The Croxley Green Residents Association

The Croxley Green Residents’ Association

Chairman: Barry Grant, 93 Frankland Road WD3 3AS

Tel. 01923 778660 mob. 07941367446

E.mail:

9th March 2014

Three Rivers District Council

Three Rivers House
Northway,

Rickmansworth,

WD3 1RL

Dear Sir,

TRDC Site Allocations

Modifications Consultation 31 January – 18 March 2014

This response relates primarily to the Inspector’s recommendation that the Green Belt area around Killingdown Farm, Croxley Green be deregistered in order that 180+ houses can be built.

In his letter to TRDC of 28th November 2013, the Inspector noted that it is a national priority to maintain, as far as possible, established Green Belts but that given the tight constraints of the site allocation strategy, compensatory allocation does exist within the purview of options previously provided to TRDC. He stated that he was inclined to the view that the public interest, as reflected in the national intentions of the Framework, is best served by a (his) pragmatic approach appropriate to the local circumstances.

“There is also the Killingdown Farm site (H085 in SD42) to consider. It is unsatisfactory in Green Belt boundary terms to confine the allocation to the farm buildings alone, as the SALDD proposes. The residual land south and east of Little Green Lane would be hard tomanage productively and could deteriorate. A broader allocation would create the scope for a much better defined Green Belt boundary and, ultimately, a development scheme that is more accessible by foot and sensitive to the conservation area.”

“Essentially, however, soundness lies in providing, with a small margin for

flexibility, a robust supply overall of sustainably located sites.”

In treating this site in isolation when recommending Green Belt Boundary removal the Inspector ignored the consequences of isolating an adjacent Green Belt site. Additionally, the suitability for land to be in the Green Belt is not determined by its ability to be managed productively.

I have selected the following points which demonstrate unsound reasoning in relation to Planning Policy:

1. The Inspector refers to the deregistration as a minor revision and states that losing this site would not be unduly harmful to Green Belt purposes. The evidence of 2000 responses to consultation from residents based on sound planning guidance grounds suggests that removing Green Belt protection from land in such a rural setting that provides a green buffer between the developed side of Croxley Green and its Green Belt places the Inspector in a minority of one. The Inspector did not refer to this record response to public consultation and also did not refer to the arguments of the development company wishing to build on this land or those of the landowner. The latter two must have been particularly persuasive in presenting their "sustainable" option and their representations must have had an influence on the recommendation process. I would have thought that reference to these highly influential factors would have given perspective to the Inspectors rationale yet, remarkably, any such reference was absent. How can sound judgment be demonstrated when key consultative factors are not referred to by an Inspector?

2. Half of this site is also within a Conservation area. The District Council describes Conservation Areas as “Areas of Special Architectural or Historic Interest, the character or appearance of which it is desirable to preserve or enhance”. Conservation policies include the following:

a) Respect existing landscape features (including characteristic plot boundary treatments) and the relationship of buildings to plot boundaries.

b). Be acceptable in terms of the impact on traffic generation (having regard to existing and past traffic generation where information is available) and parking provision on townscape and the character of the Conservation Area.

c) Not adversely affect important spaces in the Conservation Area.

d) Development proposals outside the boundary of a Conservation Area should not adversely affect the setting, character, or appearance of that Conservation Area (including views into or out of the area)

e) Development which has already taken place in a manner which is unsympathetic to a Conservation Area will not be accepted as a precedent.

I cannot see that the Inspector has referred to i) the site being in the Conservation area and ii) the above-mentioned policy points. Given the fact that theSite is partially in a Conservation Area (presumably designated to maintain or improve the quality of life of Three Rivers’ communities) and that a record Site Allocations public consultation response reaffirmed the importance of this site as both a highly valued Green Belt site and a Conservation Area it is clearly not sound reasoning for the Inspector to consider deregistering this site from a) the Green Belt and b) a Conservation Area merely because it was a site that the landowner put forward to TRDC for consideration for development (What would happen if the Council put forward The Green for development?).

How can TRDC and the Inspector justify placing a large housing project in a Conserrvation Area when, elsewhere in Croxley Green Conservation Areas, the restrictions on what residents can do to enhance thier homes and environment are so strictly enforced?

3. Government Planning Guidance states that “very special circumstances” have to be determined to show that the benefits of development will outweigh the harm caused to the green belt. There is no presumption in favour of sustainable development on Green Belt land. As previously stated, suitability for land to be in the Green Belt is not determined by its ability to be managed productively.

The Inspector referred to the TRDC Spatial Vision. Its priorities for the future includelimiting changes to the Green Belt that will be necessary to accommodate some growth required to locations which result in the least harm to Green Belt and sustainability objectives and to recognise opportunities to improve and enhance the built, historic and natural environment wherever possible.

A sound recommendation would have considered all available options and would have asked TRDC to seek alternative sites that were more appropriate within the District. Creating precedents in this district for the removal of a large portion of our highly valued Conservation Area and Green Belt land from a rural setting adjacent to a developed area is of grave concern as it exposes for de-registrationany Green Belt site adjacent to an urban area and reaffirms the public's sceptism that "planning" is the one aspect missing in the rush to make up the numbers for new housing.

The Inspector referred to the TRDC Spatial Objectives. Spatial Objectives S1 states:"To ensure that development in Three Rivers recognises and safeguards the District’s distinctive character of small towns and villages interspersed with attractive countryside and Green Belt, through sustainable patterns of development. Development in the District needs to be achieved whilst protecting the very assetsthat make Three Rivers unique and help maintain a high quality of life".

There is a widely held notion in planning circles that "sustainable" in this context means "profitable". Does the Inspector recommend, and TRDC concur, that the aforementioned distinct charactor and attractive countryside setting of this site should be lost to this "sustainable development?

The Inspector appears merely concerned with buttoning down the housing options and has not discussed or considered the Green Belt Planning Guidance issues. I fail to see how the Inspectors recommendations can possbily be considered sound or justified when the most pertinent National Planning Policy factor is absent from his deliberations.

4. The recommendation to deregister the Killingdown Farm land from the Green Belt exposes and isolates the adjacent Green Belt site that is the former Durrants School Playing Field. I fail to see why TRDC has not pointed this out to the Inspector. The recommendation is unsound in that it is not consistent with National Green Belt Policy. Isolating the former Durrants School Playing Field simplifies the argument for dergistering an isolated Green Belt site. Is this the unscripted intention of the Inspector and TRDC so as to ensure a future supply of building land? This is either a terrible oversight or a deliberate plan aimed at creating further development on an adjacent site in the next allocation cycle. Is it a coincidenc that the land has remained in the ownership of Herts County Council since the closure of Durrants School. Removing the land from the Green Belt and making it available for development would significantly raise the value of the land and allow the Council to cash in on its landbanking activity.

The inevitable consequence will be the transformation of prime Green Belt land in a Conservation area into a large area containing around 500 dwellings, the destruction of the natural environment and the way paved for land on the north side of Little Green Lane to be removed from our Green Belt.

In conclusion, the above mentioned factors demonstrate that the Inspector’s recommendations are not consistent with National Planning Policy but are entirely consistent with a blinkered approach to the delivery of building land, no matter what the cost to a community that placed great faith in the democratic process and in the Government’s planning policy. Green Belt Policy has been ignored and worse, Green Belt land has been considerd by the Inspector as an enevitable makeweight, something to be plundered when the housing numbers are thrown around and don’t add up.

Yours faithfully,

B Grant

Barry Grant

Chairman