Local campaigns

Most of our locally-based clients want more than just sound town planning advice. They look to Green Balance to guide them not only on what they say on planning issues but on how they say it, who else to involve, other action to take, and how they manage the whole project through to a successful conclusion. We understand how local organisations function, their financial constraints, and how to divide responsibilities, so we can work co-operatively together. Some examples are summarised below.

Planning application for a block-making factory in the Green Belt

Green Balance acted as expert witness for Wrotham Parish Council at a public inquiry into a proposal to expand this factory on the edge of Borough Green in Kent, at the foot of the North Downs scarp.  Kent County Council supported the development largely because the developer promised to pay for the adjacent Borough Green bypass.  Green Balance advised on the scope of the evidence needed at the inquiry, suitable witnesses and how to handle the promoters’ likely arguments.  The scheme fell – mid-inquiry – on a technicality, resulting in the exceptionally unusual outcome of the Parish Council being awarded its entire costs at an inquiry where the application had been ‘called-in’ for the Secretary of State’s decision.

Site of the proposed block-making plant seen from the North Downs above Wrotham. The Borough Green bypass would have taken a line close to the nearer marked boundary.

Proposed allocation of land for sand working

Residents of Hurtmore village near Godalming, Surrey were surprised when in 2006 the County Council identified Eashing Farm as a preferred area for the quarrying of soft sand and Bargate stone in a Primary Aggregates plan.  About 5.25 million tonnes would be dug up from this substantial site.  The Save Surrey Hills Action Committee (SSHAC) was formed in response, and Green Balance was retained to advise on how to tackle the proposed allocation.  On technicalities we were able to show that major issues affecting the practicability of operating the site remained unresolved, including:

  • in the absence of a hydrogeological study, how could it be known whether the adjacent Site of Special Scientific Interest would be affected by working the site, as its designation relied on a pure water supply through the allocation site?
  • how would the 0.9 million tonnes of waste silt in the site be disposed of?
  • would necessary improvements to the slip-roads onto and off the adjacent A3 trunk road be economically justified by the low grade mineral in the site, or practicable in view of unwilling vendors of the necessary land?
  • one slip-road would pass so close to the village pub that this would probably close: how could that be justified?

Part of the Eashing Farm sand allocation site on the edge of Hurtmore village, Surrey

We also helped SSHAC to run its campaign.  We engaged with all the national agencies with responsibility for aspects of the allocation, and advised on when and how to draw matters to the attention of local government officers, politicians and the media.  We advised on the engagement of transport consultants and lawyers at appropriate moments for specific purposes, and we helped SSHAC to avoid difficulties with objectors to competing sites.  We advised when its members should write letters (to whom and on what) and turn up at events.  We drafted submissions to all stages of the Plan, including appearing at its Examination as both expert and advocate.  Throughout the process we kept in close touch with SSHAC, providing reassurance about what needed to be done, when and why.  In 2010 the Eashing Farm site was removed from the Plan submitted for Examination by an Inspector, and at the Examination the mineral company which had proposed to work the site withdrew its interest.  A five year campaign had been successful, though all SSHAC’s questions remained unanswered.

At the close of the Examination, SSHAC’s Secretary wrote to us:

“We must once more express our great thanks to you for all you have done for the Committee and the local residents in this community… you have always treated us with the most attentive care and consideration and taken up every little (and often irrelevant!) concern with the utmost patience.  We quite frankly could not have got where we are now without you, and we are sure it is because of your expertise, perseverance and complete integrity that things have turned out the way they have.”

New school in the Green Belt

The residents of north Tonbridge, Kent faced an application for a new school at Greentrees Farm in the Green Belt.  Green Balance showed that the proposal did not meet the tests for allowing development in the Green Belt, that it ignored that the site was best and most versatile agricultural land, that it was susceptible to flooding, and that surface water and foul water from the site could not realistically be accommodated.  The application was withdrawn in June 2015 and the school is now expected to share a superior site in south Tonbridge already safeguarded for another school's expansion.

Greentrees Farm on the north edge of the built-up area of Tonbridge, Kent, designated Green Belt and successfully protected from a Kent County Council school.

Housing challenge to village 

In 2014 Circle Housing Association required their tenant pensioners at St George's Court, Wrotham, Kent to move out of their social rented flats to accommodation it provided elsewhere, so that it could redevelop the 1 hectare site.  Under a planning application in 2015, the 56 flats, warden's flat and communal hall would be demolished.  They would be replaced by 60 dwellings entirely for younger households with just 20% guaranteed at 'affordable' rents.  Green Balance assessed the scheme for Wrotham Parish Council, including revised proposals in 2016 intended to have less impact and, later, raise the proportion of affordable rents to at least 40%.  Tonbridge & Malling BC officers recommended approval but councillors refused the application.  Circle lodged an appeal.  At the Hearing in June 2017 Green Balance, for the Parish Council, led the case against the proposal, arguing principally that the scheme was a substantial over-development of the site, had an over-bearing design, and would cause the loss of mature trees around the site which contributed greatly to local character.  Additional traffic would be generated, also contrary to adopted planning policy.  The Inspector broadly agreed and dismissed the appeal.

Meanwhile, Circle had lodged an application with the Upper Tribunal to lift the covenant on the site restricting its use to an old persons warden scheme.  Green Balance provided an expert witness statement on planning to challenge the application, again for the Parish Council.  After the planning appeal failed, Circle withdrew its Court application and was required to pay the Parish Council's costs.

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