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site is unsatisfactory for residential development.   It is considered that the reasons for
               refusal...were soundly based” [14 June 1985]

               I 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
               up its approach to harmful backland development by its Policy CS17.

               Harmful backland development  In its Policy CS 17 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.)

               Historic Cedar Tree  Of the two Cedar trees mentioned as being in this garden land in 1985,
               only one  remains – the other having been lost in a gale some years ago.  The surviving Cedar
               (and the one in the garden of  No. 18 St James Way) is of great heritage importance as it was
               planted by Lancelot 'Capability' Brown in c1782 as part of his landscaping of North Cray
               Place (whose parkland now forms Foots Cray Meadows). The history of the Cedar trees in the
               gardens of Nos. 22 and 18 St James Way and their connection with 'Capability' Brown has
               been confirmed by English Heritage.  Both are protected by TPOs (reference 68/1246).  These
               trees are very important to local residents, and important too in the history of North Cray.  We
               all share the concern expressed in 1973, and again in 1985, that their roots would be damaged
               in excavating for building foundations and in building a new access road.   We are not
               reassured by the applicant's Arboricultural Survey Report as this makes no reference to the
               very real threat of root damage from the building of house foundations etc.  We are also
               particularly concerned by the proposal (clearly shown on the Plans for this site) to severely
               prune this Cedar tree for the benefit of the proposed new houses. It is for this reason that we
               are copying this letter to Bexley's TPO officer.

               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.  But with one very important exception. This is the statement under
               Principle of Housing and Density that the site is “previously developed” and that, as such, it is
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