland Avenue. Occasionally attempts are made to light fires but in the main residents are aware of the activity and are able to take preventative measures.
Older generation of youngsters are responsible for the sporadic more serious fire starting on other parts of the land, that takes place usually over the course of the summer months, and causes the Fire Service to attend.
The potential for harm to animals, damage to the facility and creating a more serious fire, with more serious consequences, close to the scrub field directly behind the Stable Block, to the south, should not be dismissed.
At 6.9 of the Design and Access Statement, and to conform to cpbc officer requests, a width restriction gate is proposed to discourage unauthorised Motor cyclists. Whilst this would not be unwelcome, it must be acknowledged that this form of nuisance does not amount to the problem that it once was.
In the event of the Fire Service and Ambulance service vehicles requiring to attend the site in an Emergency, during the wet winter months, the poorly drained and waterlogged fields may well present a serious problem for the vehicles traction.
Impact on the Neighbourhood.
The intention is to use the created horse manure as agricultural fertiliser. This is usually created by allowing the horse manure to rot down on site.
The rear gardens of Holland Avenue, being just 70 metres away will most likely be affected by the smells emitting, especially during the warmer months when residents will expect to be able to leave windows and doors open to enjoy the fresh air, but would likely be prevented from doing so.
1998 Adopted Local Plan
RE11 (iii) BE DETRIMENTAL TO THE RESIDENTIAL AMENITIES OF NEARBY PROPERTIES BY VIRTUE OF NOISE, SMELL OR GENERAL DISTURBANCE. (my emphasis) And further; “would be likely to cause danger to other road users” by means of unsuitable entry access.