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Baldwins Gate Action Group

OBJECTION TO

Planning Application: 13/00426/OUT

Erection of up to 113 dwellings and associated works on land at end of Gateway Avenue, Baldwins Gate

Baldwins Gate Action Group, c/o 14 Gateway Ave, Baldwins Gate, Newcastle, Staffs ST5 5DD

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The Baldwins Gate Action Group The Group was formed to help villagers discuss and decide their position regarding the proposed development and to co-ordinate the gathering and submission of objections to the application.

We would wish to advise you that the comprehensive objection forms forwarded to the Development Control Manager were formulated from the views and comments of local residents and members of the Group during a series of public meetings attended by hundreds of local residents. This approach was taken to assist the Council in collating the anticipated large number of objections. The use of a standardised form does not negate the strength of feeling of the individuals concerned.

Whilst quantity of letters of objection may not be as important as quality of objection, some people are not as capable as others when it comes to stating their opinions. However, the fact that over 300 people have co-operated in creating our objection form and have taken the trouble to complete their own is an indication of the strength of feeling and, as the NPPF states: Planning should include communities.

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Introduction Newcastle-under-Lyme Borough Council, like many others, has failed to provide a 5-year housing plan, which leaves it vulnerable to unscrupulous speculators trying to gain Outline Planning Permission in parts of the Borough where they should not be permitted. The proposed site on agricultural land outside the village envelope in Baldwins Gate is one such development.

The Applicant, Richborough Estates, have used various consultants to provide professionally produced documents to substantiate their claims that this development is a sustainable one that should be approved.

These documents have been poorly prepared and are full of INACCURACIES, OMISSIONS, ERRORS and GENERALISATIONS, which have no doubt been submitted on numerous previous occasions for applications in other parts of the country, with minor amendments in an attempt to make them appear specific to Baldwins Gate.

They are an attempt to make the application look comprehensively considered when, in actual fact, they KNOW nothing about the village, local community, its heritage or environment.

In fact, they CARE nothing about the village, local community, its heritage or environment. Why should they? They are merely a commercial organisation concerned only with making money by selling to the highest bidder and moving on to the next site.

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The Action Group would like to raise the following matters in more detail.

1 Previous planning history The Applicant has failed to include the previous planning history of the proposed development site

i) 1st February 1962: proposal to erect dwellings on the application site. Application refused

Reason for refusal: “The site is in an area which is in the approved county development plan is included in a rural area and in which development should not normally be permitted except where it is required in the interests of agriculture”.

ii) 2nd August 1963: proposed erection of dwellings adjacent to Sandyfields Estate and Gateway Estate, Baldwins Gate. Application refused.

Reason for refusal: “plan and the proposed development is contrary to the local planning authority’s policy for such areas, is that it would be an undesirable extension of the existing settlement of Baldwins Gate”.

iii) 14th May 1964: proposed residential development adjacent to Gateway and Sandyfields Estate, Baldwins Gate. Application refused.

Reason for refusal: “the site lies within a rural area as defined in the approved county development plan and the proposed development is contrary to the land planning authority’s policy for such areas in that it would be an undesirable extension of the existing settlement of Baldwins Gate”.

Subsequent appeal to the Ministry of Housing and Local Government 5th April 1965. Reasons for dismissing the appeal: “the site is within the rural area, is defined by the approved county development plan and the proposed development is contrary to the planning authority’s policy for such areas”.

“The development would be an undesirable extension of the existing settlement of Baldwins Gate”.

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The Inspector also commented that “The site was within an area of Great Landscape Value”.

Clearly the previous planning history has not been mentioned by the Applicant and has not been considered in their arguments presented in relation to previous planning policies and decisions.

Gateway Avenue as an access The Applicant’s assertion that Gateway Avenue was designed to facilitate future access is incorrect. The Borough Council Planning Officers in their evidence at the Appeal, stated:

“Because the roads in the Gateway and Sandyfields estates have been extended up to the boundary, it does not necessarily follow that this implies that residential development should be extended onto adjoining land. In design of layout of estates, the roads are often taken up to the boundary to allow a full utilisation of the land without awkward shaped corner plots.”

In the Inspector’s conclusions, he stated:

“The policy of the planning authority is sound to allow only limited infilling and rounding off of Baldwins Gate”

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2 Drainage & Services The application makes no mention of the proposed routing of services which would be required to connect to the development site, ie gas, electric, water, telecommunications, foul and surface water drainage. Connections to the development will, by necessity, be routed through the existing residential estates and will consequently cause significant disturbance, inconvenience and nuisance to local residents.

Furthermore, to date no information has been provided by United Utilities to confirm that their existing sewage treatment plant has capacity to deal with the increased effluent that would be generated by the proposed development. It is known that there are existing problems of sewage flooding onto gardens, malfunctioning of the pumping station in Meadow Way, and a lack of capacity at the current sewage works resulting in the need for effluent to be tankered from the site for further treatment. Retaining this existing system would appear to be UNSUSTAINABLE. In winter months, the site is subject to periodic flooding adjacent to some of the existing properties in Gateway Avenue.

3 Light Pollution The application fails to provide any information as to the effects of light pollution that will be generated by this development. Due to the valley location this site will dominate the evening and night-time views from all elevated surrounding areas, including Whitmore Heath, Madeley Park Wood, Manor Road, Snape Hall Road and not least from the existing residential estates adjoining the site. This excessively dense development with associated street-lighting and house illumination will significantly change the night-time visual appearance of the locality and illuminate the night sky, thereby adversely affecting the village character. Such an issue cannot be properly addressed by a planning condition as the area subject to proposed development is so large.

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4 Network Rail Objection The objection raised by Network Rail with regard to works required to the boundary adjoining the West Coast mainline railway track will significantly affect the landscape views both into and out of the proposed development as a 1.8 metre high palisade security fence is required along the entire boundary, in addition to the existing Network Rail fence, to prevent unauthorised access to the railway.

This will also prevent any residents of the proposed development from directly accessing the adjoining public footpath, which will then be routed in a corridor between two fences.

The Applicant has made no assessment of the visual impact of such an imposing security fence that will clearly dominate the views.

5 Design & Access The proposed total of 113 properties is not in keeping with the village design and character. In addition, the density of the proposed development is twice that of the adjacent properties and significantly higher than any other developments within the village envelope. This does not conform to the Village Design Statement or Parish Plan.

The proposed single access to the development site is both unsatisfactory and unsafe in case of emergency. In their submission, the Applicant has admitted that they explored using Sandyfields as an additional access road, which clearly a development of this size would require, but they were unable to do so as Sandyfields is a private road. By this approach the Applicant is fully aware that the single proposed access is totally insufficient.

Furthermore the proposal to use Hillview Crescent as Emergency Vehicular Access does not fulfill this description as this cul-de-sac joins Gateway Avenue prior to its junction with the A53. Any blockage or accident on this section of Gateway Avenue would effectively trap the residents of up to 150 properties in the estate and would prevent access by emergency vehicles.

It is also noted that in design terms, throughout the village of Baldwins Gate, no spine roads joining the A53 service more than 50 properties. It should be noted that, if this application is approved, ONE THIRD OF ALL VEHICLES IN THE VILLAGE would need to access the A53 through Gateway Avenue. This is a totally unacceptable access route to the proposed development.

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SITE TRAFFIC The Applicant fails to adequately address the issue of a route for contractors’ traffic to access the development site. To suggest that the matter could possibly be agreed at a later date is totally unsatisfactory particularly when both the development site and any potential route for construction traffic would be under the control of the site landowner. The access route for contractors’ traffic should be decided as part of the Application. A detailed assessment should be made to ensure that the route does not cause nuisance or disturbance to the residents of Sandyfields estate.

Gateway Avenue is an unsuitable, narrow access for the proposed residential traffic that would be generated by the development, let alone 42 ton articulated lorries and large earth-moving equipment that would, by necessity, have to access the site.

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6 Village Planning Policies & Strategies In respect of planning policies and strategies, we would wish to draw your attention to the following: WHITMORE PARISH PLAN Whitmore Parish Plan, was drawn up by the Parish Council, after a consultation process with local residents. This included public meetings and questionnaires to every household in the parish. It received an 85% response rate from local residents. It was formally adopted in 2005. The Parish Plan was a prerequisite to the Parish Council attaining Quality Status. The plan was approved and accepted without alteration by Newcastle-under-Lyme Borough Council and Staffordshire County Council. This document has been adopted and used in deciding previous planning applications. The Plan made the following clear statements in respect of housing development, transport and road safety. There was a considerable amount of support for MINOR EXPANSION within existing communities, with strong opposition to any large developments but with some support for minor infill. Existing traffic problems were cited as one of the main reasons for not wanting any more housing developments. It was clear there was NO NEED and NO SUPPORT for MAJOR housing development within the Parish. In conclusion, the high accident rate on the A53 was cited as a main concern together with the rapid increase in traffic volume, which is mainly due to the private motor car being the predominant method of transport within the rural communities.

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WHITMORE VILLAGE DESIGN STATEMENT The Whitmore Village Design Statement was adopted by Newcastle-under-Lyme Borough Council in September 2002. It clearly states that an increasing threat to the distinctive character of rural settlements is uniformity and standardisation in design of new developments and the use of non-local and inappropriate construction materials. It is clear that the proposed development does not complement the style of housing in Gateway and Sandyfields either in density or proportion. Additionally, the land to the North West of the village was previously designated as “an Area of Special Landscape”. The classification was subsequently modified under the Local Plan to “an Area of Landscape Restoration”. Policy S15 identifies that all new developments must be in visual harmony with the character of the area. It is clear that the type of proposed development does not satisfy these policy requirements and nor does it preserve or enhance the landscape. Local people expressed strongly held concerns about the amount and nature of traffic passing through the Parish, particularly Whitmore and Baldwins Gate. In relation to LOCAL PLANS, we would draw your attention to a statement issued by Eric Pickles, Secretary of State, Department for Communities and Local Government on 26th March 2013 :

“Wherever a local plan is drawn up, consulted on, and agreed by local residents IT WILL TAKE AUTOMATIC PRECEDENCE OVER THE PRESUMPTION IN FAVOUR OF SUSTAINABLE DEVELOPMENT. THAT’S REAL LOCALISM IN ACTION!”

He went on to say:

“Suggestions that the lack of a plan will lead to a charge of concrete mixers rolling into the English countryside are completely unfounded. Even in cases where there is no local plan, new development will still have to conform to the framework, which clearly sets out that it must be well located, well designed, and SUSTAINABLE”

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7 Local Planning Policies & Strategies NEWCASTLE BOROUGH LOCAL PLAN The Newcastle Borough Local Plan, in its introduction, defines SUSTAINABLE DEVELOPMENT in section 1.2:

Sustainable development is at the heart of this Local Plan. It is enshrined in its general aim.

Development that improves the quality of life for the residents of the area is to be encouraged so long as it is not to the detriment of the environment in other ways and does not harm the environment for future generations.

The highest priority must be given to non-renewable resources: those things which if damaged or destroyed can never be replaced.

All development decisions must be subjected to the most rigorous scrutiny to ensure that the long term future is not sacrificed to short term expediency. This includes not only what is developed, but where development takes place.

The pattern of development affects the way we behave; if we have to travel unnecessarily, we cause pollution and use more non-renewable resources.

This policy identifies the issues that need to be considered to assess if a proposed development is sustainable. Whilst this policy may have been superseded, these principles of sustainability have not changed and apply to all current planning proposals.

Policy S1 states :

In determining planning applications for any type of development, the Council will have regard to the likely effect of the development on the general aim of moving towards increased sustainability. To the extent that such matters are material to the consideration of a planning application, both direct and indirect effects will be taken into account, including transport implications, … and non renewable resources.

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NEWCASTLE-UNDER-LYME AND STOKE-ON-TRENT LOCAL DEVELOPMENT FRAMEWORK - CORE SPATIAL STRATEGY This strategy strongly supports community involvement in the planning process and sustainable communities. It requires that new developments make adequate provision for all necessary facilities ie healthcare, education, sports, recreation and leisure. Developments should reduce the need to travel. They should balance the supply and demand for quality housing. Rural development should be focused within the communities of Loggerheads, Madeley and Audley Parish in order to support their function as rural service centres to meet the needs of local people. To improve and protect the countryside, no further development is planned within the villages of Betley, Mow Cop, Baldwins Gate, Ashley and Whitmore and it is important to minimise green-field development. The requirement is for a maximum of 900 additional dwellings up to the year 2026 which should primarily be located on brownfield sites, within the village envelopes, and in key rural service centres. This proposed development should not take place as it is outside the village envelope and the three rural service centres. A development of this size would be a disproportionate share of rural housing provision in one small village.

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8 National Planning Policy Framework

This policy raises a number of significant issues in respect of the development process. It states that the development plan should empower local people to shape their surroundings, take into account different areas, and recognise the intrinsic and beauty of the countryside. It should focus primarily on development in locations WHERE IT IS SUSTAINABLE It should also reflect local housing NEEDS and the VIEWS of the COMMUNITY. Transport systems used should be balanced in favour of sustainability giving people a choice about how they travel ensuring a safe and suitable access can be achieved to the development. There should also be an aim to minimise journey-lengths for employment, shopping, leisure and education. Overall, the planning system should contribute to, and enhance the local environment by protecting landscapes and should be based on NEED.

The proposed development comprehensively fails to meet the aims of the national policy and ignores the views of local residents.

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9 Sustainability The crux of this matter is whether or not the proposed development would be SUSTAINABLE, for it is this point that decides whether or not the planners have to view it with a “presumption in favour of approval”. “Presumption in favour of approval” applies only to developments that are SUSTAINABLE.

We consider this development would be UNSUSTAINABLE.

The NPPF states that…

In order to fulfil its purpose of helping achieve sustainable development, planning must not simply be about scrutiny. Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives. This should be a COLLECTIVE enterprise. Yet, in recent years, planning has tended to exclude, rather than to include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them. Dismantling the unaccountable regional apparatus and introducing neighbourhood planning addresses this.

The villagers of Baldwins Gate, in the parish of Whitmore have stated their NEEDS and DESIRES already in the previously mentioned documents, which show NO NEED for a development of this scale and a confirmation that only INFILL development WITHIN THE VILLAGE ENVELOPE is to be allowed. So from a NEIGHBOURHOOD point of view, this Application should automatically be refused.

Newcastle’s previous planning decisions have taken the above into account and policy documents have made reference to several points.

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The NPPF identifies three dimensions to sustainability, namely ECONOMIC, SOCIAL and ENVIRONMENTAL.

ECONOMIC

1. The Applicant states that the development will create 97 full-time jobs within the construction industry over a 3-year period. Whilst it may sustain employment for 97 individuals, these are not necessarily new jobs nor are they guaranteed to employ local people or unemployed people. In any event, it is unlikely that the build would take three years. Since it is the intention of the Applicant to sell the site to a development company, how can they possibly know how many jobs this will create or where the workforce will come from.

2. It is stated that the proposed development will generate £1.4 million per annum within the local economy. This makes huge assumptions that all prospective residents would come from outside the Borough, whereas, in reality, it is most likely the majority would come from elsewhere within the Borough. It also assumes that most of their spending will be within the Borough whereas that is very unlikely. Therefore, the Applicants’ claim that this expenditure would support an additional 16 jobs in the Borough is specious.

3. The Applicants claim that their development would attract highly paid executives from outside the area. We dispute whether this estate would provide the high-quality housing which the Applicants claim. In view of the density and size of the proposed properties, this would be unlikely.

4. The Applicants’ claim that the Borough would benefit by £1.1 Million from the New Homes Bonus. In fact, wherever these houses were to be built, the Borough would benefit but THIS LOCATION IS UNSUSTAINABLE.

SOCIAL

1. The applicant states that there is a MARKET and AFFORDABLE HOUSING NEED. This is just not true according to the Rural Housing Needs Survey. There are already 10% of properties for sale within the village in a wide price range and many are on the market for over 12 months before being sold.

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The development would be completely contrary to policy H1 (Residential Development) of the Local Plan as the site is NOT WITHIN THE VILLAGE ENVELOPE. The clear intention of this policy was to ensure that development took place in a sustainable manner and did not destroy irreplaceable green-field sites. The Applicants are attempting to create a housing MARKET for financial gain rather than fulfilling a genuine housing need.

2. The Applicant has stated that the site is: “well located and has the potential to reduce the reliance on the private motor vehicle”. This statement is patently untrue as most households of the development will have two vehicles and will have to travel to Newcastle, Stoke-on-Trent or further, as there is minimal employment within the village of Baldwins Gate and limited facilities of all types.

ENVIRONMENTAL

The assertion by the Applicant that a high density style of housing development can in some way regenerate an already beautiful and impressive rural landscape is, to say the least, illogical. If the principle of this argument were accepted then developments should in future be approved on some of the most outstanding landscapes within the Borough. We are sure that in planning terms such an approach would be strongly resisted as it would make a complete mockery of careful structured planning and development that has taken place within the Borough of Newcastle-under-Lyme in the past.

The application, if approved, would cause demonstrable harm to an area of great landscape value by the destruction of the very landscape that previous planning decisions have sought to protect.

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The NPPF goes on:

International and national bodies have set out broad principles of sustainable development. Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the NEEDS of the present without compromising the ability of future generations to meet their own needs. The UK Sustainable Development Strategy “Securing the Future” set out five ‘guiding principles’ of sustainable development: living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy promoting good governance; and using sound science responsibly.

Meeting the needs of the present without compromising the ability of future generations to meet their own needs:

It has always been a national as well as a local policy that the best grades of AGRICULTURAL LAND should not be built upon. To do so is to use a finite natural resource of the country, which reduces the long term ability of the country to feed its rapidly increasing population.

The field upon which this development is intended to take place consists of grades 1 and 2 agricultural land; the highest quality soils capable of producing excellent crops. Although currently used as pasture-land and to grow fodder for a dairy herd, this does not mean that future generations could not use it for other crops. In fact, in the past, it has been used to grow potatoes and wheat on many occasions.

The Newcastle Borough Local Plan of 2011 stated that the value of land such as this lay…

“in its intrinsic quality as agricultural land. Development can be irreversible. There is a need to protect green-field land, including the best and most versatile land defined as land in grades 1, 2 and 3a of the Agricultural Land Classification, from development that would cause it irreversible damage. Government guidance suggests that development should not be permitted on agricultural land unless opportunities have been assessed for accommodating development on previously developed sites and on land within the boundaries of existing urban areas. Where development of agricultural land is

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unavoidable, areas of poorer quality land should be used in preference to that of higher quality. In the Borough there are significant areas of previously developed land while agricultural land in grades 1, 2 and 3a is in relatively short supply.”

Development on agricultural land, including the best and most versatile land, defined as land in grades 1, 2 … will not be permitted unless it can be demonstrated that the development cannot be accommodated on previously developed land and on land within the boundaries of existing urban areas. Where development of agricultural land is unavoidable, areas of poorer quality land should be developed in preference to that of a higher quality.

The Applicant points out in para 8.17 of their Planning Statement that more recent government guidance states that proposed development of greenfield sites should not be refused where the development is sustainable. Since everything points to this development being UNSUSTAINABLE for other reasons, there is no need to take this paragraph into account. In any case, in view of the limited land of this grade within the Borough, the permanent destruction of this finite natural resource is in itself enough to class the development as UNSUSTAINABLE.

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Living within the planet’s environmental limits: Any development which requires all its residents to use the car for general day-to-day living is to be discouraged. Baldwins Gate is on a single bus route with only an hourly service (recently described as “limited public transport” in the Planning Committee’s decision regarding the Barbour Store nearby).

Anyone wishing to travel to a destination, which is not on the Shrewsbury to Hanley route, already has great difficulty in doing so.

In their planning statement prepared by Hourigan-Connolly, Richborough claim that…

“The site is well located in relation to LOCAL SERVICES and has the potential to reduce reliance on the private motor vehicle.”

THIS IS PATENTLY UNTRUE.

How can a site, five miles from the nearest town, with one bus per hour on a single bus route, possibly reduce the reliance on the private motor vehicle?

The only LOCAL SERVICES we enjoy in Baldwins Gate, (recently described in a Planning Committee report as “some basic facilities”) are two small independent shops (a butcher and a newsagent/post office), the independent filling station, a pub, and a junior school that is full.

The Applicant has also incorrectly assessed the medical facilities available within the village by assuming that Baldwins Gate Surgery is a separate practice from that of Madeley. It is, in fact, a branch surgery of that practice, open for only 3 hours each morning during which times a doctor is not always present. Patients will, by necessity, have to travel to Madeley Practice outside these times, for which no public transport is available.

The village has no secondary school, no pre-school nursery, no ante-natal clinic, no pharmacy, no dentist, no chiropodist, and no optician. Also there is no direct public transport link with the University Hospital of North Staffordshire.

There is no public transport between Baldwins Gate and Madeley, and no prospect of any such public transport ever being provided. Nor is there any possibility of a full-time doctors surgery or a secondary school. There is no dentist, no hairdresser, no pre-school nursery, no ante-natal services, no library, no supermarket, no entertainment, no sports facilities and no take-away food outlets.

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The possibility of reducing reliance on the private motor vehicle IS NIL. How could their suggested extra 113 properties REDUCE reliance on the car?

The Borough Council’s Carbon Management plan states that:

“This council is leading Newcastle-under-Lyme to a sustainable and LOW CARBON future”.

At a time when we are being urged to reduce our Carbon Footprint, it is difficult to see how the proposed development can be claimed to be environmentally sustainable.

As stated in Newcastle’s own previous planning guidance: WHERE WE BUILD IS AS IMPORTANT AS WHAT WE BUILD.

It is NOT SUSTAINABLE to build houses where EVERYONE has to travel by car.

Using data from the borough’s own website, it is easy to calculate that the cars from the new houses would be generating green-house gases at the rate of around 2 TONNES of CO2 PER DAY!

The proposed site is NOT SUSTAINABLE as it is increasing the carbon footprint of the village.

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Ensuring a strong, healthy and JUST society

The Housing Needs Survey carried out by Newcastle Borough Council shows that it is a JUST society in that it is listening to and considering the needs of its residents. When conducted in 2009 by Newcastle Borough Council with Sanctuary Housing, the survey showed a NEED for 14 houses.

But on a wider scale, having an increase in population of up to 50% in one small village, imposed by some higher authority AGAINST THE WISHES OF THE MAJORITY would NOT BE JUST.

Achieving a sustainable economy

Richborough’s Planning Statement makes a habit of attempting to mislead without anyone being able to accuse them of dishonesty. They constantly point out the requirement to approve sustainable development without ever actually claiming that their proposed development is itself sustainable. The nearest they come is to claim that their proposed site “HAS THE POTENTIAL TO BE” sustainable. EVERY FIELD IN THE BOROUGH has the potential to be a sustainable development site if enough money is invested in providing the necessary INFRASTRUCTURE but, in its existing state, the village has inadequate infrastructure for any major development and therefore such development would be UNSUSTAINABLE.

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Infrastructure The Applicant, as part of their attempt to secure a sustainable approach, has offered significant financial assistance to a number of Service Providers and organisations. However, these offers alone do not address the sustainability question unless improvements to facilities and services are implemented BEFORE the development is complete i.e. additional primary school accommodation, improvements to the sewage works/drainage systems, and additional staffing/building for medical services. Although they have offered one-off payments, some of these services will require additional financial resources indefinitely e.g. staff resources. This illustrates the need for INFRASTRUCTURE BEFORE DEVELOPMENT. Regarding financial commitments, it should be noted that the Applicant has made it clear that they intend to walk away from this development, should they obtain Outline Planning Permission.

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QUALITY OF LIFE The quality of life enjoyed by all the population, both now and in the future, is at the heart of Sustainability.

Policy S10 of the Local Plan:

In determining planning applications for any type of development, the Council will have regard to the likely effect on the quality of life of people in the locality. To the extent that such matters are material to the consideration of a planning application, development may be refused if it is considered that an unreasonable loss in quality of life would be caused, whether by direct or indirect effects, and it would not be practicable for the development to alleviate, or mitigate, such effects.

The lack of local infrastructure and problems arising from the poor local road network clearly illustrate that there will be an adverse effect on local residents and people travelling on the A53. This will have a significant negative impact on people’s lives, not least the residents of the Gateway Avenue estate.

The detrimental effects on the quality of life make this an UNSUSTAINABLE development.

CONCLUSION In conclusion, there are a considerable number of statements contained within the Application that are not backed up with accurate factual or statistical evidence. A large proportion of these statements are incorrect. This results in a lack of confidence that the application has been compiled in a competent and professional manner and, overall, questions the validity of conclusions that are reached by the Applicant.

The application does not meet the criteria of sustainability required to justify a “presumption in favour of approval” set out in the National Planning Policy Framework.

This Development would NOT BE SUSTAINABLE and should be refused on those grounds.

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Please note:

Should any additional material come to light before the application goes before the Planning Committee, we may wish to make further comment or objection.