Objection – 20240623 – 04 — Due to Public Health Concerns.pdf



Material Considerations Used in the Objection, Grouped by Main Categories


  • Mental Health and Well-being: Stress and anxiety from continuous construction.
  • Noise Pollution: Health risks and cognitive impairment from prolonged noise.
  • Community Disruption: Social isolation and disrupted access to services.
  • Air Quality and Respiratory Health: Construction dust and emissions impacting vulnerable populations.
  • Lack of Transparency and Consultation: Undermined public trust due to inadequate consultation.

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Objection – 20240623 – 06 — Based on Deliverability and Sustainability Concerns.pdf



Material Considerations Used in the Objection, Grouped by Main Categories


  • Ecological Impact and Sustainability: Concerns over outdated data and insufficient sustainability measures.
  • Environmental and Flood Risks: Historical flooding issues inadequately addressed.
  • Infrastructure and Service Strain: Inaccurate housing supply figures and repurposed NHS comments.
  • Public Opinion and Community Impact: Significant community opposition and manipulated feedback.
  • Archaeological Concerns: Insufficient mitigation for potential archaeological findings.

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Objection – 20240623 – 05 — Based on the Ecological Impact Assessment.pdf



Material Considerations Used in the Objection, Grouped by Main Categories


  • Significant Biodiversity Net Loss: High loss of biodiversity contrary to planning policies.
  • Insufficient Mitigation and Compensation Measures: Lack of detailed, enforceable plans.
  • Potential Adverse Effects on Local Wildlife: Risks to protected species with inadequate mitigation.
  • Cumulative Impact with Previous Developments: Additional habitat loss and urbanisation.
  • Impact on Non-Statutory Designated Sites: Risks to nearby nature conservation sites.
  • Inadequate Consideration of In-Combination Effects: Lack of comprehensive assessment of cumulative impacts.

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Objection – 20240623 – 03 — Due to Traffic and Access, Flood Risk and Community Impact Concerns.pdf



Material Considerations Used in the Objection, Grouped by Main Categories


  • Outdated Traffic Data: Reliance on outdated surveys.
  • Survey Methods: Scrutiny of survey methods for accuracy.
  • Feasibility of Mitigation Measures: Evaluation of proposed road improvements.
  • Cumulative Impact: Assessment of cumulative traffic impacts.
  • Existing Flooding Problems: Ongoing flooding issues at Beechlands Road and Redhill junction.
  • Exacerbation of Flooding Issues: Concerns over increased flooding from new development.
  • Lack of Detailed Plans: Insufficient flood risk mitigation details.
  • Impact on Local Infrastructure: Strain on local services and amenities.
  • Safety and Accessibility: Risks from flooding affecting safety and access.

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Objection – 20240623 – 02 — Due to Inadequate Community Involvement and Lack of Trust.pdf



Material Considerations Used in the Objection, Grouped by Main Categories


  • Limited and Biased Consultation Reach: Insufficient and potentially biased community engagement.
  • Superficial Responses to Concerns: Developer’s inadequate responses to community concerns.
  • Manipulated Feedback: Lack of trust in the consultation practices.
  • Fear of Voicing Opinions: Residents fear repercussions for voicing concerns.

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ECOLOGICAL_IMPACT_ASSESSMENT-1335968.pdf


Key Points:

Surveys conducted between 2018 and 2024, including habitat and species-specific surveys. Identified 25 Important Ecological Features (IEFs), including habitats and species of local and regional importance. Recommendations include habitat protection, creation of wildlife corridors, and mitigation measures for light and noise pollution.

Summary:

The ecological impact assessment highlights the need for careful planning to protect local wildlife. Recommendations focus on minimising disturbance to habitats and implementing strategies to enhance biodiversity.

Weak Points:

  • Some data, including tube tests, are from 2018, raising concerns about their current relevance and accuracy.
  • Potential biases in survey methods and interpretations to favour the developer’s outcomes.
  • Mitigation measures may be optimistic and require thorough verification.

What aspects should be evaluated in relation to this document?

ENVIRONMENTAL IMPACT


Biodiversity and Habitat Preservation:

  • Evaluate how the development affects local biodiversity, including flora and fauna. Assess measures for preserving and enhancing habitats within the site.

Ecological Connectivity:

  • Review the impact on ecological corridors and connectivity between habitats. Ensure that wildlife movement and genetic exchange are not disrupted by the development.

Protected Species and Sites:

  • Identify any protected species and designated conservation areas within or near the development site. Evaluate the measures proposed to mitigate impacts on these protected entities.

Mitigation Measures:

  • Assess the effectiveness of proposed habitat creation and restoration efforts. Ensure that these measures will compensate for any habitat loss or degradation caused by the development.
  • Review the long-term management plans for maintaining and monitoring ecological features. Ensure that there are clear strategies for managing habitats and species over the lifetime of the development.
  • Evaluate the commitment to achieving biodiversity net gain. Ensure that the development will result in a measurable improvement in biodiversity compared to the pre-development baseline.

Monitoring and Reporting:

  • Review the plans for monitoring the ecological impacts of the development over time. Ensure that there are clear indicators and methods for assessing the effectiveness of mitigation measures.
  • Ensure that there are provisions for regular reporting to relevant authorities and stakeholders on the ecological performance of the development.

DESIGN AND APPEARANCE


Integration of Green Infrastructure:

  • Assess how green infrastructure, such as green roofs, walls, and sustainable drainage systems (SuDS), is integrated into the design of the development. Ensure that these features contribute to ecological enhancement.

Landscape Design:

  • Review the landscape design for its contribution to ecological value. Ensure that native species are used, and that landscaping enhances habitat diversity and connectivity.

LOCAL AND NATIONAL PLANNING POLICIES


Local and National Planning Policies:

  • Verify that the ecological impact assessment aligns with relevant local and national planning policies, including those related to biodiversity conservation and environmental protection.

Legislation and Regulations:

  • Ensure compliance with relevant legislation and regulations, such as the Wildlife and Countryside Act and the Habitats Regulations. Review any required licenses and permits for working with protected species and habitats.

RESIDENTIAL AMENITY


Community Engagement:

  • Evaluate the extent of stakeholder and community involvement in the ecological assessment process. Ensure that local knowledge and concerns have been incorporated into the assessment and mitigation plans.
  • Assess opportunities for using the development to promote environmental education and recreation. Ensure that the design includes features that can engage and benefit the local community, such as nature trails and information boards.

Disclaimer


COVERING_LETTER-1335946.pdf


Establishes:

Outline Application Submission: Provides a summary of the outline planning application for up to 70 dwellings, including details about vehicular and pedestrian accesses, public open space, landscaping, and drainage.

Referenced Documents: Lists the documents and plans submitted as part of the application package, including transport assessment, ecological impact assessment, flood risk assessment, and more…

Weak Points:

General Information: The letter primarily provides an overview without detailed justifications or specific data. It refers to other documents for comprehensive details.

Potential for Overlooked Concerns: If the referenced documents do not fully address key concerns, there may be gaps in the application package.

Documents:

The covering letter for the planning application includes a comprehensive list of documents and plans submitted as part of the application package. Here are the documents and plans referenced:

  1. Application Form and Ownership Certificate (Certificate B)
  2. Planning Statement, incorporating:
    • Sustainability Statement
    • Affordable Housing Statement
    • s106 Heads of Terms (Prepared by SLR Consulting)
  3. Design and Access Statement (Prepared by Thrive Architects)
  4. Statement of Community Involvement (Prepared by SLR Consulting)
  5. Housing Land Supply Assessment (Prepared by Pegasus Group)
  6. Transport Assessment, incorporating:
    • Road Safety Audit (Prepared by iTransport)
  7. Framework Travel Plan (Prepared by iTransport)
  8. Flood Risk Assessment (Prepared by The Civil Engineering Practice)
  9. Utilities Statement (Prepared by The Civil Engineering Practice)
  10. Landscape and Visual Appraisal, including:
    • Associated viewpoint photographs
    • Designation plans (Prepared by SLR Consulting)
  11. Ecological Impact Assessment (Prepared by LC Ecological Services)
  12. Biodiversity Net Gain Metric (Prepared by LC Ecological Services)
  13. Arboricultural Impact Assessment and Method Statement (Prepared by Barrell Tree Consultancy)
  14. Tree Protection Plan (Prepared by Barrell Tree Consultancy)
  15. Manual for Managing Trees on Development Sites (By Barrell Tree Consultancy)
  16. Desk-Based Archaeology Assessment (Prepared by SLR Consulting)
  17. Phase 1 Geo-Environmental and Geotechnical Site Assessment (Prepared by Geo-Environmental)
  18. Lighting Plan (Prepared by Nulty Lighting)
  19. Noise Impact Assessment (Prepared by SLR Consulting)
  20. Sustainability Checklist (Prepared by SLR Consulting)
  21. Validation Checklist (Prepared by SLR Consulting)

What aspects should be evaluated in relation to this document?

LOCAL AND NATIONAL PLANNING POLICIES


Verify Compliance:

  • Ensure the covering letter confirms compliance with relevant local and national planning policies. This includes adherence to all relevant legal and regulatory requirements, obtaining necessary permits, and ensuring the development complies with zoning laws and environmental regulations.

Review Alignment with Policy Objectives:

  • Assess how the proposed development aligns with broader planning objectives outlined in local and national policies, including sustainability goals, housing needs, and infrastructure improvements.

INFRASTRUCTURE AND SERVICES


Assess Impact on Infrastructure:

  • Evaluate how the proposed development will impact local infrastructure, including transportation, utilities, and public services. The covering letter should outline any plans to upgrade or expand infrastructure to accommodate the new development.

RESIDENTIAL AMENITY


Review Impact on Residents:

  • Consider how the development will affect existing residents. The covering letter should address potential impacts on noise levels, privacy, and access to amenities. It should also highlight any proposed measures to mitigate negative impacts on residential amenity.

ENVIRONMENTAL IMPACT


Evaluate Environmental Considerations:

  • Assess how the development addresses environmental concerns. The covering letter should mention strategies for minimizing the environmental footprint, such as sustainable building practices, green spaces, and conservation efforts.

DESIGN AND APPEARANCE


Review Architectural and Landscape Design:

  • Examine the proposed architectural and landscape design elements. The covering letter should provide an overview of how the design complements the existing neighborhood and enhances the visual appeal of the area.

PUBLIC OPINION


Assess Community Involvement:

  • Evaluate the extent of community involvement in the planning process. The covering letter should detail any community consultations that have taken place and how feedback from residents has been incorporated into the development plans.

Disclaimer


APPLICATION_FORM_REDACTED-1335944.pdf


Establishes:

Basic Application Information: Provides essential details about the application, including the site location, description of the proposed development (up to 70 dwellings with vehicular and pedestrian accesses, public open space, landscaping, and drainage), and the developer’s details.

Document References: Confirms the submission of various supporting documents, such as the Design and Access Statement, Services Plan, and Flood Risk Assessment.

Residential Units: Specifies the types and numbers of proposed residential units, including market and affordable housing.

Weak Points:

General Information: The application form itself does not provide detailed justifications or assessments but references other documents for comprehensive details.

Potential Gaps in Application Package: If referenced documents do not fully address key concerns, there may be gaps in the application package.

Lack of Immediate Detail: The form defers many specifics to the supporting documents, requiring thorough review of all referenced materials to get a complete understanding of the proposal (over 1k pages).

Material Consideration Explanation:

Local and National Planning Policies: The application form confirms compliance with planning policies, which is crucial for obtaining approval.

Infrastructure and Services: The details about vehicular and pedestrian accesses, public open space, and drainage impact local infrastructure and services, ensuring the development meets community needs.

Residential Amenity: Information about residential units impacts the assessment of the development’s fit within the community, considering factors like housing type, density, and mix.


What aspects should be evaluated in relation to this document?

Local and National Planning Policies


Review the application form to confirm that the development adheres to local and national planning policies. This is crucial for obtaining approval and ensuring the project aligns with broader planning objectives.

Infrastructure and Services


Assess Access and Connectivity: Examine the details about vehicular and pedestrian access to ensure they are sufficient and well-integrated into the existing infrastructure. Consider whether the proposed access points meet safety standards and provide convenient routes for future residents.

Evaluate Public Open Space Provision: Check the plans for public open spaces to ensure they meet community needs and contribute to the quality of life. This includes assessing the size, location, and intended use of these spaces.

Analyse Drainage Plans: Review the drainage plans to understand their impact on local infrastructure. Ensure that the development will not exacerbate existing drainage issues and that it includes sustainable drainage solutions.

Residential Amenity


Evaluate Housing Type and Density: Consider the types of residential units proposed, their density, and how they fit within the existing community. Assess whether the mix of housing types meets local demand and contributes to a balanced community.

Assess Impact on Community Fit: Examine how the proposed residential units integrate with the surrounding area in terms of architectural style, scale, and overall design. Ensure that the development enhances the character of the community and does not create incongruities.


Disclaimer


Objection to Planning Application 27000-005 — 20240621 – 02.pdf


Traffic and Access Concerns: This section reviews the developer’s documents related to traffic and access. It identifies critical weaknesses in the proposed solutions, such as the increased traffic congestion and potential safety hazards due to narrow roads and lack of street lighting.

Parking and Cycle Strategy Plan: This section discusses the insufficiency of proposed parking spaces and the lack of secure cycle storage, which could lead to on-street parking and associated safety issues, and does not promote sustainable transport options.

Walking, Cycling, and Horse-Riding Assessment: This section highlights deficiencies in existing infrastructure, such as narrow footways and lack of street lighting, posing safety risks for pedestrians and cyclists, especially during low-light conditions.

Legacy Recommendations and Historical Context: This section references historical concerns and recommendations for an EIA due to significant impacts on critical junctions. It underscores the need for comprehensive assessments to understand cumulative traffic impacts.




Disclaimer


Objection to Planning Application 27000-005 — 20240621 – 03.pdf


1. Procedural Concerns:

This section addresses the incomplete disclosure of material considerations and the lack of public awareness regarding the application’s consideration under Paragraph 11 of the NPPF. It emphasises the importance of transparency and informed public participation.

2. Impact on Traffic and Access:

This section discusses the increased traffic congestion and potential delays to emergency services due to the proposed development’s access plan leading to Lymington Bottom Road, a primary route to hospitals and other essential services.

3. Potential Procedural Error:

This section points out the potential procedural errors due to the failure to disclose all material considerations and the omission of a comprehensive EIA, which might undermine the integrity of the planning process.

4. Conclusion:

This section concludes that the proposed development does not meet the sustainability criteria required by Paragraph 11 of the NPPF. It urges the council to reject the application unless substantial revisions are made to address the critical concerns comprehensively.




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