Page 38 - Archive in reverse date order

“brownfield land” and so not precluded from development for housing. We find this statement
inexplicable and unacceptable as the site for the proposed cul-de-sac and access road is
garden land- land that has not previously been built upon. We strongly reject Planning's
interpretation. If it was valid, then any garden or grounds with hard standing (say for a tennis
court, as once existed on the application site) or laid down as a large patio or for some other
use, would automatically become brownfield land and, as such, permissible for a residential
development. We are sure that this was not the government's intention when drawing up the
NPPF. In fact, we see from Annex 2 of the NPPF that the definition of Previously developed
land is “Land which is or was occupied by a permanent structure...This excludes: land that is
or has been occupied by agricultural or forestry buildings; land that has been developed for
minerals extraction or waste disposal by landfill purposes...land in built-up areas such as
private residential gardens, parks [etc]; and land that was previously developed but where the
remains of the permanent structure or fixed surface structure have blended into the landscape
in the process of time”. This interpretation is repeated in the Dept. of Communities & Local
Government's document Building more homes on brownfield land – consultation proposals
dated January 2015.

We also know that 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 was legally tied to the main house as an ancillary to it. This is not
the aim of this application!

Having said all this, we also wish to point out that the disputed “brownfield land” comment
was only part of Planning's advice in its pre-app guidance to the applicant. The submitted
application failed as regards Policies CS06, H3, H8, and CS17. And we are unconvinced by
the applicant's Arboricultural Survey and Preliminary Ecological Appraisal.

Planning Statement:-

7.2 This argues that, as the NPPF encourages the re-use of vacant and derelict land for
housing, the current application is appropriate for such planning approval. But in this case, the
land in question is not vacant, nor derelict land but a garden (albeit neglected) with mature
trees and valuable biodiversity.

7.5 This argues that the proposed five new dwellings would make a key contribution to
Bexley's housing supply. It would not – and at what cost to local residents and their
environment! And an examination of Bexley's Growth Strategy: our Emerging Vision
confirms what we were told by Planning last year: there are no plans for new homes in the
south of the borough – the targets for Bexley's housing growth are all in the north of the
borough. Furthermore, we know of several houses within walking distance of the application
site that are awaiting sale – and six more will become available at 139 North Cray Road (the
same Developer?). We consider that with the latter (a very unwelcome development in Green
Belt Land), together with the housing estate built a few years ago on the site of our school
and playing fields, North Cray has already done its bit towards increasing Bexley's housing
supply. Surely this is enough.

8.5 This acknowledges that the need to preserve residential amenity is a key consideration.
But the current application fails in this respect. Please see Harmful backland development
above, and below.