THE COLNE-STOUR COUNTRYSIDE ASSOCIATION

Kentwell Hall
Little Maplestead
Pentlow Mill
Melford Hall
Paycocke's
Cavendish

News, Events and Announcements

  

Date Added Subject
November 2013 Further Pylons Update
September 2013 Update on Buntings/Horkesley Park/Stour Valley Visitor Centre
May 2013 CSCA Submission to Planning Inspector re Appeal by Buntings
January 2013 CSCA Submission to Colchester Borough Council
July 2012 CSCA Response to National Grid's Connection Options Report
July 2012 CSCA Response to Colchester Borough Council
June 2012 Stour Valley Visitor Centre at Horkesley Park
June 2012 Pylons Update
September 2011 Consultation on the Government's National Policy Framework (NPPF)
March 2011  Localism Bill
January 2011 Localism Bill threatens massive new house building on greenfield farmland?

 

 

FURTHER PYLONS UPDATE.

You will be aware that National Grid have announced that because of changes to the timing of new generation projects in the East Anglian region, the proposed second 400Kv  line is not expected to be required until the early 2020's rather than 2017. As a result National Grid are putting the project on temporary hold. The Public consultation and formal application planned for next year will now take place nearer the time when connection is needed.

Some have interpreted this as a significant victory and speculate that with an intervening general election it may never happen. This is not right. All we have secured is a temporary stay. The revised Needs Case for the project makes it clear that a new line will eventually be required.

Nevertheless it is good news. This gives us a much needed further 3 or 4 years to prepare our opposition. Importantly, it will (a) give time to advance the application to extend the AONB and so reinforce National Grid's intentions to underground the Stour Valley through to Twinstead, even if rising energy prices increase public pressure for a cheaper alternative; (b) give us a better opportunity to try to have the existing overhead line put underground at the same time; and (c) enable us to increase the pressure to have the substation sited at Braintree and not Twinstead.,

Charles Aldous 19.11.2013.

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STATEMENT OF EVIDENCE TO BE GIVEN BY THE COLNE STOUR COUNTRYSIDE ASSOCIATION.


Re: Appeal AAP/A1530/A/13/2195924; Stour Valley Visitor Centre at Horkesley Park

The Colne Stour Countryside Association objects to the above development.

The proposals:

  • Contravene both National and Local Planning Policy designed to protect open countryside and Areas of Outstanding Natural Beauty in particular.
  • Are unsustainable, both as regards the viability of the scheme and importantly the excessive number of vehicles which will be drawn into the AONB.
  • Will threaten the peace and tranquillity of the AONB and place unacceptable pressure on it and on the other attractions within it, such as Flatford and Dedham.
  • Are unnecessary, in that many of the so called attractions are available elsewhere in the locality; with others such as the Chinese Garden alien to the very reason for the Dedham Vale being created an AONB.


It will be difficult to fully appreciate the importance of preserving the Dedham Vale from a single visit. It was granted AONB protection in 1970 because of its special unspoilt lowland rural landscape; succinctly described by the Countryside Commission as a rural idyll, with its rolling hills, gentle valleys, trees, riverbank willows, flood plain meadows, ancient narrow lanes, traditional villages and farm buildings, scattered churches and the meandering river. It is the quiet, timeless character of the Vale which it is so important to preserve for future generations to enjoy, walk through and experience, largely unspoilt, as it has stood for several hundred years. An area such as this in Eastern England is unique.

This was recognised by the Countryside Commission. In its report on the Dedham Vale in 1997, the Commission stressed that conserving this special landscape for future generations to enjoy will involve both the enforcement of effective planning policies, the adoption of an agreed management plan and “no doubt, the outspokenness of local communities who care about the Dedham Vale to resist harmful change”.   

All the various interested parties (including Suffolk and Essex County Councils, Colchester Borough Council, Braintree, Babergh and Tendring District Councils, Natural England, the National Trust and others) then got together to form the Dedham Vale AONB & Stour Valley Partnership, to oversee the area. Its remit was and is to conserve and enhance the special qualities of the Vale for future generations to enjoy; employing a Project team of dedicated professionals to manage it on a day to day basis. The award of £1m of Lottery Funding to the Project’s “Managing a Masterpiece” is testament to its standing when it comes to knowing how best to manage the Dedham Vale.

In accordance with the Countryside and Rights of Way Act 2000, a Management Plan for the Vale was duly agreed to and adopted, after wide consultation; the current Management Plan operated by the Project, including a Strategic Environment Assessment, being the AONB Management 2010-2015.

As to effective planning policies:

The National Planning Policy Framework (NPPF) stresses the importance of protecting the rural countryside and Areas of Outstanding Natural Beauty in particular.

To cite just two paragraphs:-

Paragraph 115 states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty which have the highest status of protection.

Paragraph 116 states that planning permission should be refused for major development in these designated areas except in exceptional circumstances.

The proposal for a large scale visitor attraction intended to draw in over 316,000 visitors per annum, mostly by car, (however unrealistic), is undoubtedly a major development. Further, although an important part of the site would be just outside the AONB, by far the largest part of the area of the proposed tourist centre, for which change of use is required, is within it, including the visitor park, Chinese Garden and so on.

This is a single development proposal affecting open countryside, with an essential and the largest part within the AONB. It can only be looked at as an integral whole.

Under the NPPF there is no presumption in favour of sustainable development where, as here, the proposal is for a major development within the AONB. Even so, the site is in a clearly unsustainable location, with a predicted 82% of visitors arriving by car. It was revealing, when during the planning hearing it was suggested that many cars would arrive at the site via the narrow approach lanes or then go on to explore the area, that the Highways Authority acknowledged that it had not carried out any satellite navigation survey of the routes into Horkesley Park.  

In short, both paragraphs 115 and 116 of the NPPF apply. It should be very rare for a major development to be allowed within the countryside and rarer still for a development of this size to be permitted within and adjacent to an AONB.

There are no exceptional circumstances, as is clear from the numerous local planning policies which the proposal would contravene. There is no need for this development and certainly not in the AONB. The claimed public demand for the centre has been grossly exaggerated. Even so, the presence of so many visitors each year, arriving mostly by car, many using the protected lanes, will have a detrimental effect on the environment. Further, the proposal is in conflict with the adopted Management Plan.
Numerous local planning policies would also be contravened by these proposals, including Core Strategy Policies SD1, CE1, TA1, Development Policies DP1, DP9, DP10 and DP17 and Environment Policies ENNV1 and 2. The Borough Council will presumably address these. Even were the proposals to fall outside the AONB, the scheme constitutes a very large scale development in the countryside, of which both national and local planning policies disapprove.  

I refer to Local Development Policy DP 22 which states that development will only be supported in or near to the AONB if it

(1)    does not adversely affect the character, quality, views and distinctiveness of the AONB or threaten public enjoyment of these areas, including by increased vehicle movement, and

(2)    supports the wider environmental, social and economic objectives as set out in the Dedham Vale AONB & Stour Valley Management Plan.

Even though part of the site is just outside, the whole is indisputably in or near to the AONB.This proposal would adversely affect the AONB, bringing in a huge influx of cars, many driving through the narrow protected lanes, which the Vale cannot sustain. There will be inevitable noise and light pollution to what should remain a quiet tranquil area for walkers and horse riders to enjoy. A theme park such as this is incompatible with the intrinsic character and beauty of the AONB.

Importantly, the proposal is also in conflict with the adopted Management Plan, breaching the second condition of DP22. This matter will be addressed by the Project. We ask that the Inspector takes time to familiarise himself with the work being undertaken by the Project, its objectives, educational activities, public participation, provision within the Vale of sustainable public transport and the future projects already planned; see the Project’s web site www.dedhamvalestourvalley.org. From this the Inspector will appreciate that it and the National Trust at Flatford are the bodies able to manage the AONB in a way which best enables the public to enjoy the Vale in all its aspects, whilst at the same time protecting its rural character and tranquillity. There is already very good public access to the Vale. With its many public footpaths and protected lanes, the public are able to see, experience and enjoy the Vale in its natural state and free of charge; not as a fenced off private theme park and retail centre.

There is no tourism need for this centre and certainly not in and adjacent to the AONB. Many of the elements of the proposal are already available elsewhere in the locality, including Flatford Mill, the Museum of East Anglian Life, Easton Farm Park, the Suffolk Punch Centre at Hollesley Bay, Jimmies Farm and Kentwell Hall. Culturally, Constable had little or no connections with Great Horkesley. For displays of paintings, there is Gainsborough House in Sudbury, Sir Alfred Munnings Museum in Dedham and Christ Church Mansion in Ipswich, which claims the most Constable paintings outside London. A celebration of the English countryside is catered for and Suffolk Punches are on display at a number of these centres. In so far as there may be interest in some of the various activities contained in the proposal there is no requirement for these to be in the AONB, rather than elsewhere in a more sustainable location. There is no reason why the Suffolk Punch attraction and breeding centre needs to be at Great Horkesley, other than the fact that the Appellant happens to own land there.

The claimed demand of over 316,000 visitors per annum for the attraction has been shown to be wholly unrealistic. Other objectors will best explain the shortcomings with the so called Chantry Art Gallery and its claimed ability to display of Constable paintings. As for the Chinese Garden, there can be no justification for creating this within the AONB.

Although the new buildings to replace the greenhouses may be seen as an improvement, given their current state, there is no good reason why this site cannot be put back to some form of agricultural related use. The fact that this may not be as profitable to the Appellants should be disregarded. The Appellants have allowed the site to deteriorate whilst pursuing their various schemes to turn the site into a theme park and retail centre.

Returning to the perceptive comment made by the Countryside Commission (see above), it is significant that virtually all those closely involved with caring for the Dedham Vale are resolutely opposed to these proposals.

We beseech you, Sir, to support the Borough Council and reject this appeal.


Charles Aldous, QC (Chairman).
(Although practicing as a commercial barrister, I did not specialise in planning)

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CSCA SUBMISSION TO PLANNING INSPECTOR RE APPEAL BY BUNTINGS

Attention of Robert Cook,
The Planning Inspectorate,
Room 3/02 Temple Quay House,
2 The Square, Bristol BS1 6PN.


Dear Sir,                                                                                                          24th May 2013

Re: Application AAP/A1530/A/13/2195924; Stour Valley Visitor Centre at Horkesley Park.


I write as Chairman of the Colne Stour Countryside Association to object to the above Appeal. Please pass this letter to the Inspector. This Association has consistently opposed this and the previous application from the outset. I refer you to my letter dated 26th January 2013, which I ask to be taken into account on the Appeal.

The Association, which is of long standing with a current membership of over 650, acts along side the Dedham Vale Society to protect the Stour Valley.

The Dedham Vale was granted Area of Outstanding Natural Beauty protection in 1970 because of its special unspoilt lowland rural landscape; succinctly described by the Countryside Commission as a rural idyll, with its rolling hills, gentle valleys, trees, riverbank willows, flood plain meadows, ancient narrow lanes, traditional villages and farm buildings, scattered churches and the meandering river.  In its report on the Dedham Vale Landscape in 1997, the Countryside Commission stressed that conserving this special landscape for future generations to enjoy will involve both the enforcement of effective planning policies, the adoption of an agreed management plan and” no doubt, the outspokenness of local communities who care about the Dedham Vale to resist harmful change”.

Such a Management Plan was duly agreed to and adopted by all the various interested parties (including Suffolk and Essex County Councils, Colchester Borough Council, Braintree, Babergh and Tendring District Councils, Natural England, the National Trust and others). 

The Planning Authority found, comprehensively, that the Appellants’ proposal would conflict with both national and local planning policy as well as the Management Plan.

 

 The National Planning Policy Framework (NPPF) recognises the importance of protecting Areas of Outstanding Natural Beauty.

To cite just two paragraphs from the NPPF:-

Paragraph 115 states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty which have the highest status of protection.

Paragraph 116 states that planning permission should be refused for major development in these designated areas except in exceptional circumstances.

The proposal for a large scale visitor attraction intended to draw in over 316,000 visitors per annum, mostly by car, (however unrealistic), is undoubtedly a major development. Further, although part of the new development would be just outside the AONB, by far the largest part of the area of the proposed tourist centre, for which change of use is required, is within it, including the visitor park, Chinese Garden and so on. This is a single development proposal affecting the AONB, with a highly material part within it, and must be looked at as an integral whole. Although an issue for the Inspector to decide, the Borough’s Planning Policy Department said in its Planning Policy Statement that “It is clear that the tourist attraction as a major development as a whole would include land within the AONB and therefore it is considered that paragraph 116 of the NPPF is relevant.” (para 3.2.32).

As the Council correctly held, under the NPPF there is no presumption in favour of sustainable development where, as here, the proposal is for a major development within the AONB. Even so, the site is in a clearly unsustainable location, with a predicted 82% of visitors arriving by car. It was revealing, when during the hearing it was suggested that many cars would arrive at the site via the narrow approach lanes or then go on to explore the area, that the Highways Authority acknowledged that it had not carried out any satellite navigation survey of the routes into Horkesley Park.

In short, paragraph 116 of the NPPF applies. There are no exceptional circumstances, as is clear from the numerous local planning policies which the proposal would contravene. There is no need for this development and certainly not in the AONB (see further below). The claimed public demand for the centre has been grossly exaggerated, as evidenced by the reports on possible visitor numbers from the independent experts, Britton McGrath Associates. Even so, the presence of so many visitors each year, arriving mostly by car, many using the protected lanes, will have a detrimental effect on the environment. Further, the proposal is in conflict with the adopted Management Plan.

Numerous local planning policies would also be contravened by these proposals, including Core Strategy Policies SD1, CE1, TA1, Development Policies DP1, DP9, DP10 and DP17 and Environment Policies ENNV1 and 2. 

For emphasis, I refer to Development Policy DP 22; which states that development will only be supported in or near to the AONB if it

(1) does not adversely affect the character, quality, views and distinctiveness of the AONB or threaten public enjoyment of these areas, including by increased vehicle movement, and

(2) supports the wider environmental, social and economic objectives as set out in the Dedham Vale AONB & Stour Valley Management Plan.

This proposal would, if allowed, adversely affect the AONB, bringing a huge influx of cars into the AONB, many, as stated, driving through the narrow protected lanes, which the Vale cannot sustain. There will be inevitable noise and light pollution to what should remain a quiet tranquil area for walkers and horse riders to enjoy. A theme park such as this is, as the Council rightly held, incompatible with the intrinsic character and beauty of the AONB.

Further, as stated, the proposal is in conflict with the adopted Management Plan, as made clear by the Dedham Vale AONB & Stour Valley Partnership’s objection, being the body responsible for producing and overseeing the Plan. We ask that the Inspector takes time to familiarise himself with the work being undertaken by the Partnership, its objectives, educational activities, public participation, provision within the Vale of sustainable public transport and the future projects already planned. From this the Inspector will appreciate that the Partnership (in conjunction with the National Trust at Flatford) are the bodies able to manage the AONB in a way which best enables the public to enjoy the Vale, whilst at the same time protecting its rural character and tranquillity. There is very good public access to the Vale. With its many public footpaths and protected lanes, the public are able to see, experience and enjoy the Vale in its natural state free of charge and not as a fenced off private theme park and retail centre. The Plan can be found on the Partnership’s web site www.dedhamvalestourvalley.org.

There is no tourism need for this centre and certainly not in the AONB. Many of the elements of the proposal are already available elsewhere in the locality, including Flatford Mill, the Museum of East Anglian Life, Easton Farm Park, the Suffolk Punch Centre at Hollesley Bay, Jimmies Farm and Kentwell Hall. Culturally, Constable had little or no connections with Great Horkesley. For displays of paintings, there is already Gainsborough House in Sudbury, Sir Alfred Munnings Museum in Dedham and Christ Church Mansion in Ipswich, which claims the most Constable paintings outside London. A celebration of the English countryside is already catered for and Suffolk Punches are on display at a number of these centres.

In so far as there may be interest in some of the various activities contained in the proposal there is no requirement for these to be in the AONB, rather than elsewhere in a more sustainable location. There is no reason why the Suffolk Punch attraction and breeding centre needs to be at Great Horkesley, other than the fact that the Appellant happens to own land there.

Other objectors will best explain the shortcomings with the so called Chantry Art Gallery and its claimed ability to display of Constable paintings. As for the Chinese Garden, which even after months of prehearing preparation still lacked any design detail, there can be no justification for creating this within the AONB.

The Grounds of Appeal are in part nonsense and in other respects misconceived.

It is nonsense to claim that the proposals are in accordance with the NPPF and the Local Development Plan and policies. They are not, as comprehensively rejected by the Committee. 

It is not proposed in this submission to go through each of the grounds which have already been addressed seriatim in the response from the Nayland with Wissington Conservation Society.          

The claimed demand of over 316,000 visitors per annum for the attraction has been shown to be wholly unrealistic, as made clear by Britton McGrath Associates. The Planning Committee members were rightly concerned over the Applicants refusal to disclose its Business Plan other than in confidence to the planning officers. The same concerns were expressed about the absence of any firm detail on the paintings said to be exhibited. This Association, along with many other objectors, had complained over many months of their inability to be able to scrutinise the Business Plan. They had been denied the opportunity to show that the Plan was unviable and would inevitably result, if change of use were to be permitted, to ever increasing theme park activities and retail use in an attempt to make it pay; just as they had been able to do successfully on the previous application when objectors were able to “pull the previous plan to bits.”

The Notice of Planning Decision states correctly that it has not been demonstrated to the Council’s satisfaction that the proposed development is commercially viable and sustainable.

This being an appeal, this Association will want to be able to make representations to the Inspector at the Pre Inquiry Meeting, were the Appellant to invite him to read any material, (such as the unredacted Business Plan or letters said to show offers of paintings to exhibit), which the Appellant had refused to supply to the objecting public prior to the Council hearing and which had likewise not been made available to Planning Committee. Similar representations will need to be made if the Appellant were now to attempt to introduce this withheld material through its witness statements.

Yours sincerely,

 

 

Charles Aldous QC; Chairman.

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CSCA RESPONSE TO NATIONAL GRID’S CONNECTION OPTIONS REPORT.

The Colne Stour Countryside Association (“The Association”) is an active member of the Amenity Group and gives full support to the responses of other members. Here the Association primarily addresses National Grid’s (“NG”) proposals in so far as they directly affect Area G, the Stour Valley and the siting of the substation.

Before doing so, the Association wishes to register its complaint over NG’s whole approach to the Bramford to Twinstead project. All the alternative corridor options were selected as optimal overhead line routes, based on a premature decision by NG not to underground the whole route. NG did not apparently investigate in any depth an alternative optimal underground route.

Whilst the Association welcomes the initial decision to underground Area G through to Twinstead, it is concerned over the precise line of the route and requires significant changes at both the west and east end.

The Association has persistently complained over the NG’ failure to undertake proper consultation. Four pertinent examples are given here:-

(1) NG has failed to carry out any sufficient local socio economic research, especially into business and tourism, on which to consult and arrive at a properly formed judgment on the areas to underground and, importantly so far as Area G, to fairly assess the damaging effect of any substation  and the associated overhead lines. No real attempt has been made to carry out a required cost-benefit analysis of the environmental effect of overhead lines. This failure is a persistent complaint of both the Amenity Group and Local Councils

(2) NG should have coordinated the consultation on the location of any substation with that of the cable route and undergrounding. Although said to be subject to further consultation, there are very serious objections to the site at Butlers Wood; such that if this were to be subject to a separate planning application, the Association firmly believes it would be rejected. A substation at Butlers Wood of the size which UKPN will eventually need would be a grotesque blight on this highly visible landscape. Had NG consulted on the substation at the same time it would have caused it to look in detail at alternative solutions, including (as Stour Valley Underground have set out in detail) a substation at the existing site at Braintree and a consequential undergrounding of the 132Kv line to Rushly Green. This will not only dispense with the need for any substation at Twinstead, but also lead to the removal of all the 132Kv line from Bramford right through to Castle Hedingham, a very considerable benefit to the area.  It was NGs failure to progress the matter with UKPN with sufficient urgency that prevented it from coordinating consultation on the substation with that on the cable route.

(3)  Despite the size of its membership (over 650 and 22 affiliated parishes), the Association was not invited to be a member of any Thematic Group. The Association is aware, however, of complaint over the way these meetings were conducted. As far as the Association can understand, the Thematic Groups were never consulted on how the relative values and weighting should be ascribed to such matters as effect on landscape and environment, cultural heritage and biodiversity if and when they came into conflict. This issue was raised by the Association at Community Forum meetings, requesting details of the approach and methodology being used by the experts and NG to enable them to reach the right decision on say the relative importance of the effect on landscape and scenic views against the protection of an ancient hedgerow or disturbance of buried archaeological artefacts; a matter on which some members of the Thematic Groups would have been particularly experienced to be consulted and contribute. The request was refused; NG saying that it was for it to make its own judgment.


(4)  Throughout section 5 of the COR NG assert that its assessment of the relative importance of the effect on landscape, the environment, biodiversity etc is a matter of judgment. That judgment was always expected to be based on the reports and advice from the two independent firms of experts, Environmental Resources Management and The Environment Partnership. Despite repeated requests, NG declined to provide their reports or advice, without giving any reason. The advice cannot be confidential. If the advice had been made available during the consultation, the Association and others would have (a) been able to see to what extent it was based merely on desk top research and provide the requisite additional material, (b) to see whether in fact NG has relied on or disregarded the advice and, (c) importantly, to point out errors or deficiencies in the advice, which if corrected, should have led to a different conclusion. To give an example with the West Sealing End Compound, currently proposed to be adjacent to pylon 4YLA001, close to Sparrows Farm; the advice will show whether, before rejecting an underground line through to pylon 4YLA005 (as we propose) any detailed work was ever undertaken on a route which we believe could reduce to a minimum the effect on wildlife and which would bring real benefits by the removal of further pylons and the reinstatement of woodland.

What is required.

NG rightly accept that this part of the Stour Valley has very many of the same features and attributes as the existing Dedham Vale AONB and, given the application to extend the AONB, that it is appropriate to treat the Stour Valley as an area of high amenity value.

As such NG is required to do what it reasonably can to protect the area and mitigate the effect on the beauty of the countryside, sites, buildings etc there. (Schedule 9 of the Electricity Act 1989.)

 Despite this, NG is proposing to install both the east and west Sealing End Compounds in unsuitable locations. The Association fully supports the position taken by Stour Valley Underground (SVU), which has taken the lead on this issue.

At the west end, the Sealing End Compound and associated tower should not be at pylon 4LYA001. The location is an environmentally and ecologically sensitive area close to Sparrows Farm and Loshes Meadow Nature Reserve. We do not repeat here the list of important features set out by SVU which make the installation of a large Sealing End Compound and tower there wholly unsuitable.

Rather, the underground route should be taken south to connect at pylon 4YLA005, a site much less visible, with better unprotected road access and with the benefit of then enabling 4 further pylons to be removed. Again we do not repeat the detailed environmental case made out by SVU for this alteration, which we fully endorse.

Likewise it is wrong to site the eastern Sealing End Compound and tower on the high ground at Dorking Tye, at a point which will be highly visible from within the Stour Valley. It is the views from within the Valley that are all important. The COR wrongly asserts that although visible, the presence of the existing overhead lines and the nearby Assington Masts means that the cumulative effect of a Sealing End Compound there will have minimal effect. Quite the reverse; all reasonable steps should be taken to progressively remove the environmental eyesore on the skyline and protect the views from many parts of the valley. The sealing end compound should be moved to a point further east out of view from the Stour Valley. In order to protect the views westwards from the Polstead end of the existing AONB, the sensible solution must be to underground the whole of Area F.

The Association gives its full support to the need for further undergrounding, including the picturesque and culturally important Brett Valley and the area around Hintlesham, with its grade 1 listed Hintlesham Hall and SSI protected woodland.


Charles Aldous (Chairman).                                                                               27th July 2012.  

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CSCA SUBMISSION TO COLCHESTER BOROUGH COUNCIL

Mr Vincent Pearce,
Development Services Manager,
Colchester Borough Council,
Rowan House,
33 Sheepen Road,
Colchester C03 3WG.                                                       26TH January 2013.
 
 
Dear Mr Pearce,
 
Application No:120953 Stour Valley Visitor Centre at Horkesley Park.
 
We write to express our dismay on reading that the Planning Officers are minded to recommend permission for this proposal, when this would:-
 
Cause very real damage to the AONB; 
 
Be completely unsustainable (made clear by CBC’s experts); 
 
Be commercially unviable, (estimated by Britton McGrath Associates to make an annual net loss of £1,7999,000); 
 
Contravene both the NPPF and all relevant Colchester Borough’s planning policies;
 
 Be in conflict with the Borough’s own planning Policy Advice of 4.10.13; and 
 
Not comply with the AONB Management Plan for the Dedham Vale, which the Borough is committed to. 
 
 
Underlying the Planning Officers preliminary statement appears to be a profound lack of appreciation of the importance of the Dedham Vale, its uniqueness and why this has to be protected. 
 
As the Countryside Commission report on the Dedham Vale Landscape said:
 
 “The AONB…. embraces some of the finest unspoilt countryside. Of all the AONBs, it is a lowland landscape most held in the nation’s mind as the English rural idyll…. In a world where natural and cultural heritage are being lost at an unprecedented rate, remaining areas where the rural idyll and peoples pastoral roots can still be discovered are profoundly important” “
 
Conserving the special landscape of Dedham Vale in the future will involve many people and organisations-ideally working to a common goal through an agreed management plan. It will involve …..the effectiveness of planning authorities in controlling unsuitable development, and, no doubt, the outspokenness of local communities and others, who care about Dedham Vale, to resist harmful change… The essence of the Dedham Vale AONB landscape lies in its unspoilt traditional character. This will remain so provided it is continually managed with vigilance, sensitivity and care.”
 
What was stated in the Countryside Commission Report in 1997 is even truer today. Due in large part to careful management by the Dedham Vale AONB & Stour Valley Project, this description of the Vale has been preserved for the public to freely enjoy. How perceptive the requirement for local communities, who care about the Vale, to be outspoken in resisting harmful change and ensuring that the Planning Authorities adhere to planning policy.
 
It is for this very reason that the National Planning Policy Framework states that Areas of Outstanding Natural Beauty must have the highest status of protection, and why the Borough has adopted specific policies to protect the Vale and prevent development such as this. 
 
We have set out below the main planning provisions governing this application in order to emphasise why permission has to be refused. 
 
Paragraph S115 of the NPPF states that great weight should be given to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection. Para S116 states that planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest. 
 
There are no exceptional circumstances. The reports commissioned by the Borough refer to numerous planning policies contravened by this application.
 
 Fundamental to the NPPF is the need for development to be sustainable. This proposal is not sustainable, as Vectos make abundantly clear.  In its report to Council on compliance with transportation planning policy, Vectos state in unqualified terms that “the proposed development does not support the aims of National or Local Policy.” Horkesley Park is in an unsustainable location and, with over 80% of expected visitors arriving by car, does not comply with either national or local transport policy (particularly TA1 and DP10 and 19). TA1 states that developments (such as this) which are car dependent or promote unsustainable travel behaviour will not be supported.
 
The proposal is likewise commercially unviable. Britton McGrath’s report concludes that visitor numbers are only likely to be between 90-130,000, (less than 50% of number claimed), which “inject a fatal flaw into the foundations of the Business Plan;” It describes the forecast turnover as either ambitious or extremely ambitious, predicting an annual loss of  £1.799m, and stating: “Essentially the assumptions for many of the key foundations of the Business Plan appear to be fundamentally flawed resulting in an overwhelming conclusion that this is a business which would quickly become insolvent, resulting in any possible wider benefits to the community being lost.” 
 
Britton McGrath was pressed twice by the Applicants to re-examine the visitor figures and consider whether Horseley Park might, along with other local attractions, bring in visitors from further afield. Yet, in their first addendum they state that “even visitor numbers of 100-130000 would be ambitious” The matters addressed in their second addendum resulted in their again stating that this “all strengthens our original opinion that visitor numbers are unlikely to exceed 100-130,000.” 
 
Stour Valley Action Group has persistently maintained that the proposal is unviable. Britton McGrath, whilst stating that it may not entirely agree with the absolute numbers detailed in the SVAG report, confirms that it is clear that they have identified the fundamental issues with the project; in that it overstates visitor numbers; overstates entry fees; overstates spend per head; overstates the margins on food, beverage and merchandise; and overstates the likely job numbers. Tellingly Britton McGrath says “We cannot disagree with the principles of this conclusion.”
 
 The Borough’s Planning Policy Department points out that even with the most positive interpretation of Britton McGrath’s estimates, the business as currently proposed would be unviable and that this is “a very important material consideration given the scale and sensitive location of the development proposed.” The Policy Department points out that, not only would the claimed benefits (including jobs) not be delivered, but that, if unviable, there would be a serious risk that it would result in a change in the nature of attractions to include business diversification and further travel intensive use; stating that “this would lead to greater harm in sustainability terms and would further conflict with adopted planning policy.”. 
 
Many objectors fear that, if permission were given, the Applicants would be compelled to include further commercial activities and retail outlets to make it profitable. It is noteworthy that Vectos observe that the proposed level of parking is close to the level of car parking associated with food retail (3.3.21).
 
The Policy Department further refers to the fact that the previous application was refused because the Council was not convinced that the project was viable and hence able to produce the claimed economic benefits. Precisely the same factors arise again. Consistency in applying planning policy is fundamental. It would be perverse if the Council were now to be advised to reach a different decision. 
 
Coming to the Borough’s own planning policies, the Policy Department makes clear that full weight must be given to all the main Policies in the Borough’s Core Strategy (2008) and the Development Plan Policies (adopted 2010), whether or not the proposal is regionally significant (3.1.4).  
 
Core Policy SDI provides the overarching spatial policy for the Borough and ensures that new development is located in sustainable locations to minimise the need to travel and to avoid negative environmental impacts. The Policy Department says unequivocally that the proposal fails to accord with SD1.
 
Access and travel policy TA1 provides that developments that are car-dependent or promote unsustainable travel behaviour will not be supported. The Policy Department again states that the proposal clearly fails to meet this policy.
 
Core Policy ENVI states that developments that have an adverse impact on the Dedham Vale Area of Outstanding Natural Beauty will not be supported.
 
Whatever commercial benefits it might be hoped could be brought to the Borough, (none if not viable), this policy alone requires the application to be refused if it will have an adverse impact on the AONB. We refer above to the unique features of the Dedham Vale. Charles Clover, Chairman of the Dedham Vale Society, has succinctly set out in his letter of 21st January 2013 how this proposal would increase noise, light, traffic and visitor pressure to an unacceptable degree. The independent body, the Dedham Vale AONB & Stour Valley Project, is best equipped to answer this and believes that it will have an adverse impact. The Policy Statement says the proposal is considered to have “an unacceptable impact on a sensitive rural area……The scale of the attraction, the mix of uses including many intensive main town centre uses, combined with the unsustainable location in a sensitive area on the edge of the AONB, results in greater impact in terms of unsuitable travel as well as potential harm to the AONB. (5.6, 5.7). The Statement says that the proposal does not appear to accord with this policy (3.1.50).
 
Nothing could be clearer.
 
Core Policy ENV2 provides that Outside village boundaries, the Council will favourably consider small scale rural business, leisure and tourism schemes that are appropriate to local employment needs, minimise negative environmental impacts and harmonise with the local character and surrounding natural environment.
 
Similar restrictions are imposed by Core Strategy Policy CE1 and Development Policy DP10. The project is not small scale. The Policy Department is again explicit in saying that the proposal does not comply, as does the Nathaniel Lichfield report.
 
Policy DP 22 states that development in or near to the Dedham Vale Area of Outstanding Natural Beauty will only be supported that:
(1) Makes a positive contribution to the special landscape character and qualities of the AONB;
(2) Does not adversely affect the character, quality views and distinctiveness of the AONB or threaten public enjoyment; and
(3) Supports the wider environment, social and economic objectives as set out in the Dedham Vale AONB & Stour Valley Management Plan.
 
The Policy Department report is unambiguous. Paragraph 3.1.88 records that the scale of the proposed attraction and its location in relation to the surrounding area and AONB raise concerns over its impact on the tranquillity of the existing AONB. The proposal is stated to attract 316,250 visitors a year, the majority of which will travel by car. This increases the risk of dispersal tourism including to hotspots in the AONB which on some occasions could not cope with more cars.
 
Paragraph 3.1.89 says that the proposal, therefore may not comply with the criteria to make a positive contribution to the AONB and to avoid adverse effects on its character. It would also appear to conflict with many of the objectives of the Dedham Vale AONB& Stour Valley Management Plan.
 
This is again confirmed by the Dedham Vale AONB & Stour Valley Project.
 
The Planning Officers statement that they would be minded to support the application, if evidence of regional status could be produced, cannot be justified. There is no support for this approach in the Planning Policy Department’s Statement, nor in the Borough’s applicable planning policies. Nevertheless, it caused Britton McGrath to revisit the predicted visitor numbers. 
 
Nathaniel Lichfield state in their report that in their view none of the proposed elements at Horkesley Park, in isolation or combined as a whole, have sufficient draw to suggest it will be a tourist attraction of regional significance. (3.32) 
 
Although, contrary to Nathaniel Lichfield, Britton McGrath conclude that, if viable, the project could have regional appeal, they state “we stand by the analysis presented in the previous document with regard to penetration rates.” 
 
In other words, all the independent evidence shows the scheme to be unviable to a very significant extent and therefore unlikely to produce any of the claimed benefits; the very reason for the Council rejecting the previous application (regional or otherwise). 
 
However, the latest report from Britton McGrath throws up further concerns with the proposal. It identifies as two of the key drivers of the scheme:-
 
The Chinese Garden.
The Constable Experience. 
 
A Chinese garden attraction within the AONB is contrary to everything for which the Dedham Vale was granted protected status, and does not comply with DP 22. Such an attraction should be in a sustainable location closer to the Town Centre. As for the so called Constable Experience, if there is need for such an exhibition and gallery, there is no special reason why it needs to be located at Horkesley Park. The views are not unique to Horkesley Park. Rather than fence off the area as a private fee paying attraction, the Vale should continue to be managed so successfully by the Dedham Vale AONB & Stour Valley Project as an area freely available to all to enjoy. Constable had no particular connection with Horkesley Park. There is no realistic prospect of the Applicants purchasing any worthwhile original paintings or persuading owners to lend them for display. 
 
We have set out the policies and evidence at some length to show that, if planning policy is consistently applied (as it must be), it would be improper for the Planning Officers to recommend acceptance.
 
Yours sincerely,
 
 
 
Charles Aldous, Chairman.
 

CSCA RESPONSE TO COLCHESTER BOROUGH COUNCIL

Re: Application No: 120965           

                                     Stour Valley Visitor Centre at Horkesley Park.

The Colne Stour Countryside Association objects to the above application.

Despite the changes to the scheme which was overwhelmingly rejected in July 2011, it still has many of the same objectionable features. The Dedham Vale Area of Outstanding Natural Beauty (AONB) must be protected from this sort of commercial exploitation. The Vale is already well served with many open footpaths and country lanes for the public to access and enjoy. An entertainment venue said to attract 316,000 visitors year on year (arriving mostly by car), and to generate the sort of revenue the Applicants presumably require, will cause serious harm to the character and tranquillity of the AONB. In so far as there is a need for any of the attractions (see further below), there is no justifiable reason for their being here in the AONB. This is not a site which has been identified for development, let alone a major tourist attraction, in the Local Development Framework.

The proposals conflict with both the National Planning Policy Framework and the Core Strategy and Development Policies of Colchester Borough Council’s current Local Development Framework. In so far as relevant, they likewise conflict with the East of England Plan. There are no exceptional circumstances here.

National Planning Policy Framework:

Paragraph 109 states that the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes.

Paragraph 115 states that great weight should be given by [Local planning authorities] to conserving landscape and scenic beauty in Areas of Outstanding Natural Beauty, which have the highest status of protection.

These proposals do not enhance the AONB.

Paragraph 116 states that Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

A development which is claimed to attract 316,000 visitors per annum and doubtless cost a very considerable amount of money to build and run is clearly a major development. As stated, there are no exceptional circumstances for having such a development within the AONB; nor has it been shown (particularly given the level of objection from such as the Suffolk Preservation Society, the Dedham Vale Society and at least four local Parish Councils) that there is any overwhelming public interest for it.


Importantly, the National Planning Policy Framework states that applications for planning permission which conflict with an up to date Local Plan (as these do) should ordinarily be refused.

 

Local Plan; Colchester Borough Council’s Core Development Framework:

Core Strategy

ENV1: states that developments that have an adverse impact on the Dedham Vale Area of Outstanding Natural Beauty will not be supported.

ENV2 is against large scale rural development (which this undoubtedly is) outside village boundaries.

The development is both large scale and will have an adverse effect on the AONB.

Development Policies

DP 22 states that development will only be supported in or near to the Dedham Vale Area of Outstanding Natural Beauty (AONB) that:

(i) makes a positive contribution to the special landscape character and qualities of the AONB;
(ii) Does not adversely affect the character, quality views and distinctiveness of the AONB or threaten public enjoyment of these areas, including by increased vehicle movement; and,
(iii) Supports the wider environmental, social and economic objectives as set out in the Dedham Vale AONB & Stour Valley Management Plan.

Again, as explained below, these proposals make no positive contribution to the landscape character and qualities of the AONB; will adversely affect its character and distinctiveness and, subject to the comments of the Project, do not support the Management Plan.

The Applicants attempt to get round this by claiming that it is a regional significant scheme governed by the East of England Plan, which should have primacy. The scheme is not a regionally significant scheme. Colchester Borough Council’s independent experts concluded that not even the much larger former scheme was. In any event, the East of England Plan (which is soon to be abolished) states that the Dedham Vale AONB should be afforded the highest level of protection.

No need; no exceptional circumstances.

Many of the main elements of the scheme are already available elsewhere in the locality, including Flatford Mill, the Museum of East Anglian Life, Easton Farm Park, the Suffolk Punch Centre at Hollesley Bay, Jimmies Farm and Kentwell Hall. Culturally, Constable had little or no connection with Great Horkesley. There is Gainsborough House and the Sir Alfred Munnings Museum at Dedham. Christchurch Mansion, Ipswich, already claims the most Constable paintings outside London. A celebration of the English Countryside is already catered for and Suffolk Punches are on display at a number of these other centres, including at the Suffolk Punch Trust at Hollesley Bay. There is no reason why the Suffolk Punch attraction and breeding centre needs to be at Great Horkesley, other than the mere fact that the Applicants happen to already own land there.

There is already very good public access to the Vale. The Dedham Vale AONB Project manages the AONB successfully ensuring that its many footpaths, bridleways and lanes are maintained to enable the public to enjoy the Vale, whilst at the same time protecting its rural character and tranquillity. Excellent work is already being done by the Project to increase access and recreational activities there.

Effect on the AONB. 

The AONB is one of Colchester’s most precious heritage assets. Its distinctiveness is the open landscape, the way it continues to be farmed, its timeless tranquillity, and the many footpaths and uncongested country lanes. All must all be preserved for future generations to enjoy. Commercial exploitation of the Vale must be resisted. Areas such as this will become increasingly rare in 50 to 100 years. The presence of over 316,000 visitors each year, arriving mostly by car, many using the protected lanes, will inevitably have a detrimental effect on the environment. The scheme makes no positive contribution to the special landscape character of the AONB.

It is likely that the visitor numbers are significantly overstated, in which case revenue from retail activities will have to significantly increase to make the scheme viable. Despite this being a resubmitted application, the public are now denied access to the Applicant’s Business Plan. It is now being said that the whole Plan is confidential even though such a Plan was provided on the first application and presumably not regarded as confidential. It is difficult to see how the whole Plan can be truly confidential, particularly when the application requires the public to be able to comment on such matters as the schemes viability, the required retail spend for it to be sustainable and the consequential likelihood of increasing retail activities. The Tourism Report contains an unrealistic claimed potential market size of 30 million extending from London to North Norfolk (i.e. persons within 2 hours drive time) and an assumed penetration rate of 1.04, without any regard to alternative attractions nearer to home. The Report curiously relies as a comparator on a garden attraction in Vancouver Island, Canada. Where other farm and garden sites have been looked at in other parts of the UK, little or no attempt has been made to identify which attractions draw visitors. In many cases they include such things as adventure play areas, amusement arcades, fair rides, tractor and train rides and such like, wholly unsuitable for an AONB.


Contrary to any claim to be open and transparent, the Applicants have chosen to deny the public access to the Business Plan, which would enable objectors to ascertain (as before) what revenue per capita is required to make the scheme viable, how this is made up or what is the lowest number of visitors per year below which the scheme fails. If, as suspected, the scheme is not sustainable it will inevitably lead to ever increasing commercial activity.

Traffic.  

Although Essex Highways Authority has not objected, its concerns are mainly with the major roads, A12 and A134. Even though projected numbers have decreased in the revised scheme, there will still be an unacceptable increase in cars going to or from the site through the narrow lanes from West Bergholt, Nayland and Higham. It is difficult to see how a proposal can be said to be sustainable which is intended to attract over 316,000 visitors each year, mostly by car, from as far afield as London and North Norfolk, and to a rural location never designated as a development site.

Greenhouse site.

The greenhouse site has been allowed by the owners to decline. It is understood that in the past there were others prepared to take it on for horticulture. There is no reason why it should not be restored to the use for which planning permission was granted or knocked down and put to agricultural use.

In short, these proposals are for nothing less than a fenced off commercial theme park. Planning policy does not permit the siting of such a large scale tourist attraction on a site which is over 90% within the AONB.


Charles Aldous (Chairman).    24 July 2012.

 

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STOUR VALLEY VISITOR CENTRE AT HORKESLEY PARK.

Application No: 120965.

The latest application by the Buntings for Horkesley Park has now been published and can be seen on the Council’s website at: www.colchester.gov.uk. As I understand it, the application will be decided by the Planning Committee in October, after receiving the planning officer’s report. However, there is only to be a 42 day public consultation period from 15th June. This means that your letters or e-mails must be sent in by 26th July. Otherwise you will have no opportunity to have your views taken into account.

Your letters or e-mails, quoting the title and application number should be sent to:-

         Colchester Borough Council, Environment and Protective Services,
(Attn. Sue Jackson), PO Box 889, Rowan House, Sheepen Road, Colchester CO3 3WG.

Or e-mail to:  planning.services@colchester.gov.uk.

Please do not assume that the application is so similar to the previous one that it is bound to be rejected on the same grounds without any need for further comment from you. Your letters should set out the important issues which concern you, expressed in your own words.

There have been substantial changes in the design. There will be no buildings within the AONB. The floor area of the new buildings are 30% less, with a claimed 86% reduction in retail floor space and 56% less café area. As a consequence the estimated visitor numbers have reduced from 483,000 to 316,000; a figure you may still think unacceptably large for such a sensitive site.

Those of you interested in examining the voluminous application documents will see that the Application quotes numerous planning provisions and policy statements. It may suffice for the present for you to be aware that:

 ENV1 of Colchester Borough Council’s current Local Development Framework (LDF) states that developments that have an adverse impact on the Dedham Vale AONB will not be supported.

And that DP22 (LDF) states that Development will only be supported in or near to the Dedham Vale AONB that (i)makes a positive contribution to the special landscape character and qualities of the AONB; (ii)does not adversely affect the character, quality views and distinctiveness of the AONB or threaten public enjoyment--- including by increased vehicle movements.

The new National Planning Policy Framework (NPPF), which presumes in favour of sustainable development, states that proposed development that conflicts with an up-to-date Local Development Plan (as this is) should be refused unless other material considerations indicate otherwise. Section 11 goes on to state that planning permission should be refused for major developments in AONBs except in exceptional circumstances. There are none here. You may want to say that large scale developments, such as this, should not be permitted so close to one of the most important AONBs.

The Buntings attempt to get round the effect of Colchester’s Local Development Plan, by asserting that it is a Regional Development still governed by the East of England Plan (EEP). This is disputable, nevertheless Policy ENV2 of the EEP states that the Dedham Vale AONB should be afforded the highest level of protection. 

If you consider that the application will have an adverse impact on the AONB and/or is not needed, do please write in. Every letter counts.

Below is a short summary of the new proposals, with a critique of some of the important issues raised:-

Great emphasis is being made that all of the new buildings are to be on the site of the existing greenhouses and therefore outside the AONB, that the Visitor Centre is not only compatible with the AONB but would in fact enhance it and that, by opening up the parkland, there will be greater public access to the AONB itself. The existing greenhouses site will have new buildings covering 8950 sq m, to include a Suffolk Punch Breeding Centre, Indoor Display Ring, areas for “field-to fork production renewable energy centre, demonstration nursery and gardens, visitor shop, café etc.

The attractions are said to include, a Country Park for recreation, Chantry Art Gallery, creative design workshops, Chinese Garden and tea pavilion, indoor covered display ring, the Suffolk Punch breeding centre, working horses, animal encounter area, farm animal rare breeds, Stour Valley walkway and exhibitions, nature watch exhibits, active learning area, renewable energy centre, farming through the ages exhibition, cooks school and demonstration area, field-to-fork experience, creative design workshops and demonstration nursery and gardens. There will also be visitor centre, shop, eating and refreshment areas.

The whole area will be gated, with entrance fees of £14.95 for adults and £10.45 for children, with slightly reduced OAP, family and group rates.

You may think that this has been skilfully put together to maximise its planning appeal. It is claimed that this will attract 310,000 day visitors and 6,250 daytime special event visitors, employing 106.5 (full time equivalent) people on site. The centre is to be open every day except Christmas Day for an average of 8 hours per day.

But this is not intended to be a charitable scheme. It is a profit making enterprise for Bunting and Sons.  However they refuse to produce their Business Plan, which has only been disclosed to CBC in confidence. This is contrary to the whole idea of fairness and transparency.

Visitor numbers:

You may think that the claimed visitor numbers years on year are significantly overstated. The Tourism Evaluation Report asserts a staggering potential market size of 30 million (i.e. persons within 2 hrs drive time) and assumes a penetration rate of 1.04, without any apparent regard to alternative attractions nearer to home. Of this claimed figure of 30 million, over ¾ are said to live between 1 and 2 hours drive away, covering an enormous area from North Norfolk to central London.

The report even, bizarrely, relies on a garden attraction in Vancouver Island, Canada as a comparator! Where other farm and garden sites have been looked at in other parts of the UK, little or no attempt has been made to identify which attractions draw the visitors. In many cases they include such things as adventure play areas, amusement arcades, fair rides, tractor and train rides and more, which you may think would be wholly unsuitable for an AONB.

Without access to the Business Case, it is impossible to ascertain what revenue per capita is required to make the scheme viable, how this is to be made up or what is the lowest number of visitors per year below which the scheme fails. As with the previous proposals, this information is essential. We should be allowed to test it. If the scheme is not sustainable, it will, if allowed, inevitably lead to yet further applications to extend the retail element and commercial exploitation of the site. As many of us as possible must demand access to the Business Case.

Need:

You may also think that there is little or no need for this there. All the main elements are already available elsewhere. There are existing facilities at Flatford Mill, Gainsborough House Museum, the Museum of East Anglian Life near Stowmarket, Easton Farm Park, Kentwell Hall, the Suffolk Punch Centre at Hollesley Bay, Sir Alfred Munnings Museum, Assington Mill Rural Skills and Craft Centre and much more.

There is no single element which would likely persuade people to drive up to 2 hours from London or North Norfolk.

As for access, the Stour Valley and Dedham Vale AONB Project already manages the AONB successfully ensuring that its many footpaths, bridleways and lanes are maintained to enable the public to enjoy the Vale, whilst at the same time protecting its rural character and tranquillity. Excellent work is already being done by the Project to increase access and recreational activities there.

Traffic:

Although the Essex Highways Authority has entered no objection to date, its concern has been mainly with the major roads A12 and A134, which it assumes will be the routes used. Most visitors will inevitably come by car. Although the projected traffic numbers have significantly decreased in the revised scheme, there will still be a substantial increase in vehicles accessing the site through the narrow country lanes from West Bergholt, Nayland and Higham and Stoke-by-Nayland.

Retail:

Without access to the Business Plan, we cannot know what amount Buntings will need to extract from retail sales and extra events for the scheme to be viable. It is believed that sales will still need to be substantial. No figures have been provided. Although the retail space has been reduced from the previous proposals, there is nothing to stop Buntings using any of the covered areas for other retail events.

Sustainability:

A presumption in favour of sustainable development is now a core principle of the NPPF. As well as the requirement to conserve heritage assets and prefer development on land of lesser environmental value, sustainability also focuses on developments which promote sustainable transport and reduce traffic pollution. It is difficult to see how a proposal can be sustainable which is intended to attract over 300,000 visitors
p.a, mostly by car from as far as London and North Norfolk; and moreover to a rural location which has never been designated as a development site. There is no reason why the site cannot be restored to its previous horticultural or agricultural use.

You may each have your own reasons for objecting, for example the effect on the grade 1 listed church or on the peace and quiet of the Vale. Do not feel restricted in what you write by what I have set out above.

If you want to hear more about the campaign to stop further exploitation of this precious piece of countryside, there will be a meeting convened by Stour Valley Action Group in Little Horkesley Village Hall on the 4th July at 7.00 pm.


Charles Aldous,  28th June 2012.

 

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Pylons Update

You will be aware by now that National Grid have announced its initial proposals for the new 400 Kv line from Bramford to Twinstead. The Connections Option Report can be viewed on line at National Grid’s Bramford to Twinstead site. The Report proposes two underground sections: (i) 4.2 km of the Dedham Vale AONB, from a point west of Heath road, Polstead Heath to Leavenheath, and (ii) 3.8 km across the Stour Valley, from west of Dorking Tye to Pylon 4YLA 001, south of the existing Twinstead Tee. In the process the existing 132 Kv line through to Twinstead will be removed.

Much of the credit for achieving this must go to the enormous amount of time and effort devoted by Stour Valley Underground, and David Holland and Richard Barnes in particular. In short, National Grid was much influenced by the cultural and landscape importance of the Stour Valley; accepting that our area has very many of the same attributes as the Dedham Vale AONB. Undoubtedly the application to have the AONB extended towards Sudbury was a significant factor, for which Robert Erith and the AONB Project deserve much credit.

Although this will be thought to be a considerable achievement, there are still real problems at both ends of the Stour Valley underground route, which we will be pursuing. I will explain these below, but, before doing so, want to point out that, so far, National Grid are refusing to underground any other sections, including the Hintlesham end, with its effect on the grade 1 listed Hintlesham Hall and Hintlesham Woods SSSI and also the Brett Valley. As a member of the collective amenity group, the Colne Stour Countryside Association will be pressing for more undergrounding than is currently being proposed. This will not be to the detriment of the Stour Valley.

Returning to the Stour Valley, at either end of the underground route there will need to be an unsightly Sealing End Compound, with a 50m bulkier pylon and associated equipment to transfer power up to the overhead line. At the Twinstead end, we will be strongly supporting Stour Valley Underground’s proposal to have the Sealing End point moved from pylon 4YLA001 to a more southerly and less conspicuous point at pylon 4YLA005; far less visible and intrusive. Those interested in the detail of this alternative and the considerable benefits this will bring should visit Stour Valley Underground’s website, where it is fully explained with supporting photographs.

If the Stour Valley is to be preserved, as it should be as a potential AONB, the views looking outwards from within the valley must equally be protected. The existing pylons and the proposed Sealing End Compound on the high ground at the eastern end of the underground route will be highly visible, despite National Grid’s assertion that it will seek to screen it as far as possible. We will be pressing here for an extension of the undergrounding and, correspondingly, for the Sealing End Compound to be moved eastwards so as to be out of sight.

The views westwards towards Assington from the proposed underground section of the Dedham Vale AONB will likewise be blighted with a Sealing End Compound, requiring it to be moved west out of sight of the AONB.The sensible solution to accommodate both may be for the whole of the Leavenheath Assington section to be undergrounded. The Association, together with the Dedham Vale Society and other interested organisations, will similarly be pressing for this.

Finally, it must not be overlooked that National Grid’s proposals will require the building of a new sizeable substation in the Twinstead area in order to connect up with the 132 Kv line running west. Stour Valley Underground have come forward with an interesting suggestion that if the existing 132 Kv line were to be laid underground straight from Bramford to the existing Belchamp substation, not only could all of the intervening132 Kv pylons be removed, including those between Twinstead and the Belchamp substation, but there would then be no need for another substation to be built at Twinstead. These proposals are at an early stage, but it should be noted that to bury a 132 Kv line does not apparently require more than a 0.5 wide x 1.0 m deep trench and at a cost comparable to the substation.

You will appreciate from the above that, although the proposal to underground the Stour Valley is great news, there is still much more to be done in trying to force National Grid to extend its undergrounding, both through the planning procedure and politically.

National Grid are inviting feedback on the Report by Friday 27th July; either by e-mail to: Bramford-twinstead@uk.ngrid.com; via the website at: www.nationalgrid.com/bramford-twinstead. or in writing to: Freepost NATIONAL GRID CONNECTIONS.

The positioning of the Sealing End Compounds is important, as is any solution which could avoid the substation. Do please respond.

Charles Aldous. 25th June 2012.
 

 

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 CONSULTATION ON THE GOVERNMENT’S NATIONAL POLICY FRAMEWORK (NPPF).

Members will be aware of the likely destructive effect of the Coalition Government’s proposals for a new National Planning Policy Framework. Much has already been said about it in the media. The National Trust, CPRE and many other respected organisations concerned with protected our rural landscape are strongly against these proposals. We have until 17th October to register our concerns and, importantly, to ask our local Councillors to write in on our behalf. These proposals make radical changes to planning policy. The Government, mistakenly, sees that the only way to achieve economic growth, and the need to build a vast number of new houses, is to scrap the tried and tested Planning Policy Statements (PPS) and Guidance. Instead, whilst greater control is being passed down to Local Authorities, the proposed framework for each Authority is in future to presume in favour of any sustainable development, irrespective of whether this is on green field sites. There is no clear understanding of what is and is not “sustainable.” Although there will be protection for designated Areas of Outstanding Natural Beauty, the less protected, but still sensitive, areas of our countryside will now be at serious risk.

The existing planning framework, evolved over many years experience, is there to strike the right balance between the demands for new housing, and the interests of developers on the one hand, and the need to protect our countryside, on the other. Under the New Framework there will no longer be a presumption in favour of building first on available brown field sites, nor of office development in town centres. There are other serious concerns. I see these proposals, unless radically amended, as a real threat to the picturesque villages and countryside in this lovely part of North East Essex. Development must continue to be strictly controlled on green field sites.

The draft NPPF can be found on: http://www.communities.gov.uk/publications/planningandbuilding/draftframework. Those interested can access the views of both CPRE and the National Trust through their respective web sites: www.cpre.org.uk, and www.nationaltrust.org.uk. Those who wish to write in, or ask their Councillors to, should do so before 17.10.2011, sending responses to Alan C Scott, Department for Communities and Local Government-National Planning Policy Framework, Zone 1/H6, Eland House, Bressenden Place, London SW1E 5DU; or by e-mail to: planningframework@communities.gsi.gov.uk.

Charles Aldous. 8.11.2011.

 

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The Localism Bill

The main speaker at the CPRE lecture on Thursday 10 February was Greg Clark, the Minister for Decentralisation with ultimate responsibility for the Localism Bill. The panel comprised CPRE’s Chief Executive Shaun Spiers, Professor Patsy Healey of Newcastle University, a planning expert, and Debbie Tripley of the Environmental Law Foundation.

Although there are positives in the Bill, I fear the Government has got the substance of this crucial bit of legislation utterly wrong, and that we are sleepwalking towards the environmental catastrophe of a development free for all.

The Minister reinforced the Government’s pro growth and development stance. They want to “unlock the right kind of development” and “require development to be sustainable”: these are words which seem to invite greenfield development.

The Government believes that if a Neighbourhood Plan is agreed by a community, there need not be a third party right of appeal. The Minister gave assurances that financial support and advice will be available to assist local groups making Neighbourhood Plans, which must not “frustrate a pressing need for homes.”

Patsy Healey responded that checks and balances are required to stop “the big barons running amok.” We need discussion and debate rather than exhortation. Developers must buy into collaborative planning.

Debbie Tripley responded that Community Plans can be ignored by local authorities and that Community Groups comprising a minimum of three people, only two of which need to live in the area, can be hijacked by developer.

Shaun Spiers highlighted CPRE’s three main areas of concern:

1 The framework of the new system

Local Enterprise Partnerships with no regard for environmental protection.

Development incentives which reward the numbers of houses built.

2 How can development possibly be “sustainable” if:

The planning system is perceived as an impediment to economic growth?

Economic objectives override social and environmental objectives?

3 There must be a third party right of appeal in Neighbourhood Plans. Rebalancing the planning system to favour development is wrong.

This Bill in its present form will perpetuate the importance accorded to the pursuit of economic growth in planning decisions.  In a country with finite resources of undamaged countryside, and particularly so here in Essex, this can only accelerate environmental degradation with a hugely adverse and unsustainable outcome. 

The Localism Bill has been through two readings and will have gone through the report stage in March. CPRE has serious concerns about the reality of this Bill beneath its headline claims of a new dawn of local emancipation. It is now time to make our views known more forcefully.

 What have CPREssex done to date?

1 We organised Westminster Essex MPs’ planning briefings in July 2010 and March 2011 with participants from CPRE’s National Office and CPREssex.

2 We wrote to Essex MPs about our specific areas of concern last October, and sent them CPRE’s Charter for Planning Reform last November.

3 In our individual capacities, CPREssex members have written to our own MPs expressing our concerns.

 Please:

* Publicise the environmental threat of the Localism Bill, for example by circulating this email.

* Commit as much of your time as you can spare towards this crucial campaign.

* Ask people to join CPRE and to join us in our campaigning.

Thank you

                                      Tom Holme 

 

 

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Localism Bill threatens massive new house building on greenfield farmland?

Under the previous Government, regional house building quotas were imposed via the East of England Regional Assembly. There was some environmental consultation, but the main driver was the perceived requirement for continuing economic growth.

The East of England Regional Assembly was abolished and replaced by the East of England Development Agency. The new Government promptly abolished the East of England Development Agency.

A reformed planning system will be contained in the forthcoming Decentralisation and Localism Bill. The stated aim of the reforms is to shift power away from central government and put local communities in charge of planning.

Whilst the decision to abolish imposed Government housing quotas is welcome, there are growing fears that the current absence of clear replacement planning policies has created a vacuum which will result in unconstrained greenfield housing development at the expense of the regeneration of our towns and cities.

The Campaign to Protect Rural England, CPRE, exists to promote the beauty, diversity and tranquillity of the countryside by the sustainable use of land and other resources.  CPRE and its Essex county branch CPREssex are urging the Government to make protection and enhancement of the natural environment a key objective of the forthcoming Bill, and in particular those elements of the Bill which focus on planning reform.

A robust planning system has done much in recent years to protect greenfield land throughout the county of Essex from unnecessary and inappropriate development. CPREssex is asking the Government for a planning system which delivers long term gains, rather than a short term deregulation of house building to the detriment of the Essex countryside. 

We cannot see how the Coalition Government hopes that the Decentralisation and Localism Bill will fulfil its pledge to be the 'greenest government ever’. There are certain specific likely environmental dangers which CPRE have identified and which we are campaigning to be taken account of.

A “Community Right to Build” envisages housing development without planning permission where it is favoured by the majority in a community.  We are calling for this to be regulated to ensure that local communities are not unfairly pressurised by developers.

 We are concerned that the payment of incentives for building new housing through local plans is monitored and safeguarded, to ensure transparent disclosure and environmental protection.

The proposed Local Enterprise Partnerships (LEPs) entail alliances between councils and business interests. There seems to be no provision for environmental protection in LEPs: we are seeking to rectify this.

CPREssex  recognises the need for housing, but we advocate a genuinely sustainable approach to its provision, rather than an ill considered dash for development with potentially catastrophic environmental consequences for the county of Essex.

Nationally and locally, we are doing our utmost to engage with our elected representatives about our concerns in the process of consultation and debate about the forthcoming Bill.

Tom Holme Chairman CPREssex

 

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