Object
Development Management DPD Preferred Policy Options Document
Representation ID: 28320
Received: 27/02/2012
Respondent: Ms G Yeadell
1. COMMUNITY INVOLVEMENT
1.19 Proposal for this makes no difference. Consultation, then LPA will do as they planned anyway.
1.23 In spite of sustainable community strategy - promoting a green district - hundreds of dwellings are proposed for the green belt, plus densification of settlements.
2. HOUSING, CHARACTER OF PLACE AND RESIDENTIAL AMENITY
Vision - short, medium, long term
If a number of residential developments are completed to meet local needs, why a whole lot more? We have not heard the outcome of the Local List consultation. Much of the historical built environment has been destroyed in eg Hockley
Objectives
No.6 "..appropriate infrastructure to accompany new development" - this can only be achieved by more destruction.
Nos.4,7,8 It is proposed to prioritise brownfield development to minimise green belt use, new development to respect built environment. Unfortunately RDC has already allowed/encouraged huge buildings out of scale with existing, intentionally to make a precedent to delete local traditional buildings. These outsize characters will now be the 'respected' built environment. "Built heritage" is already being eroded, many character dwellings have been cleared away in Hockley. Some say these had huge gardens as excuse to demolish, redevelop, but some had hardly any.
HOUSING, DESIGN OF NEW DEVELOPMENTS
2.2,2.4,2.6 "protection of settlement characteristics" may apply in Rochford, Rayleigh, Paglesham etc, but such items are still being destroyed elsewhere. Ashingdon, Hockley, Hawkwell will become a conurbation.
Draft Policy DM1 - Design of New Developments "should respect character of locality" - I'm afraid this is shutting stable door after horse has gone and it still goes on. Each decade is marked by plans to redevelop the same patch over again.
DENSITY OF NEW DEVELOPMENTS
2.15 "..ensuring effective use of existing housing stock" usually means demolition, including of traditionally rural scaled dwellings, replaced by mansions.
Figure 2 - average density from random samples Why is Hockley marked as having the highest density? Is this LPA's plan for the future of Hockley?
INFILLING AND RESIDENTIAL INTENSIFICATION
2.19 "Infilling defined as filling the 'small gaps' between existing groups of dwellings with new development" - in other words, demolition, town cramming, densification. What 'small gaps'? In 2010 we learned homes/gardens will no longer be designated brownfield and automatically planned for redevelopment. But it seems PPS3 has overridden this - so demolish one home and build more in its place, provided there is a tiddly bit of garden. "..where it conforms to existing street pattern.." - first allow mansions, then make the rest conform to that?
2.20 This is a contradiction - you admit "infilling/intensification can have negative impact" and town cramming, so a "restrictive approach" is needed, but demolishing one and replacing with more amounts to the same thing.
2.21 "Backland development where development proposed to rear of existing dwellings in large back gardens ..inappropriate due to tandem relations..intensification..detriment to neighbouring dwellings". One takes the point, but this is why people resort to this kind of thing, precisely to prevent builders/planners demolishing them, that results in home loss, more town cramming, etc. People are on a hiding to nothing if they don't protect themselves with something. It seems heads you lose, tails you lose.
2.22 Demolishing one, to replace with more, as alternative to 'backlands' results in more demolition, town cramming - you don't seem to get away from demolition. Replacement of bungalow with flats is discouraged, but LPA were happy to replace a period house with 11 flats.
LIGHT POLLUTION
2.33 "Inappropriate lighting can create..pollution. affect local character, cause stress, anxiety for those adversely affected". A pity you didn't consider these rules in time. An RDC letter of January 2004 said private 10' lamp posts were ok in planning, but RDC not responsible for "the light emitting from the top of them"!
2.35 ".full horizontal cut off (prevention of light spillage into adjoining areas)" [specifically should mean prevention of light spillage in bedrooms from adjacent development ].
2.36- 2.40 I disagree with your arrangements for EZ1, 2, 3 - viz. "EZ3 - within development boundaries". According to Institute of Lighting Engineers rules, EZ1 is dark - National parks, etc, EZ2 is low district brightness - industrial, residential rural areas, EZ3 is medium district brightness, small town industrial, residential suburbia. This is not the same as your idea of EZ1 full darkness, EZ2 green belt, EZ3 residential.
"Lighting proposals permitted if proposer can demonstrate..scheme is minimum needed for security and/or working purposes". So it is usual to be working at 3am at a residential property for example? As for security, there are such things as electronic gates, burglar alarms, CCTV can be lit by infrared spot lights. If idiots must have lights on all night, they could have, say, 3-4ft high lamps, with total cut off above that height, so all light is directed downwards for access, rather than lighting up the whole walls, roof etc - and everyone else nearby as well. Incidentally it has been proved that if you light up a property to that extent, neighbouring properties are much darker at ground level than they would be, so making them vulnerable to burglary.
2.40 RDC considers ILE Curfew (reducing light at late night, circa 11pm) "unreasonable"
as RDC will decide how much trespass is allowed for working/security at 3 am!
Table 3 (amended from ILE Guidance) I hope you have to put up with EV 10 LUX in your bedroom windows all night. The whole idea of light pollution rules is to prevent that.
I note careful protection of Listed buildings, conservation areas etc. Could we all be so protected?
2.42 Apparently a detailed scheme is not always considered necessary - why not?
Clean Neighbourhood and Environment Act 2006 is ignored. Incidentally lighting in adopted, public roads, as opposed to private development schemes, is excluded from the ACT. However, complaints from residents around UK about street lights (as in the public street) have resulted in public lights being amended, but RDC doesn't apply this to private developments apparently.
ENVIRONMENTAL ISSUES
Nature and Conservatrion
Trees and Woodlands
4.11-4.13
Draft Policy DM24
Development resulting in loss of trees etc, this should be mitigated. Unfortunately we all know that that means - TPO trees, hedgerows replaced by 'sticks'.
1. COMMUNITY INVOLVEMENT
1.19 Proposal for this makes no difference. Consultation, then LPA will do as they planned anyway.
1.23 In spite of sustainable community strategy - promoting a green district - hundreds of dwellings are proposed for the green belt, plus densification of settlements.
2. HOUSING, CHARACTER OF PLACE AND RESIDENTIAL AMENITY
Vision - short, medium, long term
If a number of residential developments are completed to meet local needs, why a whole lot more? We have not heard the outcome of the Local List consultation. Much of the historical built environment has been destroyed in eg Hockley
Objectives
No.6 "..appropriate infrastructure to accompany new development" - this can only be achieved by more destruction.
Nos.4,7,8 It is proposed to prioritise brownfield development to minimise green belt use, new development to respect built environment. Unfortunately RDC has already allowed/encouraged huge buildings out of scale with existing, intentionally to make a precedent to delete local traditional buildings. These outsize characters will now be the 'respected' built environment. "Built heritage" is already being eroded, many character dwellings have been cleared away in Hockley. Some say these had huge gardens as excuse to demolish, redevelop, but some had hardly any.
HOUSING, DESIGN OF NEW DEVELOPMENTS
2.2,2.4,2.6 "protection of settlement characteristics" may apply in Rochford, Rayleigh, Paglesham etc, but such items are still being destroyed elsewhere. Ashingdon, Hockley, Hawkwell will become a conurbation.
Draft Policy DM1 - Design of New Developments "should respect character of locality" - I'm afraid this is shutting stable door after horse has gone and it still goes on. Each decade is marked by plans to redevelop the same patch over again.
DENSITY OF NEW DEVELOPMENTS
2.15 "..ensuring effective use of existing housing stock" usually means demolition, including of traditionally rural scaled dwellings, replaced by mansions.
Figure 2 - average density from random samples Why is Hockley marked as having the highest density? Is this LPA's plan for the future of Hockley?
INFILLING AND RESIDENTIAL INTENSIFICATION
2.19 "Infilling defined as filling the 'small gaps' between existing groups of dwellings with new development" - in other words, demolition, town cramming, densification. What 'small gaps'? In 2010 we learned homes/gardens will no longer be designated brownfield and automatically planned for redevelopment. But it seems PPS3 has overridden this - so demolish one home and build more in its place, provided there is a tiddly bit of garden. "..where it conforms to existing street pattern.." - first allow mansions, then make the rest conform to that?
2.20 This is a contradiction - you admit "infilling/intensification can have negative impact" and town cramming, so a "restrictive approach" is needed, but demolishing one and replacing with more amounts to the same thing.
2.21 "Backland development where development proposed to rear of existing dwellings in large back gardens ..inappropriate due to tandem relations..intensification..detriment to neighbouring dwellings". One takes the point, but this is why people resort to this kind of thing, precisely to prevent builders/planners demolishing them, that results in home loss, more town cramming, etc. People are on a hiding to nothing if they don't protect themselves with something. It seems heads you lose, tails you lose.
2.22 Demolishing one, to replace with more, as alternative to 'backlands' results in more demolition, town cramming - you don't seem to get away from demolition. Replacement of bungalow with flats is discouraged, but LPA were happy to replace a period house with 11 flats.
LIGHT POLLUTION
2.33 "Inappropriate lighting can create..pollution. affect local character, cause stress, anxiety for those adversely affected". A pity you didn't consider these rules in time. An RDC letter of January 2004 said private 10' lamp posts were ok in planning, but RDC not responsible for "the light emitting from the top of them"!
2.35 ".full horizontal cut off (prevention of light spillage into adjoining areas)" [specifically should mean prevention of light spillage in bedrooms from adjacent development ].
2.36- 2.40 I disagree with your arrangements for EZ1, 2, 3 - viz. "EZ3 - within development boundaries". According to Institute of Lighting Engineers rules, EZ1 is dark - National parks, etc, EZ2 is low district brightness - industrial, residential rural areas, EZ3 is medium district brightness, small town industrial, residential suburbia. This is not the same as your idea of EZ1 full darkness, EZ2 green belt, EZ3 residential.
"Lighting proposals permitted if proposer can demonstrate..scheme is minimum needed for security and/or working purposes". So it is usual to be working at 3am at a residential property for example? As for security, there are such things as electronic gates, burglar alarms, CCTV can be lit by infrared spot lights. If idiots must have lights on all night, they could have, say, 3-4ft high lamps, with total cut off above that height, so all light is directed downwards for access, rather than lighting up the whole walls, roof etc - and everyone else nearby as well. Incidentally it has been proved that if you light up a property to that extent, neighbouring properties are much darker at ground level than they would be, so making them vulnerable to burglary.
2.40 RDC considers ILE Curfew (reducing light at late night, circa 11pm) "unreasonable"
as RDC will decide how much trespass is allowed for working/security at 3 am!
Table 3 (amended from ILE Guidance) I hope you have to put up with EV 10 LUX in your bedroom windows all night. The whole idea of light pollution rules is to prevent that.
I note careful protection of Listed buildings, conservation areas etc. Could we all be so protected?
2.42 Apparently a detailed scheme is not always considered necessary - why not?
Clean Neighbourhood and Environment Act 2006 is ignored. Incidentally lighting in adopted, public roads, as opposed to private development schemes, is excluded from the ACT. However, complaints from residents around UK about street lights (as in the public street) have resulted in public lights being amended, but RDC doesn't apply this to private developments apparently.
ENVIRONMENTAL ISSUES
Nature and Conservatrion
Trees and Woodlands
4.11-4.13
Draft Policy DM24
Development resulting in loss of trees etc, this should be mitigated. Unfortunately we all know that that means - TPO trees, hedgerows replaced by 'sticks'.