Tag Archives: Benfleet

‘Allo, ‘Allo, ‘Allo, what’s Going on Here Then? Castle Point Brownfield Register applying pressure on Green Belt Development? Every Little Counts!

Why, if there is such a Desire to Protect Green Field Land in our Borough, is Castle Point Council’s Brownfield Land Register nothing short of Paltry?

2017-12-16

Despite, yet another, “cross-party Member Working Group” having been established by cpbc cabinet to prepare and consult on the Brownfield Register prior to its publication the outcome of the working work, is a List of just 20 sites capable of yielding upwards of 254 new Dwellings across the whole Borough!

This Register doesn’t even indicate 1 Year’s worth of sites towards the Borough’s Housing Need!

AND yet, we learn via news in the Echo, that cpbc were in receipt of a Planning Proposal for the Benfleet High Road, Police Station site two weeks prior to the Council meeting in which the Brownfield Register was considered and approved by members!

The police station site was not recorded in the Brownfield Register, nor was the proposed housing numbers added to the total!

The cpbc meeting’s Agenda paperwork also indicated;

“This report provides the Council with a summary of the work undertaken following that resolution and recommends that Part 1 of the Castle Point Brownfield Land Register be published.

It also explains why there no sites to be carried forward into Part 2 of the Register which would then have benefited from “Permission in Principle”.

With typical cpbc Lack of Transparency little explanation as to why none of the, Castle Point Brownfield sites with potential for development, were entered into Part 2 of the Brownfield Register, those the “working group” considered able to grant Permission in Principle.

Whilst those sites listed in Part 1 of the Brownfield Register mainly have yet to receive development applications, the reasons given as to why no sites were even considered for Part 2 and given permission in Principle for development appeared to be down to;

(cpbc) “must also carry out consultation, notification and publicity in accordance with regulations”

And that,

“Furthermore, Canvey Island is within Flood Risk Zone 3a, and as such planning applications for residential development normally require a Flood Risk Assessment. Advice is awaited from the Environment Agency as to if and how the Council could go about addressing this requirement before proceeding to consider any sites on Canvey Island for inclusion on the Part 2 of the Register”

The reliance and the preference for Canvey Island as the part of the Borough preferred for Land released for Development, appears clear!

However past record suggests that cpbc will not allow Flood Risk of any type to be a Constraint to development where Canvey Island is concerned.

Unusual then that work on Part 2 of the Brownfield Register was not undertaken.

The question as to why the Police Station site in High Road Benfleet had not been entered onto the Brownfield Register, part 1 or part 2, especially as the police have indicated they will no longer have use for it with their drive for cut-backs, may seem especially puzzling.

An explanation may lie in the Agenda paperwork which announced;

“A Government grant of £14,600 was received late in the last financial year (2016/17) for Brownfield Register and “Permission in Principle” work.

This grant has not yet been allocated and could therefore be applied to fund the consultation costs”

Every little £ Helps indeed, especially when it appears not to be ring fenced monies.

The cpbc Brownfield Register indicates possible development sites capable of developing between 1 and 54 dwellings, in direct contrast to a report by the Campaign to Protect Rural England (CPRE) which indicates that local authorities “Brownfield Land Registers are failing to record smaller sites that could collectively accommodate nearly 200,000 new homes across England.”

It appears that cpbc have, with the minimal amount of work and effort, undertaken a process to fulfil a commitment as required by Government, rather than an exhaustive effort to indicate preferred sites for development.

On the face of it the Register due to inconsistency and scope provides ammunition suitable to be used to suggest that Castle Point Green field and Green Belt land is required to fulfill housing needs.

Yet another cpbc Local Plan Assessment lacking effort and commitment?

The full CPRE report can be read by following the Link below:

CPRE LINK HERE.

Photograph: Copyright Google Earth

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Chickens, Eggs and Railroading – Green Belt now under threat from Business development. Councillors apply a dash of realism!

At last there appears to be an attempt to challenge the Local Plan process by committee members of the Task and Finish group.

Members appear to have recognised the “inertia” of the Local Plan that I blogged about previously on the subject of Housing Need and the Constraints topics.

The debate on the Borough’s employment and retail needs was the latest topic.

It is clear to residents and the Borough’s consultants that the roads infrastructure is a major constraint discouraging medium and large enterprises locating to our area.

The congestion in Castle Point deters new business from venturing into the Borough. The Sadlers Farm “improvement” serves  commercial traffic wishing to “skirt” the area on the way to the M25 in one direction and Chelmsford and beyond, in the other. East of Castle Point boundary and onto Southend the only arterial road is the A127 which is about as free flowing as the A13 through Benfleet!

Strategically, use should be made of the improvements along the A130.

The holdups caused by the Sadlers Farm and Waterside Farm junction as well as Tarpots and to a lesser extent the Rayleigh Weir junction, cause enough lost travelling time to discourage new business relocating to Castle Point.

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Development is encouraged, whilst infrastructure is only promised.

The Task and Finish group officers spoke of the need to have a Local Plan in place with new employment sites indicated so that a presentation for funding for new road infrastructure could be made to local enterprise agencies.

The current 1998 Local Plan, albeit now considered out of date, as well as the draft New Local Plan indicates new employment sites on Canvey Island. No doubt these indicators were used when a delegation led by our MP, chief executive, officers and lead councillors made a bid for a new access road for Canvey Island.

The bid was rejected.

The 1998 Local Plan indicates an “improvement” for Canvey Way, this also hasn’t materialised.

Castle Point Council’s consultants’ assessment of Employment and Retail needs, saw little chance that a new road would be a high priority in the near future.

“The Borough’s two allocated sites South of Northwick Road and Roscommon Way appear reasonably suited to meet future needs although their proximity to the Thames estuary, relative remoteness and potential drainage issues may deter development.

Over 90% of the borough’s allocated employment land is in Canvey Island with limited supply elsewhere to meet future demand.

While some 32.7 ha of undeveloped land was identified with potential for employment development, not all of this is necessarily available or certain to come forward for such uses within a reasonable timescale.

Taking account of potential constraints, the amount of land which would have realistic prospects of coming forward for future employment needs amounts to about 21 ha, almost all of this on just two large sites.

Despite this surplus, there may be a qualitative need for some more sites that are readily available and better located to strategic roads and population centres in the north of the Borough.   Such sites might also have better prospects of attracting developers.

One or two sites of up to 5 ha in combined area may be adequate.”

“In terms of capitalising on major new economic developments in adjoining areas, it is not obvious that a new road access to Canvey Island could enable the area to benefit to a much greater extent from the major port and distribution development at London Gateway in Thurrock.

The cost of such infrastructure would also need to be weighed against the scale of economic benefits likely to accrue to Canvey Island, and the extent of these do not appear likely to be major.

In addition, it is clear that sites in Canvey Island may not be attractive for firms based elsewhere in the Borough, some of which may choose to move out instead.”

It was noted that none of the Task and Finish group members were required to declare an interest before discussing the employment areas and new road access possibilities.

Fledgling office development.  

The consultants referred to the low level of office based employment currently in the Borough:-

“In terms of creating more local office jobs, providing more sites would not necessarily achieve this, as local demand is low and the office market is undeveloped.

It would therefore be important to start trying to build up a local office market through more start-up facilities to accommodate small firms that may, in time, require larger office premises.

A better approach, therefore, may be to seek elements of modern office space within mixed use developments in the larger town centres and in residential schemes near such centres.”

In effect making the regeneration of our two town centres more likely and more sustainable due to lack of competition from out of town centres.

The Council’s aspiration to release green field land for a large Business Park office development appears un-supported by their own consultants.

Out Commuting:

Out commuting: some 62% of Castle Point’s economically active residents out-commute to work elsewhere.”

There is nothing in the Report to suggest that the possible levels of employment in the Council’s Local Plan’s aspirations will alter the percentage level of out commuting.

Therefore it is apparent that 62% of any extra economically active population growth realised from the housing development proposals, will continue to out- commute, thereby adding to the numbers affected by the daily congestion of traffic and crowding on trains.

The Task and Finish officer spoke of the danger of the Plan being found unsound if growth was not planned for.

The Local Plan will also be found unsound if it proves to be unrealistic!

Lower the expectation levels, and keep it Real!

Photo credit: Dreamstime

Castle Point Housing, Historically deficient supply, so room for Flats in the Flood Zone yet rejections on the mainland.

Canvey Island, densley urbanised yet always room for more!

Canvey Island, densely urbanised yet always room for more!

“Housing is the first of the social services. It is also one of the keys to increased productivity. Work, family life, health and education are all undermined by overcrowded homes. Therefore, a Conservative Government will give housing a priority second only to national defence. Our target remains 300,000 houses a year.”

“This was the Conservative manifesto of 1951. The other parties of the time made similar commitments to the Conservatives. The consequence? When the baby boomers grew up we could afford to buy our own homes. At today’s prices, people on an income of £20,000 a year could buy with a deposit, also at today’s prices, of only £3,000.
With that legacy it is pretty abject that we now have a housing market where owner occupation is the preserve of wealthy people with wealthy parents. The income of a first time buyer now is £36,000, which is above the national average. The deposit needed now is £30,000, which is why two in every three new buyers are only able to buy because of the wealth of their parents.

So it is bad now – but not nearly as bad as it is about to become. There has been another baby boom, the biggest since the famous baby boomers. Over 8 million babies were born between 2001 and 2012. Remember the last baby boom generation was born when we were building 300,000 homes a year? This time round we are building around 130,000. We have a housing crisis now. Unless we take concerted, strategic, planned action now, when the new baby boomers grow up they will have nowhere to live

This is why the 2015 General Election is so critical. It is imperative that those who want our vote commit to end the housing crisis within a generation and produce a detailed, long term plan setting out how they would do this.

And it is imperative that we, who really understand the scale and nature of the challenge, this time are prepared to stand up and be counted.”

David Orr, chief executive of the National Housing Federation
The National Housing Federation is the voice of affordable housing in England.

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Whilst Mr Orr, certainly paints a rosy picture of  home ownership during the post war – late 1960’s, home ownership has weathered some pretty stormy patches since. The early 1970’s saw the first of the price boom times followed by the crippling interest rates of the later 1970’s.

It is hardly surprising that following a time of austerity there has been a severe contraction in house building.

The high numbers of housing completions, shown in the graph above, up to 1970 are due in no small part to local authority homes. The available land would have, in some part, been bomb sites and the regeneration of “pre-fab” estates, that is, cheap land. The New Town Act of 1946 had an influence on population re-distribution that has become topical more recently.

The local authority housing numbers completed around the 1970’s can be seen, in the graphic above, to have been the main reason for the record housing completions that David Orr of The National Housing Federation compares the latest figures to.

Up until the recent 2008 financial difficulties the graph suggests that market priced housing development figures have held steady.

There is a danger that the creation of Local Plans will see the possibility of Green Belt land being released or safe guarded and ending up land banked.

If as suggested the housing completions have remained fairly steady with signs of moderate recovery, given the economic uncertainty, what is there to suggest that a boom in housing will achieve the numbers necessary to satisfy Objectively Assessed Housing Need numbers?

After all, the recent assistance to promote home ownership, the help to buy scheme and the historically low static interest rates will only aid those able and qualifyied to buy.

Castle Point Borough Council appear compliant with the failure to achieve affordable housing numbers. They have agreed without proof to committee to allow a reduction of affordable homes at Kiln Road.

Similar appears to be being encouraged at Benfleet.

Redrow Homes, proposal for Felstead and Bowers Road, Benfleet “seeks to provide a range of private and affordable dwellings.”

“The affordable housing element of this scheme has been discussed with the Planning and Housing Officers at Castle Point Borough Council throughout the pre-application process.”

Of the 178 dwellings proposed just 18 affordable dwellings (10%) are planned.

Not only well below even Castle Point requirements but non of which are Flats.

Locally due to viability issues,  Canvey has seen development and proposals for flatted accommodation, apparently due to need:-

Officers report Leige Avenue proposal for Flats.

“Policy H9 of the current Local Plan requires the optimum density of development to be achieved on any site.” (in contrast to the Redrow, Benfleet proposal)!

“The most up to date local evidence of need in respect of the mix of development on sites is the 2013 Strategic Housing Market Assessment. This identified that in the Thames Gateway South Essex the focus of demand was on entry-level and mid market family housing (2/3 bed) particularly south of the A127.” (in contrast to the Redrow, Benfleet proposal)!

“The provision of one and two bedroomed flats would clearly contribute towards meeting housing need where a historic deficiency in the provision of housing has been identified.” (in contrast to the Redrow, Benfleet proposal)!

Since when has Canvey Island had a “historic deficiency in the provision of housing?”

This appears to be a suggestion by CPBC that the lack of housing supply in mainland areas provides sufficient reason to continue to abuse the Sequential Testing so as to continue to develop Canvey Island to meet the mainland’s historic deficient housing need!

And the Planning Authority continue to make these loose policy statements unchallenged.

Compared with Europe the UK population prefer not to live in Flats, as can be seen in this EU graphic below.

800px-Distribution_of_population_by_dwelling_type,_2012_(1)_(%_of_population)_YB14_II

The graphic also illustrates the low percentage of detached housing in the UK, perhaps a reflection of the concentration of housing in densely urbanised areas, much like Canvey has seen.

“Meet your Councillors” futile exercise – Castle Point Local Plan looking an expensive exercise!

Benfleet held the first “Meet your Councillor” meeting, since the Castle Point Council Local Plan draft was issued.

In attendance were local residents concerned over the loss of mainland Green Belt, and local Councillors.
Absent were Castle Point Council officers.
I am sure that the Councillors in attendance were fully up to date and knowledgeable on the Local Plan contents and it’s implications.

Hopefully they were also fully conversant with the requirements of the National Planning Policy Framework, NPPF.
They should be, as these are the Councillors that have determined that Green Belt should be released for housing development in the Borough.

We are at a little disadvantage being Canvey Island residents as only one of our ward Councillors may have had input into the Local Plan process. The Canvey Island Independent Party Councillors made the point, during the LP debate in the council Chamber, that they had no input or influence in the drawing up of the LP document.
This may appear puzzling to outsiders including the Planning Inspector charged with the LP examination, especially as Canvey Island is the largest town in the Borough.

The “Meet your Councillor” meetings, on the topic of the Local Plan can only be considered to be a talking shop in which residents opinions can be aired.
No concrete advice nor hope of altering the LP draft can be considered to be on the agenda!

The Castle Point Local Plan raises concerns.
It covers the period 2011 – 2031.

However the NPPF states that: “Crucially Local Plans should”: “be drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements, and be kept up to date.”

This raises the first question, why have Castle Point Council sought to publish a 20 year Plan?

Regarding Housing delivery the NPPF requires CPBC and other Local Authorities to “identify and update annually a supply of specific deliverable sites sufficient to provide five years worth of housing against their housing requirements”
then to
identify a supply of specific, developable sites or broad locations for growth, for years 6-10
and, where possible, for years 11-15.”

Castle Point Council admit that the Green Belt is tightly drawn around its urban area. This may allow reason to specifically indicate only a year 1 – 10 housing supply.
It may then be un-necessary to re-draw the GB boundaries to the extent that they have been.
However, have CPBC, by identifying possible sites up to year 20, shot themselves and Castle Point residents in the foot?

CPBC Local Plan identifies specific sites that it claims will fulfill the requirement to serve 20 years supply at 200 dwellings per annum.

If the selected sites are deliverable and the 200 dpa is acceptable and achievable there is a clear question mark against the tactic and preference to select a plan period of 20 years.
To also re-draw the Borough’s Green Belt boundaries, to the extent that the Authority have, goes against the clear wishes of the residents and appears to be un-necessary.

The second question is therefore raised.
Is the initial 5 year housing supply supported by real evidence?
If it is, then there is little need to show such a lengthy list of potential housing sites, many within the Green Belt.

Reading some of the criticisms of the Glebelands proposal, in particular the 5 year housing supply, by the Planning Inspector, the Secretary of State and finally (or not as the case may well be) the JR Judge, it is clear that CPBC’s opposition to the FLP proposal was merely an expensive vanity exercise. Made more puzzling by the sites subsequent inclusion in the LP’s identified housing supply.

This leads us to believe that “our” local authority have been desperate to expose some sites, by removing their GB status, so that other preferred sites may remain unidentified and be offered protection, as their development may be unpalatable for one reason or another, regardless of their Green Belt function.

Hopefully we will be enlightened, eventually.

The Bell tolls on the next area of Castle Point Green Belt facing Development.

This evening, Tuesday 2nd April the Castle Point Development Committee consider another Green Belt site proposed for housing development. The very likelihood is that permission will be granted even though the Council members have expressed their clear reluctance to allow Green belt sites to be released for such use. With the approaching publication of the new Local Plan and the difficulties involved with the process, London Road may prove to be less of a politically sensitive site than others in the Borough.
Extracts of the Development Committee Agenda follow:
Application Number: CPT/25/13/FUL
Address: 396-408 LONDON ROAD, BENFLEET
(Boyce Ward)
Description of development: DEMOLITION OF BUILDINGS AND
CONSTRUCTION OF 9 DETACHED
DWELLINGS AND 42 FLATS IN TWO BLOCKS
OF UP TO THREE STOREYS WITH PARKING,
ACCESS, LANDSCAPING AND ASSOCIATED
WORKS.
Summary
The application seeks permission for the residential redevelopment of a site allocated for Green Belt purposes in the adopted Local Plan. Based on the facts that the redevelopment of the site in the manner proposed would diminish the strategic function of the Green Belt in this area, that the site is only
partially developed and may not therefore be considered to be a wholly brownfield site and that the proposed development would have a significantly greater impact on the openness of the Green Belt than the current buildings on the site, it is not considered that development of the site can be justified on the basis of the guidance provided in the NPPF.
The proposal therefore constitutes inappropriate development in the Green Belt.
Paragraph 14 of the NPPF addresses the presumption in favour of sustainable development. With regard to decision taken it expects that development proposals will be approved where the development plan is out of date unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, or specific policies in the framework indicate development should be restricted.
Footnote 9 to paragraph 14 indicates that land designated as Green Belt Is Included as a specific policy In the Framework where development should be restricted. Therefore, it could reasonably be interpreted that the presumption In favour of
sustainable development does not normally apply to proposals for development In the Green Belt However, the guidance is clear that development will be approved where the development plan is out of date unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, or specific policies in the framework indicate development should be restricted. However, inappropriate development in the Green Belt can be exceptionally justified by the existence of very special circumstances. In this particular instance, the land
was identified by the Full Council at its meeting of the 5th December 2012, as forming part of the Council’s five year housing land supply and this is considered to amount
to the very special circumstances needed to justify the otherwise inappropriate development. The proposal is therefore recommended for conditional APPROVAL
The Proposal
Permission is sought for the removal of all existing buildings and structures on the site and the erection of two blocks of flats (A and B) providing 42 units. Block ‘A’ would be three storeys and have a maximum height of some 12.1m. Block ‘B’ would be part two/part three storeys, with a maximum height of some 12m.
Of the 42 flats proposed, six would be one bedroomed and 36 would be two bedroomed. Nine of the flats, including all the one-bedrooms, would be key worker/shared equity housing.
In addition it is proposed to erect 8 detached five bedroomed houses around a new cul-de-sac to the west of Catherine Road and a detached 3/4 bedroomed chalet fronting Rhoda Road.
The proposed houses would be two storeys with accommodation in the roofspace.
The proposed flats would have car parking areas provided at ground floor level. The proposed houses would have in-curtilage parking. Landscaping is proposed along the London Road and Catherine Road frontages of the site.
Planning History
Parts of this site have an extensive and somewhat chequered planning history. The dwelling and car wash at the eastern end of this site have limited history although the car sales site at 396 London Road has been the subject of recent successful
enforcement action in respect of a breach of condition and the use of a building on the site for the retailing and fitting of tyres. The matter was the subject of a planning appeal which was dismissed on 21st September 2012. The enforcement notice was
upheld
There have been previous applications for residential development on parts of this Site. All subsequently refused by the Development Committee on Green Belt Grounds.
CPBC Strategic Planning Within their Design and Access Statement, the applicants indicate that Green Belt policies are not relevant to the consideration of this proposal. This is not the case.
This site is designated as Green Belt. Paragraph 83 of the National Planning Policy Framework states that Green Belt boundaries may only be altered through a review of the local plan. The current review of the Local Plan is ongoing, and has not yet been completed. Therefore, at this time this site is still designated as Green Belt and consideration should therefore be given to Green Belt policies in the determination o this application.
In 2012, the Council undertook work to identify housing sites to meet the requirements of paragraph 47 of the National Planning Policy Framework to have a five year housing land supply. It was clear from a review of the Strategic Housing Land Availability Assessment that there is insufficient land within the existing urban area (non Green Belt) to accommodate any significant increase in the provision of housing. At April 2012, the SHLAA identified a capacity of just 392 deliverable homes from the urban area compared to a requirement for at least 1,000 homes, plus an additional 20% allowance to provide flexibility in the supply.
In order to ensure a five year housing land supply, the Council undertook an exercise to identify additional sites for housing. The Green Belt in Castle Point is tightly drawn around the existing urban area, and as a consequence it was necessary to consider the appropriateness of bringing forward sites within the Green Belt to meet housing needs. This work culminated in the Council agreeing a list of 9 strategic sites for the accommodation of housing in December 2012, of which 4 were within the Green Belt. The capacity of these sites when combined with capacity within the existing urban area could accommodate in excess of 1,200 homes. Land at 396 to 408
London Road was included within this list of strategic sites.
In identifying this list of sites, the Council gave very careful consideration to the National Planning Policy Framework, which at paragraph 89 made it clear that the construction of new buildings in the Green Belt was not inappropriate where it
involved the limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.
They also gave consideration to the Ministerial Statement of the 6th September 2012 which also promoted the redevelopment of previously developed land in the Green Belt as a means by which housing needs could be met. As a consequence of this
national policy direction, the Council concluded that land at 396 to 408 London Road was an appropriate location for housing development given the nature and extent of existing development on the site. The decision of Council in December 2012 suggested that a quantum of development in the order of 50 homes on this site would be appropriate.
At this time, the Council’s decision in respect of the inclusion of 396 to 408 London Road, and indeed the three other Green Belt sites, within the five year housing land supply has not been subject to independent examination by a planning inspector. It
is therefore necessary to consider how much weight should be attached to this decision and the evidence base that underpins it when determining this application. Consistent with paragraph 88 of the National Planning Policy Framework, it is important that any potential harm to the Green Belt is clearly outweighed by these considerations.
Public Consultation
11 objections have been received from the following properties:
Catherine Road: Catherine Road Residents Association, ‘Catherine Lodge’, ‘Montagne’, ‘Ryecroft’, ‘Hillcrest’, ‘Ashlea’, ‘Tudor House’, ‘Ralstan’, ‘Oak Lodge’. Rhoda Road: Hawthorn Cottage London Road: 382
Prematurity
A number of local residents have objected to the proposal on the basis that the land is Green Belt and despite the decision made by Members at the meeting of the Full Council in December 2012, development of the land would be inappropriate prior to consultation on the new Local Plan.
The document “The Planning System: General Principles”states that “in some circumstances, it may be justifiable to refuse planning permission on grounds of prematurity where a Development Plan Document (DPD) is being prepared or is
under review, but it has not yet been adopted. This may be appropriate where a proposed development is so substantial, or where the cumulative effect would be so significant, that granting permission could prejudice the DPD by predetermining
decisions about the scale, location or phasing of new development which are being addressed in the policy in the DPD. A proposal for development which has an impact
on only a small area would rarely come into this category. Where there is a phasing policy, it may be necessary to refuse planning permission on grounds of prematurity if the policy is to have effect. Otherwise, refusal of planning permission on grounds of prematurity will not usually be justified. Planning applications should continue to be considered in the light of
current policies. However, account can also be taken of policies in emerging DPDs.
The weight to be attached to such policies depends upon the stage of preparation or review, increasing as successive stages is reached. For example:
• Where a DPD is at the consultation stage, with no early prospect of submission for examination, then refusal on prematurity grounds would seldom be justified because of the delay which this would impose in determining the future use of the land in question.
• Where a DPD has been submitted for examination but no representations have been made in respect of relevant policies, then considerable weight may be attached to those policies because of the strong possibility that they will be
adopted. The converse may apply if there have been representations which oppose the policy. However, much will depend on the nature of those representations and whether there are representations in support of particular policies”.
The guidance also makes it clear that where planning permission is refused on grounds of prematurity, the Planning Authority will need to demonstrate clearly how the grant of permission for the development concerned would prejudice the outcome of the DPD process.
The Council’s draft Core Strategy was withdrawn in September 2011. At the same meeting the Council resolved to commence work forthwith on the preparation of a new Local Plan. A revised Local Development Scheme (LDS) was agreed by the Council’s Cabinet in January 2012 and has now come into force.
The Council has completed its issues consultation and in 2012, undertook work to identify housing sites to meet the requirements of paragraph 47 of the National Planning Policy Framework to have a five year housing land supply. It was clear from a review of the Strategic Housing Land Availability Assessment that there was insufficient land within the existing urban area to accommodate any significant increase in the provision of housing. At April 2012, the SHLAA identified a capacity of just 392 deliverable homes from the urban area compared to a requirement for at least 1,000 homes, plus an additional 20% allowance to provide flexibility in the
supply.
In order to ensure a five year housing land supply, the Council undertook an exercise to identify additional sites for housing. The Green Belt in Castle Point is tightly drawn around the existing urban area, and as a consequence it was necessary to consider the appropriateness of bringing forward sites within the Green Belt to meet housing needs. This work culminated in the Council agreeing a list of 9 strategic sites for the accommodation of housing in December 2012, of which 4 were within the Green Belt. The capacity of these sites when combined with capacity within the existing urban area could accommodate in excess of 1,200 homes. Land at 396 to 408
London Road was included within this list of strategic sites.
In identifying this list of sites, the Council gave very careful consideration to the National Planning Policy Framework, which at paragraph 89 made it clear that the construction of new buildings in the Green Belt was not inappropriate where it
involved the limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding
temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.
They also gave consideration to the Ministerial Statement of the 6th September 2012 which promoted the redevelopment of previously developed land in the Green Belt as a means by which housing needs could be met. As a consequence of this
national policy direction, the Council concluded that land at 396 to 408 London Road was an appropriate location for housing development given the nature and extent of existing development on the site. The decision of Council in December 2012 suggested that a quantum of development in the order of 50 homes on this site would be appropriate.
At this time, the Council’s decision in respect of the inclusion of 396 to 408 London Road within the five year housing land supply has not been subject to independent examination by a planning inspector, however the evidence base underlying the
decision to identify this site for residential development purposes is considered robust and sustainable.
There is a very real need to identify and deliver sites for residential development within the Borough. Research undertaken in the preparation of the Core Strategy and the Local Plan has identified that opportunities for such delivery are extremely limited. Given the limited opportunities available and the nature of the evidence base it is not considered that the development of this site for residential purposes would prejudice the outcome of the Local Plan process.
No objection is therefore raised to the proposal on the basis of prematurity.
The Planning Authority is currently preparing a new Local Plan which, inter alia, will consider the Green Belt boundary and the status of the Green Belt within the borough. As part of this process the Council has carried out assessments of the
function and landscape value of individual parcels of Green Belt land within the Borough.
The application site forms part of a wider parcel of Green Belt land which separates Benfleet and Thundersley. Within the Green Belt Functions Assessment, it has been concluded that at a local level this parcel of land fulfils four of the Green Belt
functions identified at para 80 of the NPPF and at the strategic level, this parcel serves to provide a link from the Green Belt in the north west of the Borough.
However, existing development of this site has already compromised the strategic function of this part of the Green Belt by allowing the adjoining urban area to sprawl.
The landscape value of this part of the Green Belt has also been diminished. The Green Belt ‘gap’ between Benfleet and Thundersley would become less open in nature as a result of this land being developed. The residential development of this
site is therefore contrary to the provisions of the NPPF.
Paragraph 89 states that a local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. The exceptions to this are:
• buildings for agriculture and forestry;
• provision of appropriate facilities for outdoor sport, outdoor recreation and for
cemeteries, as long as it preserves the openness of the Green Belt and does not
conflict with the purposes of including land within it;
• the extension or alteration of a building provided that it does not result in
disproportionate additions over and above the size of the original building;
• the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
• limited infilling in existing villages and limited affordable housing for local community needs under policies set out in the Local Plan; or
• limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of
the Green Belt or the purpose of including land within it than the existing development.
As can be seen, the last bullet point, indicates that complete or partial redevelopment of previously developed sites need not be inappropriate, provided that this would not have a greater impact on the openness of the Green Belt or the purpose of including land within it than the existing development.
Turning first to the issue of whether this site might be considered as previously developed land, it is acknowledged that the western parts of the site at Nos.396-406 London Road are currently commercial sites that display the characteristics of
brownfield land. The dwelling at No. 408 may also be considered to constitute previously developed land. However the garden and woodland attached to the dwelling are not developed and it is not therefore considered that the site, in its
entirety, may be considered previously developed land. It is not therefore considered that the proposal is fully within the scope of development envisaged by paragraph 89
of the NPPF.
The second part of the bullet point has a further test – the impact on openness of the Green Belt or the purposes of including the land, compared to the existing situation.
On the first element of the test, the replacement buildings would be larger than the ones they would replace and as a consequence the proposal will have an impact on
openness; however, it is also fair to point out that the existing buildings on the site compromise the openness of the Green Belt and in particular the activities carried out in the open parts of the site, such as car sales and valeting, whilst not built
development, seriously undermine the character and appearance of the Green Belt in this area
The proposal does constitute inappropriate development in the Green Belt; however prior to the determination of any application it is incumbent upon the Planning Authority to consider whether there are any very special circumstances which would outweigh such harm and enable the provision of inappropriate development in the Green Belt.
Although the site remains allocated for Green Belt purposes until any formal review of the Green Belt boundary it is essential for very special circumstances to be identified in order to justify inappropriate development in the Green Belt.
The Council considers that a very special circumstance does exist.
As identified above, the Council has identified limited capacity within its urban areas to provide a five year housing land supply and has undertaken an extensive review of all opportunities for the provision of residential development. As a result of this
process, the application site, along with three others, was identified as a site suitable for release from the Green Belt for residential development.
Support for this approach can be found in the Written Ministerial Statement from the Secretary of State dated 6th September 2012;
As has always been the case, councils can review local designations to promote growth. We encourage councils to use the flexibilities set out in the National Planning Policy Framework to tailor the extent of Green Belt land in their areas to reflect local circumstances. Where Green Belt is considered in reviewing or drawing up Local Plans, we will support councils to move quickly through the process by prioritizing their Local Plan examinations. There is considerable previously developed land in many Green Belt areas, which could be put to more productive use. We encourage Councils to make best use of this land, whilst protecting the openness of the Green
Belt in line with the requirements in the National Planning Policy Framework.
On the basis of the very special circumstance which has now been identified by the Planning Authority, no objection is raised to the proposal on the basis of Green Belt Policy.