Aldborough Hatch Defence Association Redbridge Local Plan 2015-2030: Pre-Submission Draft Strategic Head of Planning & Building Control London Borough of Redbridge FREEPOST RLSR-JACE HSUG Town Hall High Road ILFORD, Essex IG1 1DD 25th September 2016 Dear Sir, Redbridge Local Plan 2015-2030: Pre-Submission Draft Representations from the Aldborough Hatch Defence Association 1. The representations of the Aldborough Hatch Defence Association relate primarily to Section 3 of the Draft Local Plan (Promoting and Managing Growth) and to Policies LP1 and LP1B (Land South of Billet Road opportunity site 99). The representations also relate to paragraphs 2.2 (Table 2), 3.8.3, 3.8.4, 3.8.5, 6.1.6, 6.1.7, 6.1.9, LP 36 (C). 2. It is considered that the Draft Local Plan is not legally compliant and is not ‘sound’. It does not justify the aspirations in draft policies LP1 and LP1B, relying on erroneous evidential documentation or misinterpretation of such and in many areas the Draft Local Plan is not consistent with National and Regional policies. 3. Redbridge has put forward the Outer North East London Strategic Housing Market Assessment, prepared by Opinion Research Services, as justification for removing land south of Billet Road (Willow Farm) from Green Belt designation. It suggests that since the Strategic Housing Land Availability Assessment demonstrates that there are insufficient potential sites to meet the housing needs numbers for Redbridge for the period of the Local Plan, and as referred to in the Outer North East London Strategic Housing Market Assessment report, this demonstrates ‘exceptional circumstances’ to justify removing from Green Belt designation various parcels of land around the Borough, including the LP1B lands. However, it is clear from Section 2 of the Draft Local Plan (the Plan) and, in particular Table 2, that the declared Objective of Redbridge is to deliver up to 18,500 new homes over the plan period (although Policy LP2 refers to 16,845 new homes over the period of the Plan) as opposed to the 31,977 new homes over a similar period referred to in paragraph 6.1.6 of the Plan. (It should be noted that Appendix 1 to the Plan does not list all possible opportunity sites and therefore it creates a false base from which to conclude there is insufficient land to meet the Policy LP2 housing needs.) In addition, given the result of June's EU referendum, and the forthcoming Brexit process, can anyone really predict with any certainty the actual housing need? 4. Whilst the housing and population numbers in Section 1 of the Plan are inconsistent and, in at least one instance, mathematically incorrect, these are the numbers which have been used to guide the new housing target in Objective 1 of Table 2. Thus, the only purpose of the Outer North East London Strategic Housing Market Assessment is to try and justify ‘exceptional circumstances’. 5. The Draft Green Belt Review prepared by Wardell Armstrong January 2016, and which Redbridge is using to justify removing the LP1B lands from Green Belt designation, is flawed in many respects. It suggests that the National Planning Policy Framework is different in its approach to Green Belt issues than was the case in Planning Policy Guidance 2 but case law states that the NPPF made no changes to the guidance in PPG2. 6. The Wardell Armstrong Green Belt Review states that the area of Green Belt land south of Billet Road which they have numbered GB14c no longer meet Green Belt purposes and should be de-designated, although the reviews of 2013 & 2015 recommended that GB14c still fulfilled the Green Belt purpose. A view of an aerial photograph of the area shows the connectivity with other Green Belt land of Fairlop Plain. The housing backing onto the GB14c lands was built prior to 1950. Whilst there have been some changes in the locality (not least the development of Hainault House) the character of the area remains much as it was when it was first designated as Green Belt. We have members who have lived in the locality for well over 80 years and who can attest to this. 7. Transport issues - with the development of land south of Billet Road(GB14c) the Council commissioned A High Level Transport Report for the area from Atkins Ltd (their reference 5141547-02). In January 2016 the impact to the local roads was noted as Hainault Road – Moderate Impact, Billet Road – Moderate to Major Impact and B177 Barley Lane Minor to Moderate Impact. From local knowledge and personal observation, we believe the data used has not taken into account current actual peak flow rates into this road system or the potential developments of the other LB1b sites of King George and Goodmayes Hospitals onto the road system. Tailbacks and queues on these roads and nearby highways (Painters Road, Aldborough Road North and Whalebone Lane) are common throughout the day but especially at peak times and during the school runs. We intend to submit up-to-date data to the Inspector in due course. We believe that as the road system is operating at peak times near to its maximum capacity, trying to add another 1000+ vehicle movements will overload the system. We would add that public transport in the area is poor with only direct access to some bus services which are overloaded at peak hours, rail transport is over 2.5 kilometres away at Goodmayes (Network Rail) or Newbury Park for the Central Line which is outside the recommended CIHT Walk Journey Distance and Time Threshold. We consider that cycling on these local roads to be inherently unsafe. 8. Air quality – As well as the High Level Transport Report a separate Air Quality Report was commissioned from Atkins Ltd (their reference 5141547 – December 2015). It is apparent that no actual air quality readings were taken in the vicinity of the Billet Road, Hainault Road and the A12 junction. The report is based totally on modelling, using data that is generalised. We would have thought that some real data monitoring would have been taken from the Little Heath Special Needs School on Hainault Road to give credibility to this report. 9. Biodiversity- Although not on the Borough register of Sites of Importance for Nature Conservation (SINC) land south of Billet Road (Willow Farm) is still of importance for nature, more so since arable farming ceased. There are a large number of Western European Hedgehogs (Erinaceus europaeus) found on Willow Farm (a bit of background data: nationally 30 million in the 1950s to around 1.5 million now. They are now listed as an endangered species. If the decline continues, we will lose our last hedgehog by 2020. Declared priority conservation species in 2007.) There are several old ponds that historically were noted for Great Crested Newt (Triturus cristatus) a fully protected species in terms of the Wildlife and Countryside Act. Areas of scrub have developed with associated birdlife, such as Lesser Whitethroat (Sylvia curruca) . In the old arable land Skylarks (Alauda arvensis) breed - a bird of conservation concern. Other farmland birds are also found. Though not officially a SINC (by accident or design) it is listed as one of the Boroughs “Green Corridors” and also part of the “All London Green Grid” administered by the London Mayor. Loss of this site to built development would to the detriment of wildlife conservation in Redbridge. 10. Within the Draft Plan Redbridge has designated various areas around the Borough as Investment and Growth Areas (Section 3 of the Plan refers). One of these is referred to as The Crossrail Corridor Investment and Growth Area. As the accompanying plan (Figure 6) clearly demonstrates, far from being a ‘corridor’ Redbridge has stretched the imagination to create something which looks nothing like a ‘corridor’. It is suggested that this Crossrail Corridor Investment and Growth Area has been drawn in this particular manner in a further attempt to justify taking the GB14c land out of Green Belt designation – but this will not satisfy the tests set out in case law. 11. To take GB14c land out of Green Belt designation will clearly be contrary to the National Planning Policy Framework (Green Belt Protection), the London Plan (chapter 7) and the Plan Policies LP34 (Managing and Protecting the Borough’s Green Belt and Metropolitan Open Land), LP 36 (Allotments and Local Produce (c) protecting agricultural Land), LP37 (Green Infrastructure and Blue Ribbon Network) and LP39 (Nature Conservation and Biodiversity) 12. Sustainability Issues - Firstly we should define sustainability in the terms of the local plan; the most popular definition of sustainability is that from the Brundtland Report of 1987 which states: Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs. This maybe an over simplification of Sustainability but it is the basic reference. We must ask is it Sustainable or sensible to develop farmland that maybe needed to produce food for a growing population in the future? Is it Sustainable to develop a site that is important for its biodiversity? Is it Sustainable to develop a site where transport links are a major issue? Redbridge Council commissioned a Sustainability Appraisal (which it has to do by law) dated July 2016. There are 15 objectives that the local plan is judged against. We will concern ourselves with objective 8 “Maintain and enhance Biodiversity species and habitats” and 9 “Reduce the effect of traffic on the environment”. We also note that added to the plan proposed development sites we have this spurious “Other Greenbelt sites” (par 6.3.7 & 6.3.10).