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3. Harmful backland development  In its Policy CS 17 (paras c and 4.8.10)  Bexley re-
               affirmed  its resistance to harmful backland development.  What is now being proposed for
               the garden land behind 22-28 St James Way remains harmful for several reasons:-

               - nuisance and loss of  privacy

               - threat to security, as a road is being proposed that will run behind houses in St James Way
                 and The Grove and provide a new access/exit for burglars

               - loss of amenity, ie people's right to quietly enjoy their gardens, free from noise and
                 disturbance from traffic

               - light pollution, not least from any street lighting along the line of the proposed road

               - changed character of the neighbourhood (one which adjoins a Conservation Area) by the
                 introduction of a cul-de-sac within garden land at the rear of people's homes

               - the removal of several mature trees in order to create the  road and new houses; and the
                 threat to large, centuries-old Cedar trees which are protected by a TPO.

               - effect on biodiversity (badgers, foxes etc.)


               4.  Another precedent for refusal  An application to build a cul-de-sac comprising four
               detached dwellings in place of No.17 Wansunt Road, Bexley, and on land to the rear of
               Nos.15-23, was Refused in 2012; and an Appeal dismissed (11/01937/FUL).  Such a
               development was declared wrong for Wansunt Road and it is even more wrong for St James
               Way, where there would be a far greater impact on neighbouring properties and amenties etc.

               Please see comparison of the two sites in Appx C.


               5. Pre-planning application advice given to the applicants by Planning We  found this
               advice very helpful, setting out as it does- comprehensively and clearly- the relevant factors
               that needed to be addressed.

               We consider that the submitted application fails as regards Policies UDP H3, H5 (particularly
               para 6.11),  H8 (particularly para 6.17) and CS06 and CS17.  And we are unconvinced by the
               applicant's Arboricultural Survey and Preliminary Ecological Appraisal.  Moreover, we can
               see no evidence that Listed Building Consent has been granted in respect of the historic wall,
               see 8 below.

               Bexley is opposed to garden-division for residential purposes. We know this from several
               local cases where Planning has ensured that any building in a garden intended for residential
               use is legally tied to the main house as an ancillary to it.   This is not the aim of this
               application!
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