Developers have submitted an application for 675 homes, a care home and a primary school on Jotmans Farm. Castle Point Borough Council have also put forward a new draft Local Plan, with evidence documents that classify Jotmans Farm as ‘potential Grey Belt’. This designation increases the chances it will be developed in the future if the Labour Government tell them to increase the number of houses they are planning for.
I have stood side-by-side with local residents on the Jotmans estate many times over the last sixteen years to fight against development on Jotmans Farm. Once again, this treasured local Green Belt site is being threatened with development. Once again, as your local MP, I will stand with residents and fight to preserve this site for future generations.
IT IS VITAL THAT AS MANY RESIDENTS AS POSSIBLE WRITE TO THE COUNCIL OBJECTING TO THE APPLICATION FOR ‘VALID PLANNING REASONS’!
As your local MP, I have submitted an objection to the planning application based on valid planning reasons that the Council can use to defend the site, but the more people who submit objections, the stronger the Council’s hand will be. Valid planning reasons I used in my objection include:
· The site’s Green Belt status
· The capacity of the local road network
· Predetermination of the local plan
· Concerns about surface water flooding
You can find the full documents for the application here: https://www.castlepoint.gov.uk/find-planning-applications and by searching the reference number 26/0310/OUT.
The Council would like you to register on their website if you wish to comment on planning applications, but I have spoken to the Chief Planning Officer, and you can also email your own objections to: [email protected]
Guide to commenting on planning applications
In the event the application goes to appeal, I will request to speak against the application at the public hearing on behalf of residents and put our case directly to the Inspector.
THE COUNCIL MUST REMOVE JOTMANS ‘POTENTIAL GREY BELT STATUS’!
SIGN the petition to remove Jotmans Farm’s ‘Potential Grey Belt Status’ in the Council’s new draft Local Plan- at the bottom of this page.
We have seen off development on this site many times before, and I am determined that we put forward the strongest possible case and fight as hard as we can against it again. Please see my own objection below:
Dame Rebecca Harris MP, Member of Parliament for Castle Point...OBJECTION TO PLANNING APPLICATION 26/0310/OUT
Land at Jotmans Farm, Benfleet
I am writing to formally object to this outline planning application for up to 675 dwellings, a primary school, healthcare facility, residential care home and associated development on Green Belt land at Jotmans Farm.
Throughout my time as Member of Parliament for Castle Point, I have supported the provision of new homes in appropriate and sustainable locations. I recognise the acute need for both market and affordable housing and the importance of ensuring that local families and young people have somewhere suitable to live.
However, housing need does not make every site suitable for development. New homes must be located where the environmental harm is acceptable, where the transport network can accommodate them and where the necessary infrastructure can genuinely be delivered.
Jotmans Farm is the wrong location.
This land performs an important strategic function at the western edge of South Benfleet. It helps contain the built up area, protects open countryside from encroachment and contributes to a clear boundary between Castle Point and Basildon along the A130 corridor.
Residents have fought hard over many years to protect Jotmans Farm. The previous refusal was defended by the former Government through the courts, reflecting the seriousness of the Green Belt and planning issues associated with developing this land.
The present application is not identical to earlier proposals and must be determined on the evidence and national policy applying today. Nevertheless, the fundamental physical consequences remain clear. An extensive area of open land would be permanently changed into a substantial urban development containing hundreds of homes, roads, buildings and infrastructure.
Although the applicant seeks to rely upon changes to national planning policy, the Council’s emerging Local Plan and the site’s designation as “Potential Grey Belt”, none of these matters justify the granting of planning permission. The proposal would still result in significant and permanent harm to the openness, function and purposes of the Green Belt. It also raises serious concerns regarding highway capacity, flood risk, surface water drainage, infrastructure provision and the cumulative effects of development across the wider area.
Local residents already experience surface water flooding on Watlington Road during periods of heavy rainfall. The application site forms part of the wider catchment draining towards this area and the surrounding drainage network is already under pressure. Given the site’s topography, the reliance on a comprehensive surface water drainage strategy and the importance of ensuring that development does not increase flood risk elsewhere, the Council should only grant planning permission if it is entirely satisfied that the proposed drainage system will operate effectively throughout the lifetime of the development, including during extreme rainfall events and taking full account of climate change.
I am also concerned that the application does not adequately confront the wider cross boundary context. Basildon’s emerging Local Plan includes a significant employment proposal at Policy E4 on the western side of the A130 near Sadlers Farm. The Government has now directed Basildon Council to continue progressing its Local Plan, meaning that proposal forms part of a reasonably foreseeable strategic planning context rather than a matter which can simply be ignored.
Development at Jotmans must therefore be considered not only as an isolated housing scheme, but for its potential cumulative effects with development on the opposite side of the A130, wider housing growth, existing congestion and pressure on the strategic road network.
For the reasons set out below, I respectfully request that Castle Point Borough Council refuses planning permission.
Summary of Grounds for Objection
The proposal would permanently transform a substantial Green Belt site at the edge of South Benfleet into a major residential neighbourhood.
In my view, permission should be refused for the following principal reasons:
1) Inappropriate development in the Green Belt
The applicant has not satisfactorily demonstrated that every condition required by national policy for the development to be treated as not inappropriate on Grey Belt land has been met. If those conditions are not met, the proposal is inappropriate development and the applicant has not demonstrated very special circumstances which clearly outweigh the resulting Green Belt harm and all other harm.
2) Harm to openness and the purposes of the Green Belt
The development would permanently urbanise open land, extend the built form of South Benfleet westwards and weaken the strategic role of the countryside surrounding the A130 corridor.
3) The applicant’s Grey Belt case is not determinative
The Council’s emerging assessment is relevant evidence, but the designation “Potential Grey Belt” is not a planning permission or an allocation. The Council must independently assess this application, the precise site, the consequences of the proposed development and whether all the tests in national policy are satisfied.
4) Inadequate assessment of the wider strategic and cross boundary context
The proposal has not been sufficiently assessed alongside Basildon’s emerging E4 employment allocation and other reasonably foreseeable development affecting the A130 and Sadlers Farm. The cumulative consequences for the Green Belt, landscape and transport network require fuller consideration.
5) Highway capacity, cumulative impact and network resilience
The proposed roundabout may superficially address the immediate means of access, but it does not by itself demonstrate that the wider network can sustainably accommodate the traffic generated by 675 homes and the associated uses. The assessment must address cumulative demand and the extremely limited resilience of the A130, Sadlers Farm, Tarpots and the routes serving Canvey Island.
6) Flood Risk and Surface Water Drainage
The application has not yet demonstrated that the proposed drainage strategy would avoid increasing flood risk elsewhere or adequately address existing surface water flooding affecting land adjoining the site. Given the existing flooding experienced on Watlington Road, the Council should require robust evidence that the development will not worsen flood risk and, wherever possible, will improve the existing drainage situation.
7) Infrastructure delivery has not been secured with sufficient certainty
The proposed school, healthcare facility and other infrastructure are presented as important benefits, but outline permission should not be granted unless their delivery, funding, timing and long term operation can be secured. Providing land or buildings does not by itself guarantee that services will be commissioned, staffed and opened when residents need them.
8) Conflict with the plan led consideration of strategic growth
The application would determine the future of one of Castle Point’s largest strategic Green Belt sites before the Local Plan Examination has resolved the appropriate scale and distribution of growth or properly considered all reasonable alternatives.
9) The adverse impacts outweigh the benefits
Housing, affordable housing and community facilities attract significant positive weight. However, those benefits do not overcome the permanent Green Belt, landscape, transport and strategic planning harms identified in this representation.
1) Inappropriate Development in the Green Belt
The site lies within the Metropolitan Green Belt. The proposal would introduce up to 675 homes together with a school, healthcare facility, care home, roads and associated infrastructure onto land which is presently predominantly open and undeveloped.
Under the National Planning Policy Framework, development on Grey Belt land may be treated as not inappropriate only where all the conditions in paragraph 155 are met. These include that the development would not fundamentally undermine the purposes of the remaining Green Belt across the plan area, that there is a demonstrable unmet need, that the location is or can be made sustainable and that the applicable Golden Rules are satisfied.
The applicant asserts that those conditions are met and also advances an alternative case that very special circumstances exist. It relies upon a severe housing land supply shortfall, the delivery of 50 per cent affordable housing, a primary school, healthcare provision, a care home and other claimed benefits.
Those are substantial considerations and should be recognised honestly. However, they do not remove the need for the Council to test the proposal rigorously against each part of national policy.
In particular, the Council must be satisfied that:
· The application site itself properly falls within the national definition of ‘Grey Belt’
· Development of this land would not fundamentally undermine the purposes served by the remaining Green Belt across the relevant plan area
· The site is genuinely sustainable when the likely travel behaviour and wider highway network are considered
· The Golden Rules and associated infrastructure requirements are fully secured and deliverable
· There are no other material harms which make the application unacceptable when the Framework is read as a whole
The applicant’s own case acknowledges harm to the Green Belt, landscape and agricultural land, although it characterises the Green Belt harm as limited to moderate and argues that the benefits outweigh it.
I do not consider that assessment gives sufficient weight to the scale and permanence of the proposed urbanisation, the site’s strategic location or the evolving development context on the opposite side of the A130.
If the Council concludes that any of the paragraph 155 conditions are not met, the development remains inappropriate. In those circumstances substantial weight must be given to Green Belt harm, and permission should only be granted if very special circumstances clearly outweigh that harm and every other identified harm.
In my view, the applicant has not demonstrated that exceptionally demanding test.
2) Harm to Openness and the Purposes of the Green Belt
Jotmans Farm is not merely a vacant parcel on the edge of an urban area.
It is an extensive area of open land which contributes to the transition between South Benfleet and the countryside to the west. It limits the outward expansion of the built up area and helps protect the A130 corridor from becoming surrounded by continuous urban development.
The proposal would replace that openness with a substantial new neighbourhood. Roads, homes, the school, healthcare facility, care home, lighting, parking and associated activity would permanently change the spatial and visual character of the site.
Landscaping may soften the appearance of development over time, but it cannot recreate the openness that would be lost. Nor can planting reverse the physical extension of the built up area into the countryside.
The applicant’s assessment accepts that the relevant Green Belt parcel makes at least a moderate contribution to purposes concerning sprawl, separation and encroachment.
That finding is important. A conclusion that land does not strongly contribute to one of the purposes used in the national Grey Belt definition is not the same as concluding that it makes no contribution or that its development would cause no harm.
The Council must therefore assess:
· The extent of the westward extension of South Benfleet
· The loss of countryside and openness
· The increased perception of urban development along the A130
· The relationship between the site and development in Basildon
· The permanence of the remaining Green Belt boundary; an
· The cumulative effect upon the identity and setting of the adjoining communities
In my view, the proposal would result in a major and irreversible change to the character and function of this part of the Green Belt.
That harm should be weighed fully and should not be reduced to an assumption that development is acceptable simply because the site has been described as “Potential Grey Belt”.
3) The Applicant’s Reliance on “Potential Grey Belt”
The applicant places considerable reliance upon the Council’s Green Belt Assessment and Housing Capacity Topic Paper, which identify the relevant area as potentially meeting the national definition of Grey Belt. The Planning Statement expressly uses those findings to support the application.
It is important to state the correct planning position.
The emerging assessment is a material consideration. However, designation of “Potential Grey Belt” is not a separate statutory land classification and it does not grant permission or allocate Jotmans Farm for development.
Nor is it necessary for the emerging Local Plan to be adopted before the Council can decide whether land is Grey Belt. National guidance specifically expects planning authorities to determine Grey Belt status where necessary when deciding applications.
The decisive point is therefore not simply that the Local Plan is emerging, it is that the Council must make its own application specific judgement rather than treating a broad evidence base assessment as conclusive.
That judgement must address:
· Whether the assessment area was drawn at a sufficiently appropriate and granular scale
· Whether every part of the application site performs in the same way
· Whether the site strongly contributes to any relevant Green Belt purpose
· Whether development would fundamentally undermine the purposes of the remaining Green Belt
· Whether other protected assets or constraints provide a strong reason to restrict development
· Whether the proposal satisfies all the further requirements of paragraph 155.
Government guidance makes clear that Grey Belt identification is only one element of the decision. Wider development plan policies and other material considerations continue to apply, and Grey Belt status does not require the application to be approved.
I also remain concerned that insufficient weight was attached in the Council’s assessment to Jotmans Farm’s strategic role along the A130 and to the risk of development taking place on both sides of that corridor.
The Committee should not therefore ask only whether the applicant can point to the words “Potential Grey Belt”. It should ask whether the evidence, when tested against the precise development now proposed and the full cross boundary context, demonstrates that national policy supports permission.
In my view, it does not.
4) Wider Strategic and Cross Boundary Planning Context
The application cannot properly be assessed as though land west of the A130 will necessarily remain open and undeveloped.
Basildon’s emerging Local Plan contains Policy E4, proposing employment development to the west of the A130 near Sadlers Farm and close to the north western part of Jotmans Farm.
The Basildon proposal remains emerging and must not be described as certain development. However, the Government intervened on 21 July 2026 and directed Basildon Council to continue progressing its Local Plan. The Minister’s letter emphasises the importance of completing the plan and avoiding piecemeal and speculative development.
The applicant itself relies upon emerging planning evidence where that supports its case. It is therefore entirely reasonable for the Council also to consider the emerging cross boundary proposals which may increase the harm arising from Jotmans.
If significant employment development comes forward west of the A130 and this housing development is permitted to the east, there would be major development on both sides of a road which currently helps form a clear and understandable edge to the urban area.
The cumulative consequences could include:
· A substantial urbanisation of the A130 and Sadlers Farm corridor
· Weakening of a recognisable Green Belt boundary
· Increased encroachment into the countryside
· Greater visual and physical linkage between development in Castle Point and Basildon
· Additional peak hour demand at Sadlers Farm and on the A130 and A13
· Reduced confidence in the permanence of the remaining Green Belt
The Transport Assessment considers a number of other applications but excludes several proposals because they were not sufficiently certain at the time of preparation.
That approach may have been understandable when the assessment was compiled, but the Government’s subsequent intervention in Basildon’s plan making process is a material change in context. Before determining the application, the Council should require the applicant and the highway authority to confirm whether the cumulative analysis remains adequate.
At minimum, the Committee should not accept a planning balance which treats the Jotmans site as though its western surroundings are fixed and unaffected by reasonably foreseeable strategic development.
5) Highway Capacity, Cumulative Impact and Network Resilience
The application proposes that residential traffic would use a new roundabout on the A130, with the northbound through movement designed to bypass the roundabout. Vehicular access to the residential element would not be provided through the existing Benfleet streets.
That is materially different from a scheme which directs all traffic through Jotmans Lane, and the proposed access arrangement should be assessed on its actual merits.
However, demonstrating that the new junction itself can operate safely and within capacity does not answer the wider transport question.
The Transport Assessment states that the new access would operate within capacity and concludes that additional traffic would not materially affect the operation of Canvey Way at that location.
The relevant issue for the Committee is broader:
Can the surrounding strategic network accommodate the total additional demand generated by the development, alongside committed and reasonably foreseeable growth, without unacceptable highway safety effects or severe residual cumulative impacts?
The submitted assessment considers the A130 access, Sadlers Farm, Tarpots, Cemetery Corner, Waterside Farm and other local junctions. Its principal modelling scenarios compare a 2031 baseline with a 2031 baseline plus the proposed development.
The Council should nevertheless seek clear answers to the following matters:
Cumulative development
The assessment excluded some emerging developments because permission had not been granted or their future was uncertain. That includes significant proposals affecting the wider Basildon area.
The Council should establish whether the cumulative scenario remains robust following the Government’s intervention in Basildon’s Local Plan and whether the E4 allocation has been adequately represented.
Network resilience
Castle Point depends upon a limited number of strategic routes. Disruption at Tarpots, Sadlers Farm, the A130 or the routes serving Canvey frequently produces consequences across a much wider area.
The recent major Cadent works at Tarpots have again demonstrated how congestion can spread when an important junction is constrained. That experience is not, by itself, a technical reason for refusal. It does, however, illustrate why capacity modelling under standard conditions should be supplemented by a proper understanding of network resilience and recovery during disruption.
Existing highway safety record
The applicant’s own assessment records 110 injury collisions within the study area over five years, including 29 serious collisions. At Sadlers Farm it identifies 37 collisions, ten of them serious, while 15 incidents were recorded around Tarpots, six of them serious. The applicant concludes that these do not reveal an inherent network deficiency, but the figures underline the need for close scrutiny by the highway authority.
Travel behaviour
The Transport Assessment records high local car ownership and identifies driving as the dominant journey to work mode. It also reports comparatively low levels of walking, cycling and bus use.
The proposed bus route, walking links and cycling improvements are welcome, but assumptions about modal shift must be realistic and supported by enforceable measures, funding and monitoring.
Impact upon Canvey access
Traffic from the development using the A130 would share parts of the same strategic network relied upon by residents travelling to and from Canvey Island. The assessment must therefore demonstrate that the proposal would not materially worsen congestion or reduce resilience on routes which already perform a critical access function.
The emerging Castle Point Plan itself recognises that several junctions are at, close to or above capacity and requires cumulative impacts and mitigation to be examined carefully.
I therefore ask the Council not to determine the application until Essex County Council has provided a clear and fully reasoned conclusion on:
· The adequacy of the cumulative development assumptions
· The treatment of Basildon’s ‘E4 employment land’ allocation
· Resilience of the wider network
· The deliverability and timing of all proposed mitigation; and
· Whether the residual cumulative impacts would be severe or highway safety would be unacceptably affected.
6) Flood Risk, Surface Water Drainage and Climate Resilience
National planning policy is clear that development should not increase flood risk elsewhere and should incorporate sustainable drainage systems that remain effective for the lifetime of the development.
The principle of Sustainable Drainage Systems (SuDS) is supported and, where appropriately designed, they can make a valuable contribution to reducing flood risk. However, the issue before the Council is not simply whether SuDS are proposed, but whether the applicant has demonstrated that the drainage strategy will operate effectively under all reasonably foreseeable conditions and leave existing residents no worse off.
Local residents already experience surface water flooding along Watlington Road during periods of heavy rainfall. Whilst I recognise that runoff from agricultural land behaves differently to runoff from developed land, the site forms part of the wider drainage catchment and illustrates the sensitivity of the surrounding drainage network. The Council should therefore be satisfied that the proposed development will improve, rather than simply accommodate, existing drainage conditions.
The development would replace a significant area of permeable land with roofs, roads, parking areas and other hard surfaces. Although attenuation basins and other SuDS features are proposed to manage this change, their effectiveness depends upon robust design, adequate storage capacity, long term maintenance and the ability of the receiving drainage network to accommodate flows during severe rainfall events.
Particular attention should be given to the ultimate discharge arrangements for surface water. If the proposed drainage strategy relies upon an overflow route beneath the railway line towards Benfleet Creek during extreme rainfall events, the Council should be satisfied that this infrastructure has sufficient capacity, can operate reliably throughout the lifetime of the development and will not increase flood risk elsewhere.
The Council should therefore require clear evidence that:
- Post development runoff will not increase flood risk to neighbouring land or properties;
- Existing flooding affecting Watlington Road will not be exacerbated;
- Exceedance flows have been properly modelled;
- Climate change allowances have been fully incorporated into the drainage design;
- The receiving drainage infrastructure possesses sufficient long term capacity; and
- Future maintenance responsibilities for the drainage system are secured for the lifetime of the development.
Until those matters have been satisfactorily demonstrated through robust technical evidence and confirmed by the Lead Local Flood Authority and other statutory consultees, I do not believe the Council can conclude that the proposal complies with national planning policy relating to flood risk and sustainable drainage.
7) Infrastructure Delivery and Existing Services
The application includes land for a two form entry primary school, early years provision, a healthcare facility and a 60 bed care home. Those are potentially significant benefits and should not be ignored.
The applicant’s Education Needs Assessment identifies an immediate need equivalent to approximately one form of primary entry, while the application safeguards enough land for a two form entry school. The applicant argues that the additional capacity could also help meet need from wider development.
The Healthcare Needs Assessment acknowledges that local GP provision is already under pressure. The application proposes a 1,500 square metre healthcare facility, which the applicant says would exceed the floorspace directly generated by the development and assist with an existing shortfall.
These claims should be independently tested with Essex County Council, the NHS and the relevant service commissioners.
The central issue is not simply whether land or a building appears on an illustrative plan. The Council must establish:
· Who will fund construction;
· Who will commission and operate each facility;
· Whether a healthcare provider is committed to occupying the building;
· Whether revenue funding and staffing will be available;
· When the school and healthcare facility would open;
· How many homes could be occupied before each facility is operational;
· What happens if the relevant provider does not take up the land;
· Whether the facilities would remain available for their intended purpose; and
· Whether all obligations meet the statutory tests and are secured through the section 106 agreement.
The submitted draft heads of terms remain broad and state that the final scope is subject to negotiation. They include the provision of land for the school, healthcare facility and care home, rather than setting out a complete delivery mechanism for each facility.
A development should not receive substantial positive weight for facilities unless there is adequate certainty that they will be delivered and operated at the stage when the additional demand arises. Nor should existing residents be expected to bear further pressure while promised infrastructure remains unbuilt or unstaffed.
If those matters cannot be satisfactorily resolved through enforceable obligations and phasing conditions, the claimed infrastructure benefits should attract reduced weight and the application should be refused.
8) Conflict with the Plan Led Consideration of Strategic Growth
The application is being submitted while Castle Point’s Regulation 19 Local Plan is under examination.
The emerging Plan pursues an urban first strategy and does not allocate Jotmans Farm. It seeks to provide 6,196 homes over the plan period, compared with a standard method figure of 11,662, on the basis of the Borough’s Green Belt, highways, environmental and healthcare constraints.
The applicant disputes that strategy and argues that the housing shortfall, lack of a five year supply and Grey Belt policy justify permitting Jotmans now. That case must be considered under the national policy applying to this application.
However, the scale and strategic significance of the proposal remain highly relevant.
This is not a small windfall site. It is a proposed new community of up to 675 homes with major infrastructure, on land previously considered through earlier Local Plan processes.
National policy warns that refusal on prematurity grounds will seldom be justified, but recognises that prematurity may be relevant where a proposal is so substantial, or its cumulative effect so significant, that granting permission would undermine the plan making process by predetermining decisions about the scale, location or phasing of new development.
The Council should therefore consider whether permitting Jotmans now would:
· Predetermine a central issue before the Local Plan Inspectors
· Weaken the Council’s case concerning the strategic importance of its Green Belt
· Pre-empt the assessment of reasonable alternatives
· Materially alter the planned distribution of growth across the Borough.
I have consistently argued that the Council should make the strongest possible case to Government for a lower housing requirement reflecting Castle Point’s exceptional constraints.
If the Local Plan Examination ultimately concludes that Green Belt release is necessary, that release should follow a comprehensive and comparative assessment of strategic alternatives.
I believe North West Thundersley (colloquially better known as the ‘Blinking Owl Site’) should have received much fuller assessment because of its potential to support a new strategic road connection, improve network resilience and produce a more balanced distribution of development.
That does not mean the Planning Committee should refuse Jotmans merely because another site exists. It does mean that the Council should be extremely cautious about permitting one strategic Green Belt site before the Local Plan Examination has completed the task of assessing the Borough’s overall strategy and reasonable alternatives.
9) Planning Balance
I note the considerable benefits described by the applicant.
The proposal would deliver up to 675 homes, including a proposed 50 per cent affordable housing contribution. It would provide employment during construction, additional local spending, land for education and healthcare facilities, a care home, open space, biodiversity improvements and transport measures.
Given Castle Point’s housing shortfall, I recognise that those benefits attract weight in planning terms.
Nevertheless, the planning balance must be undertaken against the proposal actually before the Council and not against housing need in isolation.
The adverse impacts include:
· The permanent urbanisation of a substantial Green Belt site
· Loss of openness and countryside
· Westward extension of the built up area
· Weakening of the strategic A130 Green Belt corridor
· Potential cumulative urbanisation on both sides of the A130
· Unresolved questions concerning cumulative traffic and network resilience
· Uncertainty concerning the delivery and operation of community infrastructure
· Potential prejudice to the plan led consideration of Castle Point’s spatial strategy.
If the site is not found to satisfy every requirement of paragraph 155, the proposal is inappropriate development and substantial weight must be attached to Green Belt harm. In that event, the applicant has not demonstrated that very special circumstances clearly outweigh that harm and all other harm.
Even if the Council concludes that the proposal is not inappropriate development under paragraph 155, that does not mean permission must follow. The application must still comply with the development plan unless material considerations indicate otherwise, and it must be acceptable when the Framework is read as a whole. Government guidance expressly confirms that Grey Belt status does not require approval.
In my view, the claimed benefits do not outweigh the permanent Green Belt, landscape, transport, infrastructure and strategic planning harms.
I therefore respectfully request that planning permission is refused.
Final Comments
Jotmans Farm has been defended for many years because it performs a real and important planning function. It has in fact been defended by a decision made by a previous Secretary of State under the last Government, and indeed a High Court Judgement by Mrs Justice Lang less than a decade ago in 2017.
National policy may have changed, and the housing pressures facing Castle Point are undeniably serious, but the physical consequences of developing this land have not disappeared. Once this countryside is urbanised, it cannot be restored. I support the delivery of the homes Castle Point genuinely needs, but those homes must be planned in the right locations, with infrastructure that is certain to be delivered and through a process which properly assesses the consequences and alternatives.
This application fails that test.
I will continue standing with local residents and doing everything I can to protect Jotmans Farm.
Thank you for considering my objection.
Dame Rebecca Harris DBE MP
Member of Parliament for Castle Point
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APPENDIX A
Draft Framework for Suggested Reasons for Refusal
Important: These draft reasons are for reference reasons by local councillors on the development control committee only and should only be made or used for reference after full review and consultation with by the Council’s planning and legal officers after considering the complete consultation responses, any amended documents and the formal advice of Essex County Council. A highways or infrastructure reason should not be adopted unless the evidence available at determination supports it.
Reason 1: Failure to demonstrate that the proposal is not inappropriate development in the Green Belt
The application site lies within the Metropolitan Green Belt. The Local Planning Authority is not satisfied that the applicant has demonstrated that all the conditions required by paragraph 155 of the National Planning Policy Framework are met, including that the development would not fundamentally undermine the purposes of the remaining Green Belt across the plan area and that the development would be in a sustainable location.
The proposal therefore constitutes inappropriate development in the Green Belt. Substantial weight is attributed to the resulting Green Belt harm and the applicant has failed to demonstrate very special circumstances which clearly outweigh that harm and all other harm.
The proposal is therefore contrary to the relevant saved policies of the Castle Point Borough Local Plan and the National Planning Policy Framework.
Reason 2: Harm to openness, countryside and the strategic Green Belt function of the A130 corridor
The proposed development, by reason of its scale, extent and urbanising effects, would result in a substantial and permanent loss of openness and encroachment into the countryside. It would extend the built form of South Benfleet westwards and weaken the clear and recognisable Green Belt corridor adjoining the A130.
When considered in its wider and evolving cross boundary context, including reasonably foreseeable development west of the A130, the proposal would cause unacceptable harm to landscape character, settlement pattern and the long term integrity of the Green Belt in this location.
The proposal is therefore contrary to the relevant saved landscape and Green Belt policies of the Castle Point Borough Local Plan and the National Planning Policy Framework.
Reason 3: Insufficient assessment of cumulative highway impacts
On the evidence presently available, the Local Planning Authority is not satisfied that the Transport Assessment has adequately assessed the cumulative effects of the development together with reasonably foreseeable growth affecting the A130, Sadlers Farm, the A13, Tarpots and the wider routes serving Castle Point and Canvey Island.
In the absence of a robust and up to date cumulative assessment, the Authority cannot be satisfied that the proposed mitigation would prevent unacceptable highway safety effects or severe residual cumulative impacts upon the road network.
The proposal is therefore contrary to the National Planning Policy Framework and relevant local transport policies.
Reason 4: Failure to secure necessary infrastructure
The application has not demonstrated with sufficient certainty that the education, healthcare, public transport and other community infrastructure necessary to support the development would be funded, delivered, commissioned and made operational at the appropriate stages of occupation.
In the absence of an adequate planning obligation and enforceable phasing arrangements, the proposal would place unacceptable additional pressure upon existing services and would not constitute sustainable development.
The proposal is therefore contrary to the relevant infrastructure policies of the Development Plan and the National Planning Policy Framework.
Reason 5: Flood Risk and Surface Water Drainage
The Local Planning Authority is not satisfied that the applicant has demonstrated that the proposed development would avoid increasing flood risk elsewhere or that the proposed surface water drainage strategy would operate satisfactorily throughout the lifetime of the development.
In particular, insufficient evidence has been provided to demonstrate that existing surface water flooding affecting land adjoining the site, including Watlington Road, would not be exacerbated, that exceedance flows have been satisfactorily addressed, that the receiving drainage infrastructure possesses sufficient capacity or that the proposed Sustainable Drainage System would remain effective during extreme rainfall events taking account of climate change.
Accordingly, the proposal conflicts with national planning policy requiring development to avoid increasing flood risk elsewhere and to incorporate effective and sustainable drainage arrangements.
Reason 6: Prematurity and prejudice to the plan making process
By reason of its scale, location and strategic significance, the proposal would predetermine decisions concerning the scale, location and distribution of development which are central to the ongoing examination of the Castle Point Local Plan.
Granting permission before the Examination has considered the soundness of the spatial strategy, the treatment of the Green Belt and reasonable strategic alternatives would undermine the plan making process.
The proposal is therefore premature and contrary to the plan led principles of the National Planning Policy Framework.
Overall Recommendation
For the reasons set out in this representation, the Council should conclude that the applicant has not demonstrated that the proposed development is acceptable under national Grey Belt policy or that the substantial benefits of the scheme outweigh the permanent Green Belt, landscape, transport, infrastructure and strategic planning harms.
Planning permission should therefore be refused.