Fisherman's Blues

The over-abstracted River Chess at Waterside, Photo courtesy of Wikipedia

What follows is an email communication I had with a local resident, an angler, who was overwhelmed by the complexity of putting in a submission to the Local Plan Consultation.  It is fairly self-explanatory and I hope it can help others in putting together a submission.  His email first, followed by my response:

Hi Dicky,

Many thanks for sending me the example submission in PDF format that I requested. I have read the thing through and it is all way over my head, I am in no way qualified to add anything to this paper. 

Would it be OK to just cut everything in this example, and paste in the relevant areas of the official form, thus effectively sending a carbon copy of this example...or would that be a pointless exercise?

I really have no way of coming up with a comparable or even vaguely useful original, I have neither the expertise nor knowledge of the subject matter, so pointless to even attempt it.

Having said that, as a resident of Chesham for forty five years, and an angler and lover of nature, there is one thing close to my heart that I would love to tag on where applicable, but only if in your opinion, it has an actual bearing on things. If I may, I will rumble on a bit about one aspect of our town that will suffer badly if the proposed housing plans go ahead.

When I came to Chesham, the river Chess was a thing of beauty, it's crystal clear water so typical of England's chalk streams was a joy to behold. It held native brown trout, supplemented by escapee rainbow trout from the trout farm in Chesham, and all the other wildlife associated with such habitats. It gave a great deal of pleasure to the residents of that town, and was a huge asset and much admired amenity.

Sadly, for quite a number of years, the flow of the Chess has slowly reduced year on year, until it is now but a shadow of it's former self. It's original springs in Chesham near Lowndes Park dry up earlier and earlier every year, the sparkling stream that ran through the town, full of gently swaying streamer weed that harboured darting trout right in the very heart of Chesham....becomes a dry mud ditch. The trout and other wildlife it supported are obviously long dead and gone, because the periods of non existent flow (or water of any sort) in the first mile or so through the town extend remorselessly. 

The river now exists in a recognisable form only from the far side of the town onwards, on it's way to Rickmansworth, and even that is now silted up for much of it's length, with low to zero flow for much of the summer. Now we all know that global warming exists, that subsequent weather changes and so on are responsible for many things, but the fact that our towns river dries up each year is not directly down to that....it is over abstraction from the underground aquifers above and in Chesham that are to blame, abstraction levels that are required apparently to supply the steadily increasing population of the town.

That being so, what will happen if the proposed extra housing in the area goes ahead? If already we do not have enough water in the area to supply the existing population without destroying a large part of the once beautiful river that gave birth to the town, will it disappear completely and permanently, to meet increased water demands? Will the Chess become but a memory, existing only in the minds of the elderly and in old, fading photographs once the population explodes once more? Has any though gone into this? Or are the powers that be proposing to blindly go ahead with plans that have not been thought through sufficiently, and doing so regardless of consequences? 

Sorry Dicky, ran on a bit there, but you get my drift. Is any of that relevant or appropriate to be included in my response, added in somewhere or other on that form?

My very best regards

David

And my response below:

​Hello David and many thanks for you thoughtful email late last night.

I am in full agreement with you that the whole process of putting in a submission especially on using the restrictive form supplied goes way over the head of the average man on the street, including me.

The Council perhaps, have not made this easy for us, so that they can push this plan through without protest.

All the more reason why we have to push back on this.

I will disagree with you on one point in your email "I am in no way qualified to add anything to this paper."

Your email is evidence to me that you write eloquently and knowledgeably about issues that are close to your heart.

My suggestion is to forget the form and write a letter (letters are accepted, but take a copy and send it to us) stating at the start of the letter that the suggested form is restrictive, unhelpful and beyond the understanding of the average local resident.

Now attached to my email is the Draft Local Plan (click here and scroll down to Downloads), all 225 pages of mind-numbing twaddle.  Now I am not suggesting you read it all, like I have done.  I had a broken foot at the time and my lack of mobility meant I sadly had nothing else sensible to do!

But after receiving your email last last night, I quickly opened up the Local Plan PDF and did a search on the word "chalk" and Bingo it comes up three times in the document, most noticeably Section 9.6 Natural - River Character And Water Environment.(Pg 139)  Reading on I establish that the relevant clause is Policy DM NP6..(Pg 140)

You are now able to apply everything you wrote so well in your email last night against the Policy DM NP6, disputing the fact that building 500 homes so close the the Chess does not meet the expectations of this policy.  The Planning inspector will be looking for key words and will want to know if you think the Policy is sound or not.

A policy is sound if it is:

• Positively prepared - without doubt 500 homes will impact the existence of the River Chess so fails on this.
• Justified - No evidence has been provided on how the Chess will be protected or that mitigation efforts will work to save the Chess so fails on this
• Effective - You could reasonably argue that a holistic approach needs to be taken to save the Chess and piecemeal unconnected development along its length has an overall impact.  The Plan fails to demonstrate a holistic effective approach  
• Consistent with National Policy - The most important Planning Policy document that we must all adhere to, homeowners, developers, planners, Inspectors, everyone is the National Planning Policy Framework.(NPPF)  The Local Plan and its policies need to be consistent with the NPPF.  Doing a search on "river" in that document shows me that the relevant section of the NPPF is Section 15 Conserving and Enhancing the Natural Environment.  Most specifically clause 170 e) on page 49.  Building 500 homes so close to the Chess and impacting its very existence in parts is not consistent with the NPPF clause.

A few things to note, try where possible to use the words I have highlighted in bold.  It scores points with the Inspector, however, in our case we will be preceding each of those words with "not"  (ie not sound, not positively prepared etc)

You can refer to the removing of Greenbelt status to the land to the North-East of Chesham for 500 homes by its policy number SP BP2 (can be found on page 156 of the Plan).

So it's just like putting a jig-saw together, albeit quite a mundane one but worthwhile nonetheless.  

Now if you were to do a similar search on using the another word "carbon" for instance both in the Local Plan and the NPPF, you will find some interesting links, not least that the Local Plan will push up our carbon footprint by 21% which goes against the NPPF and many other national policies.  Continue along this vein using issues that you are personally concerned about, traffic, schools, healthcare etc and you will slowly build up your own meaningful submission,  With this greater understanding of the process, the info and examples that we provide on our web page on How to Respond will become more understandable and helpful to you.

We do ask all our supporters to add the following paragraph to their submission as it will add more weight to the work and more comprehensive submission that BNG put in:

I am supportive of the Brown Not Green organisation’s initiative to have the land listed as an Asset of Community Value and I feel they speak for me in respect of their objections to the draft Local Plan. Accordingly, I request that any representations made by them at any future examination in public regarding the soundness of this Local Plan be considered as an extension of my own comments herein. 

As you can see there are no shortcuts to this process, our beloved Council have made sure of that but as we are finding elsewhere that if we can prove to the Inspector that there are holes in the Local Plan, the Inspector will reject it and our Green Belt may be saved.  The more noise we make about these holes the better our case.

Whatever you eventually submit, I am sure it will be the best that you can possibly do and that will be good enough.  Please encourage as many of your friends and family as possible to submit their objections to the Plan to.

Thanks for reading this far.

​Dicky