Sites and Policies Plan Consultation Draft

Comment ID 6487489//1
Document Section Sites and Policies Plan Consultation Draft Ensuring Safe and Healthy Communities DM73 View all on this section
Respondent Deleted User View all by this respondent
Response Date 19 Apr 2013

Submission re “

Sites and Policies Plan Consultation Draft“

19 Apr 2013

Re: DM73 – Local Green Space - Beechmount Drive


We write to you to object to part of the proposed re-designation

of the Amenity Area land near Beechmount Drive as Local Green Space, in the Consultation Draft Sites and Policies Plan (SAPP).


The area that we wish to discuss and object to is only the section of land to the east of the TPO

. The area in question is approximately 18% of the total area.

The NSRLP currently identifies the land as an Amenity Area, protected under policy ECH/1.

The Government’s National Planning Policy Framework (NPPF), March 2012 introduced the new

designation of Local Green Space (LGS),. It states that “local communities, through local and

neighbourhood plans should be able to identify for special protection green areas of particular

importance to them. By designating land as Local Green Space local communities will be able to

rule out new development other than in very special circumstances”.

The NPPF sets out criteria for designation of LGS, including:

Paragraph 77. “The Local Green Space designation will not be appropriate for most green areas or open

space. The designation should only be used:

where the green space is in reasonably close proximity to the community it serves

where the green area is demonstrably special to a local community and holds a particular local

significance, for example because of its beauty, historic importance, recreational value (including

as a playing field), tranquillity or richness of its wildlife; and


where the green area concerned is local in character and is not an extensive tract of land”


The NPPF notes specifically that “Local Green Space will not be appropriate for most green areas

or open space .”

My concern and belief is that this designation is being incorrectly applied purely to prevent


development rather than because of the NPPF criteria. This is not the correct use of this planning






In Terms of NPPF criteria

This section of land is in reasonably close proximity to existing housing but what is the special

function it serves for the community ?


Philip Anelay states:

“We have interpreted the NPPF criterion on “beauty” to mean the visual attractiveness of the site,

and its contribution to townscape, landscape, character and/or setting of the settlement. We feel

that the land is of significant value in these terms being an area of open space and trees,

particularly visible from Broadway and Beechmount Close. It is particularly important to

townscape, and helps to breaks up the urban fabric and enhances the area.”


Our Position


It is important to note that we support re-designation of +/- 82% of the area. We also support the extension of the TPO eastwards to include trees that are of a quality and size to justify TPO

protection. (The application we intend to make will be outside the areas covered by TPO number


209 and 676).


The section of land that we do not believe conforms to the requirements for re-designated as


“Local Green Space” is the open area at the eastern end of the site that is accessed from


Beechmount Drive.


Does this area serve the community as defined by the NPPF or is the revue really being used by


immediate neighbours to protest against development ?


Historical Background and Current Situation:


I have spoken to the neighbours and Philip Anelay about a development proposal.

Philip is opposed to development and an email that has been circulated to residents that states

that the re-designation of this land would fundamentally prevent development. This is why the

vast majority of objectors have houses abutting the land and are not from the wider community.

It is completely understandable (as in most green field developments) , that the immediate neighbours would prefer development elsewhere. However it is a misuse of process to re-designate this land to prevent development rather than to designate it based upon NPPF criteria. Hence it is

important to focus on the NPPF criteria and determine if this area of the land in question appropriately falls within this criteria.

 Prior use of the land


Prior to discussion about development some neighbours have used this area as a tip.

Neighbours (who have written supporting the TPO) have previously cut down trees

themselves on the site and others have written requesting that we cut down trees

on their behalf.


There appears to have been an assumption that this is community land and not private

land. However whenever there has been an issue with any potential liability to a


neighbour’s property or fences from overgrowth on the land there were complaints.


Current situation of the land


The section of land in question has been cleared and does not make a valuable contribution to the

landscape. It is described by one of the respondents to this revue as “a monstrous blot on the



It is on this basis that this section of the land should not be re-designated as a “Local Green


Space” because it does not satisfy the exceptional circumstances required under the


Government’s National Planning Policy Framework, whereas the balance of the land could be


said to comply.




For Your Information

Outcome with development on the section being discussed.

We will be proposing 3 dwellings sited so as not to encroach on the woodland area

protected by both the existing and new TPO’s


The dwellings will incorporate vertical gardens on their northerly aspect.

The buildings themselves should have minimal impact when standing on Beechmount

Close once the trees and vertical gardens are in place.


From the Broadway there will be a 3 degree visibility window

between the roofline of homes on Beechmount Close and the top of the buildings. Remembering that the facades are predominantly covered by vertical gardens, the buildings are over 80 m away

(at there closest point) and will also be further obscured by new trees between them and the


existing homes on Beechmount Close.


With development there would be more trees and in-fill trees on the southern side of the

site that will create a new continuous tree line connecting the existing ancient woodlands


with the trees that run behind homes on Beechmount Drive and on towards Broadway



With development there would be a protected wildlife corridor across the north and

south boundaries.


With development any flood run off would be mitigated.

With development it has been proposed we would give the opportunity for each adjacent

home owner to purchase the land immediately behind their home for a nominal sum.

(10 pounds).


In Summary


The beauty of this area could be enhanced by permitting sensitive camouflaged homes


masked with vegetation that also enable increased forestation, new wildlife corridors and

give owners direct ownership of the land behind their homes.