Objection Letter
Opening
XX XXXXXXXX Way
Thetford Norfolk IP24 1XX
Planning Breckland Council Elizabeth House Walpole Loke
Dereham
Norfolk NR19 1EE
3rd June 2024
For the attention of Rebecca Collins:
Dear Ms Collins
PLANNING APPLICATION NO. 3PL/2024/0394/O
The Abbey Regeneration by Flagship Housing Association
I write in connection with the above planning application. I live on the Abbey Estate and will be affected by this proposed regeneration. I wish to object strongly to the development of the Estate.
1. My Circumstances
I would like to explain my own circumstances. I will lose my garage and front garden as a result of this development. It will be replaced with a car park for Flagship tenants and other residents. This is a loss of my privacy, as the barrier of a front garden down to the road will no longer exist. I will face increased car insurance costs and higher EV charges. I will have no guarantee that I will be able to park near my house and may have to use parking permits in the future. I will look out from my kitchen window onto an unsightly car park where anyone can dump vehicles or work on their cars and vans. I will also loose the garages on the other two properties that I rent out. This means that going forward I can’t charge rent for a three bedroom house with a garage and thus my rental income will be reduced. Flagship in their booklet “Our Promise and Support for Abbey Residents stated, “We will not leave anybody worse off financially.” This is not true in my case, as I will be worse off. Plans for garage removal did not appear in any of the consultation booklets and I question whether the Gunning Principles for consultation have been correctly applied.
2. Historical and Cultural Heritage
The Abbey Estate is a settled housing Estate that is fifty years old, development should be considered very carefully: infilling the Estate in manner Flagship has proposed will ruin the character of this settled community. The design of the regeneration will not take opportunities to improve the character of the area and should not be accepted. The Breckland Local Plan states that designs should be “safe for places and spaces, in both the private and public realm which respects the character and local distinctiveness of Breckland’s communities.” This proposal goes against this aspect of the local plan as the proposed development would radically alter the Abbey Estate and its community.
3. Design and Appearance
Pressure for this development is considerable, mainly for adding to the social housing stock in Thetford, however other Flagship developments in Thetford have been stopped because of loss of green space and proposed high density infill. The proposed plans show the new buildings will be flats and houses added onto the estate with loss of the current greens which are used by local people. The Thetford Area Action Plan states “Green infrastructure is multi functional and can provide a range of environmental, social and economic functions, including positive health benefits and aid social cohesion.” The Estate was award winning when it was first built and the greens between the houses was one of the reasons for the design being considered exceptional.
4. Traffic and Transport
There will be an increase of traffic on the Estate as there still will only be one road that allows access. This will be inadequate to accommodate the extra number of cars on the Estate, as many of the new dwellings will be flats and houses of multiple occupation. There cannot be another road built to improve access and prevent congestion because of the location of the Estate between the railway line and river. The Thetford Travel Plan indicated that after building the Strategic Urban Extension to the north of the town there would be an extra 816 trips taken around the town every day. It did not envisage the building of over five hundred extra dwellings being built on the Abbey Estate so this figure would now have to be revised upwards. The Thetford Area Action Plan states “The efforts on walking, cycling and buses need to be underpinned by a well-designed smarter travel programme so as to fully deliver significant modal shift and achieve wider benefits on carbon emission reductions, decreased congestion and health.” This development cannot be described as part of a smarter travel programme because of the limitations of the geography of the Estate and the high density nature of the proposed housing types.
5. Parking
At no point in the consultation were the residents told that Flagship were proposing to place houses of multiple occupation on the estate. These dwellings will house many adults who will be car owners. This means that parking will be at a premium given the density of the proposed housing. The plans show the design has ‘parking courts.’ Norfolk Constabulary in their response to the planning documents have said these are problematic and ‘a challenge’ they would not promote their use on a new development. Furthermore, the planned number of parking spaces allocated relies on the removal of private garages and gardens. The residents have, in writing, an agreement from Flagship that each street can vote whether to retain their garages. If every street decides to keep their private garages this will reduce the proposed number of parking spaces. Where will residents park if this is the case? The plans show that new three bedroom houses will be allocated one and a third parking space and each four bedroomed house two spaces. This will not be enough. Given that these spaces are not guaranteed to be outside residents homes it could lead to anti social behaviour and potential crime. Again the Norfolk Constabulary point out “it is essential to ensure that the vehicle owner is provided with a view of their vehicle to offer the best protection.” Loss of personal garages means that EV vehicles will inevitably be parked away from their owners homes when charging.
6. Impact on Local Services
There is a lot of pressure on local services as the proposed New Health Facility in the Strategic Urban Extension that should have been built by 2019 has not materialised. The Thetford Area Action Plan also stated that six dentists would be working in this Health Facility yet Thetford still has only one dental practice. It is estimated the Urban Extension will give Thetford an additional 12,000 people, however the amenities described in the Thetford Area Action Plan have not been provided. An extra 500 households on the Abbey Estate in addition to the Strategic Urban Extension will strain existing services further given that many of the families and individuals placed on the Estate will present with greater health and social needs than those on the Urban Extension.
7. Design and Appearance
The Thetford Area Extension Plan discusses ‘Regeneration Proposals in Existing Residential Areas.” The Plan states that buildings should “contribute to a positive public realm, a positive and vibrant street scape … and are sympathetic to the existing area.” The proposed regeneration will remove houses and gardens and replace them with flats and high density dwellings without garages and gardens. The plan goes on to state “The levels of children’s play equipment and open space (should be) maintained, but preferably increased.” Far from increasing open space this work will reduce green space and areas for play on the greens that are part of the Estate at present. The addition of a central park will not compensate for the overall loss of play opportunities. The proposals will result in an increase in housing density. The Thetford Area Action Plan states “Proposals for redevelopment of dwelling stock that results in a net reduction in housing density will also be supported where this provides for an overall improvement to the housing mix and the site layout, particularly in the treatment of outdoor space.” This development fails to reduce the number of households and removes vital outdoor space. Parking will have to be shoehorned into any available space in order to accommodate the needs of the extra residents leading to a street scape full of cars, terraces and flats out of scale with existing neighbouring properties.
8. Noise and Disturbance
The length of this development over a eighteen years period will seriously affect the quality of life for the residents as they will effectively be living on a building site for that period of time. Article one of the The First Protocol of the Human Rights Act states: “Every natural or legal person is entitled to the peaceful enjoyment of his possessions.” The noise, pollution and the disruption of this development over such a long period of time would inevitably break this human right. Construction traffic will only have access and egress from the junction with the Brandon Road and that will result in the area around the school becoming very congested. The noise pollution in the area of the school and houses along Canterbury Way will be particularly detrimental to those living and working in those areas. The needs of children should be considered under the Equality Act 2010 and their playtimes will be disrupted by noisy lorries and dust filled wagons full of waste passing their school.
9. Disruption to Residents in the First Phase
Flagship have agreed there will be disruption to residents particularly in the first phase of the development. Many of these residents have protected characteristics under section 4 of the 2010 Equality Act as they are either elderly, disabled or a child. They and others will be forced to move, many away from the Estate, their community and neighbours while building begins and then have to move again back onto to the estate at a later date. There is potential disruption for school aged children being moved away from their school and friends. There is the difficulty for the elderly being able to do a double move and longer waits for the disabled who have to move back to adapted accommodation. Flagship have acknowledged this will occur and it is “part and parcel’ of a phased development. This will mean that some of these residents will never come back to the Estate.
10. Loss of Privacy and being Overlooked
The building of flats that are more than three stories high will result in a loss of privacy for residents living in —————- Way. Buildings that are being retained will be overlooked by the new tenants in these buildings. The current design of the estate precludes any issues relating to a loss of privacy as the back greens act as a ‘buffer’ between rows of terraced houses. The additional properties will be placed in such a way that enjoyment of private space will be compromised.
11. Environmental Impact - Embedded Carbon
By choosing to demolish nearly half of the existing houses on the Estate the developers are ignoring concerns about embedded carbon. The UK government have implemented policies and regulations to address embedded carbon as part of its broader climate change strategy. This includes, The Climate Change Act 2008 and The National Planning Policy Framework. Addressing embedded carbon in planning should involve a comprehensive approach that includes regulatory frameworks, assessment tools, sustainable material and design choices, efficient construction practices and continuous monitoring and reporting. By selecting to tear down houses that totally serviceable and habitable the developers will fail to reduce the development’s carbon footprint and not help the local authority to meet climate goals. Flagship make the argument that with its own housing stock it will be too costly, to refurbish but they are the landlords and should be maintaining their housing stock so it does not reach this condition.
12. Public Awareness and Stakeholder Engagement
The presentation of the planning documents has been done in a way that they cannot be easily read and understood; this is discriminatory. It is good practice for planning documents to be presented in a way that makes them readable and accessible for all stakeholders, including the general public, professionals, and policymakers. Ensuring that these documents are understandable promotes transparency, inclusivity, and better engagement in the planning process. To expect the lay person to read and understand these proposals, that include one hundred and nine supporting documents, is not reasonable especially as the ‘window’ to comment is time limited. This follows on from a poor consultation from Flagship with the existing residents. The face to face consultation was halted during Covid. On resumption it appeared that the final design had been chosen by Flagship who have not changed their plans during further consultation rounds.
13. Application of the Gunning Principals for Consultation
It is evident from the documents submitted as part of this planning application that Flagship feel they have met the Gunning Principals for consultation. Gunning 4 states “the product of consultation is conscientiously taken into account by the decision maker(s.)” This has been ignored by Flagship. The early part of the consultation did not mention some of the proposals that appeared in their final booklet or that have now appeared in the outline planning application, like building houses of multiple occupation. Flagship claim that 70% of those who responded to their ideas voted for garages to be removed but in their literature it is clear this figure relates to the garage courts that they own and have allowed to become derelict. Not private garages. They have allowed Flagship tenants from other areas to have a say in the consultation process and counted the responses of schoolchildren. A Flagship representative was asked what had they changed as a result of consultation between 2022 and now. He was unable to provide an example of consultation led change. The architects, Levitt Bernstein, posted a video about the development in 2022 and that is now the version for planning going forward despite further consultation since 2022.
14. Final Paragraph
I would ask that you take the above objections into consideration when deciding this application and I would be happy for a representative of the planning department to meet me at my property to show them my objections first hand. I would also like to speak at the planning committee when they are deciding on this application.
Yours sincerely
Your name printed
15. Alternative Ending
I would ask that you take the above objections into consideration when deciding this application.
Yours sincerely
Your name printed
Writing Objection Letters for Planning
Everyone will need paragraph 1 the opening to the letter. Change the address to your own and make sure that the date is correct.
The next paragraph is all about how you feel about the regeneration. This is an important paragraph as it will be what makes your letter different from everyone else
What can I put in my first paragraph to make the letter about me?
(Some of these points are not material considerations but are worth mentioning as long as you don’t go on)
• New flats multi storied buildings will mean you are going to be overlooked or lose light/privacy
• Demolition on your street will result in increased dust, noise, dirt and inconvenience: very relevant if you have COPD or asthma
• You or your family have to move off the estate if you are in phase one or two and that would breach your rights under the Equality Act 2010 if you are part of a ‘protected group’ (children, disabled and the elderly)
• You will be moved away from family or neighbours who are your support system
• Length of time you have lived in your house
• Unhappiness about the consultation process
• How the change to your street will affect you
• How your health has been affected by Flagship’s proposals
• Financial losses as a result of the building works
• Anything else that really bothers you
Then you will need to choose the paragraphs most relevant to you
So if you are someone who lives on Canterbury Way who feels consultation was rubbish and who is having trouble seeing a doctor because of health conditions you might pick paragraphs 9, 14 and 7.
If you are in the first phase and your house is being demolished and you are elderly and don’t like the look of the new buildings you might chose 4, 8, 10 and 12.
If you are losing a garage and garden and thought you were not listened to during consultation and you thought the planning application was hard to read you might want 5, 6, 8, 13 and 14.
Do not use all the paragraphs some won’t be relevant for you
It is not about quantity but quality. The idea is that the letters are individual so they each count as a separate objection.
In the final paragraph you can ask for someone to meet with you at your property to discuss the planning application on site and you can ask to speak at the planning committee. Do not ask to do either of these things if you don’t want to. Use the alternative ending. It is very important you sign your letter so don’t forget. The letter can be sent electronically to Breckland by email or you can post it to the address on the letter.
The deadline is the 12th of June
This is a formal letter that will be posted on the Breckland website
It will not be considered if you mention anyone by name, use bad language, racist, sexist or homophobic terms.
Formal in this instance really does mean formal. The more letters Breckland council receive that are well written and meet the material considerations the better for the Estate.