Responses to consultation

Green Balance is frequently approached by organisations wishing to respond effectively to consultations on emerging policies, draft plans and planning applications. Our experience is valued by clients not only for technical reliability but also for finding the most efficient ways to construct and present a case. We can help national bodies dealing with controversial policy initiatives through to local organisations less familiar with the planning system facing challenging proposals.

Land allocations in local authority development plans

Plans prepared by local authorities aim to provide a large measure of certainty about the types and sizes of development which will be allowed in different places.  Choosing between the options can be as difficult as it is important (and Green Balance advises local authorities on these controversial matters).  We help organisations with responding to consultations on plans in preparation, providing realistic advice on what can be achieved.  We assist challenges to poorly-justified land allocations which would be environmentally damaging.

Kent County Council proposed to allocate this site at Shoreham for gravel working

In 2011 Kent County Council consulted widely on options for its Mineral Sites Development Plan Document.  One proposal was for a small sand and gravel site within the Kent Downs Area of Outstanding Natural Beauty at Shoreham.  Local residents around the site commissioned Green Balance to press for the removal of the allocation from the final plan.  The site was in a remarkably sensitive location within this village in the tourist-frequented Darent Valley, overlooked from popular rights of way and vantage points, and served by roads quite unsuited to gravel lorries.  We investigated other impacts too and presented a case showing that the site failed the Council’s own policy objectives as well as the tests for quarrying in this protected landscape.  The proposed allocation was later dropped.

In the Kent Minerals and Waste Local Plan, Kent County Council proposed to identify land for silica sand working even though extensions to all known sites like Wrotham Quarry would be in the Kent Downs AONB.  It also proposed to release a large site for soft sand at Shrine Farm, Postling in the immediate setting of the AONB.  The Kent Downs AONB Executive considered both were unnecessary and asked Green Balance to submit written and oral evidence to the Plan's Examination in April 2015.  In the case of silica sand, Green Balance argued successfully that allocations should not be made but that any planning applications should be treated on their merits so that AONB issues could be properly assessed.  We also showed that the intention to allocate Shrine Farm for soft sand was to meet a misconceived 'landbank' requirement: there was a surplus of soft sand in the county and a shortage of sharp sand, which would not be resolved by adding the two types of sand together to meet an overall target.  The Inspector agreed that sufficient sites could be provisionally identified for soft sand working while omitting those likely to adversely affect the Kent Downs AONB or its setting, like Shrine Farm.

Shrine Farm, Postling, Kent proposed site for soft sand extraction, seen from the North Downs Way National Trail near Tolsford Hill.

Consultations on national policy

Green Balance assisted the National Trust in Northern Ireland in responding to a new draft Planning Policy Statement 24 on Economic Considerations in 2011.  This proposed that where the economic implications of a proposal are significant, “determinative weight” should be given to them in deciding planning applications.  Our advice showed that the policy would be highly damaging environmentally and to tourism, development would be poorly co-ordinated with infrastructure, and that the policy was likely to be counter-productive.  We argued that the proposal was in any event based on misconceptions about the merits of planning controls, about developers’ interests in good planning, and about the impact which planning has on economic investment both in principle and in practice.  Two months later the Northern Ireland Environment Minister formally abandoned the policy proposal.

Also successful was our recent assistance in the response of the Campaign to Protect Rural England to proposals in the draft National Planning Policy Framework to abandon the priority given to developing brownfield sites before greenfield sites (see National campaigns).



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