Policy DM10 - Redevelopment of Previously Developed Land in the Green Belt

Our client supports policy DM10 Redevelopment of Previously Developed Land in the Green Belt which seeks to clarify adopted Core Strategy Policy GB2 - Rural Diversification and Recreational Uses in light of the NPPF. In particular, the confirmation that in certain circumstances retail, residential or other development of brownfield sites will be permissible, is welcomed.

Paragraph Objectives 2, para 3.2, 3.9-3.10, Policy DM10, Figure 3

Whilst under Objectives, Rochford council propose limited extensions to settlements to prevent coalescence of same and at Paragrpahs 3.2 to prevent settlements merging, there is contradiction - under Landscape Character council propose at para 3.9-3.10, Figure 3, 3 landscape character areas: farmland, coastal and South Essex Coastal Towns - completely involved Rayleigh and Rochford (plus slight extensions) with Hockley, Hawkwell, Ashingdon - effectively creating a conurbation, abolishing any green belt involved. So called SECT is denoted "least sensitive to change", mixed, but unified by overall dominance of urban development, with frequent views of an urban skyline", marked by masts, pylons and a "decline in countryside management". At paras. 3.23, 25, 30, Policy DM10, virtually all development is to go in SECT. (Clearly the Hockley Area Action Plan proposals are intended to make central Hockley a huge national shopping centre to serve such conurbation.)

This negates pious proposals to avoid impact of new development on character of an area set out in Housing chapter at paras 2.7-8 and promotion of Parish Plans etc to guide developers at para 2.10, all of which can be regarded with due scepticism in view of creeping urbanisation apparently sought.

The general approach of policy DM10 is supported whereby the Local Planning Authority recognises that redevelopment of previously developed land (PDL) in the Green Belt may be acceptable. Nevertheless, the supporting text to policy DM10, as well as the actual wording of policy DM10 is not supported and it is recommended that greater flexibility and less prescriptive text is incorporated within the wording of policy DM10 and supporting text (paragraphs 3.12 to 3.32) to DM10. It is submitted that changes to policy DM10 and the supporting text to policy DM10 are required in order for the policy to comply with the National Planning Policy Framework (NPPF).

Paragraph 89 of the NPPF states that:

" A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:
- buildings for agriculture and forestry;
- provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
- the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;
- the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
- limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan; or
- limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development."
(Underlining added for emphasis)

The NPPF is therefore quite clearly supportive of redevelopment of PDL within the Green Belt so long as the proposed development does not have a greater impact on the openness of the Green Belt and the purpose of including land within it that the existing development. It is submitted that emerging Rochford policy DM10 sets far too much prescriptive and restrictive caveats to potential redevelopment of PDL within the Green Belt. Most notably, the suggestion at supporting text 3.20 and 3.29 that redevelopment of PDL within the Green Belt will only be acceptable when located within 800m of a defined settlement boundary, or within 800m of local services and facilities including schools, doctor's surgeries and shops, is unreasonable and overly restrictive. It is recommended that Policy DM10 and supporting text should be redrafted to reflect the straight-forward and clear guidance contained within the NPPF. All sites are quite clearly different and proposed redevelopment of PDL may contribute towards and represent sustainable development in different ways including through economic, social and environmental measures. Site location is not the only measure of sustainable development, and does not represent a useful tool against which to consider the suitability of redevelopment of PDL within the Green Belt. The inclusion of text alongside policy DM10 referring to 800m walking distance is unreasonable and unnecessary.

Suitable sites for residential led / mixed-use sustainable development include sites such as the Hambro Nursery / Clovelly Works site, Rawreth, which benefits from easy access to Battlesbridge railway station, as well as other services and facilities within Battlesbridge, Rochford and Wickford. The enclosed brochure identifies the potential for a sustainable development at the Hambro Nursery / Clovelly Works site. The NPPF (notably paragraph 89) provides support to and guidance for development proposals to demonstrate that redevelopment of PDL can take place within the Green Belt, particularly where there is no greater harm to the Green Belt than an existing use. Policy DM10 should be amended to provide greater flexibility and scope for redevelopment of PDL within the Green Belt.