Page 27 - Archive in reverse date order

www.northcrayresidents.org.uk

TO: Mrs Susan Clark, Head of Development Control

FROM: Jean Gammons, Secretary

Copied to: Mrs Helen Acton and Ms Sue King DATE: 25 April 2016

Ref 16/00348/FUL Development of garden land behind 22-28 St James Way &
demolition of 20 James Way in order to create a cul-de-sac and a new access road

Dear Mrs Clark

This is to ask you to register our very strong Objection to the above planning application,

1. Precedents for refusal The current application is the fourth attempt to develop garden
land at the rear of 22 St James Way for houses. All previous applications were refused.
Please see Appx A to this letter and para 4 below.

We know of no subsequent changes in planning law that would contradict the views expressed
by the then Chief Planning Officer/s so firmly and clearly in 1967, 1973 and in 1985; and by
the Planning Inspector/s in 1973 and 1985. On the contrary, Bexley has expressly tightened
its approach to harmful backland development by its Policy CS17, see 3 below.

2. What has changed? It seems to us that all that has changed since 1985 is new government
pressure on Local Authorities to identify “brownfield” land (sites within existing Urban areas
as opposed to Open Countryside) where new houses might be built.

However, North Cray has already made significant contributions to increasing Bexley's
housing supply. Please see our comments below on para 7.5 of the applicant's Planning
Statement.

Furthermore, Annex 2 of the NPPF defines Previously developed land as “Land which is or
was occupied by a permanent structure...This excludes: ...land in built-up areas such as
private residential gardens, parks [etc]...”. This interpretation is repeated in the Dept. of
Communities & Local Government's document Building more homes on brownfield land –
consultation proposals (January 2015).

The latest government guidance that we can find on Brownfield sites is the report of the
House of Commons Select Committee for Communities and Local Government prepared in
March 2016, para 22. This states that it continues to support the development of brownfield
sites for housing where it contributes to meeting local housing needs. But this goes on to say
“However, it is important that local circumstances are taken into account when determining
whether or not a particular brownfield site is suitable for housing development”. Our view,
and that of residents directly affected by the current application, is that the application site is
unsuitable, see 3 below.