Object

Allocations: Schedule of modifications

Representation ID: 33104

Received: 12/01/2014

Respondent: Mr Nick Matthews

Representation Summary:

I object to the proposed reduction of the distance of the residential development from the high voltage pylon lines to "further than 30 metres", rather than 60 metres, as I also object to increasing the proposed site boundary entailing further loss of green belt agricultural land (see objection to MM20). While it is written that this is all for the purposes of ensuring there is a road within the development, it also allows the possibility of more than 550 homes given the proposed removal of the 5% cap (MM20).

Full text:

I object to the proposed reduction of the distance of the residential development from the high voltage pylon lines to "further than 30 metres", rather than 60 metres, as I also object to increasing the proposed site boundary entailing further loss of green belt agricultural land. All for the purposes of ensuring there is a road within the development (though it cannot be excluded it is also to allow the possibility of more than 550 homes given the proposed removal of the 5% cap (MM20).

With regards to elements of the Sustainability Appraisal of the Allocations Submission Document, it is difficult to see how losing further greenbelt land currently in agricultural use - by turning it into allotments in order to better accommodate a road (or provide more room for more houses if the 5% cap is removed) within the site - provides a "more robust greenbelt boundary" than its predecessor. By definition greenbelt land for agricultural use is already there and is in itself a "greenbelt boundary". This is dishonest tautology. It is quite simply further loss of greenbelt land and on the basis it is difficult to see why it is assessed with a "+" in the Assessment of MM22, MM25, MM26, MM27, MM29 and MM20 in the Sustainability Appraisal of the Allocations Submission Document. The judgement that "it will also protect unwanted expansion into the Green Belt" is incorrect, since on current example the existing Green Belt is not protecting unwanted expansion into the Green Belt and the rules can simply be re-written or overturned at any future date.

Also, it is difficult to see how "the addition of a strong green buffer along the western boundary will have a positive impact on landscape". Open agricultural land is clearly more aesthetically pleasing than allotments, which typically result in unattractive and obtrusive features such as growing frames, sheds etc. This would be contrary to Policy/Paragraph 3.43 which states that "development must not adversely impact on the setting of the [grade II listed] building" ('Barn approximately 40 metres east of Rawreth Hall, Rawreth'). It is also inconsistent with the comments in Policy/Paragraph 3.46 which states: "A green buffer to the west of the site should have a positive impact on the approach into Rayleigh from this direction. There is an opportunity for the development of landmark buildings towards the western end of the site taking into account the principles of the Essex Design Guide whilst being sensitive to the neighbouring landscape. Design throughout the development should be of high quality."

A row of allotments does not imply a "positive impact on the approach into Rayleigh from this direction" or "being sensitive to the neighbouring landscape".

Again the judgement that this would provide a more defensible Green Belt boundary using permanent features are flimsy at best and Landscaping should be a "-" on its own, rather than offset by "++".

I do strongly support the view contained within the Sustainability Appraisal of the Allocations Submission Document on MM22, MM25, MM26, MM27, MM29 and MM20 which concludes under 8. Landscape & Townscape and 11. Land & Soil that "Both options perform less well than the baseline option of not allocating the site." On this basis a decision should be taken to reject these proposed changes and the proposed increase to the area of the site should be rejected. The argument that "it will ensure a stronger Green Belt boundary along the north eastern boundary to the site" is also contradictory by definition and lacks logic and honesty (i.e. how can the loss of a further 30m existing Green Belt boundary to build a road help to gain a "stronger Green Belt boundary"?!).