How to make a detailed, policy-based objection
A planning application to build 93 homes on Wenny Road Meadow has been submitted. We’d like as many people as possible to object to these plans.
Objecting via the Fenland District Council website is easy. The more well-justified, valid planning reasons you can include in your written comments the more impactful your statement. Planning law calls these “material considerations”. If you’re able to back these points up with evidence and references to planning policy, your submission will be the most impactful it can possibly be.
This can take some time, but it’s well worth having a go! We’ve got lots of ideas on this page, which we have broken down into categories. Choose some you’re interested in and write about why they’re important and how you can prove that what you’re saying is well-evidenced and aligns with the council’s and the national policy.
If you think you might be short of time, feel free to submit a more simple comment instead – any objection is better than no objection.
Access to green space
Here are some ideas of things you might include in your comments:
- The National Planning Policy Framework (NPPF 99, p.28) says: “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on” unless one of three criteria are met. The first is that the space must be shown to be surplus to requirements – which it isn’t, because Chatteris is deficient in all standards of Accessible Natural Green Space. The second is that the lost open space is being replaced by something of “equivalent or better provision” – which it isn’t. The third is that the development itself is for sports or recreational use – which it isn’t. Therefore, the plans fail on all three counts and this existing open space should not be built on.
- The Cambridgeshire Green Infrastructure Strategy 2011 (p.95) states: that “Chatteris is deficient in all standards of Accessible Natural Green Space” and “at the moment there is a shortage of open space compared to the size/population in Chatteris”. This situation is likely to have worsened since that report was published, and will worsen even further as the already approved 1,250 homes at Tithe Barn and Womb Farm are constructed.
- The “Growing Fenland: Chatteris Final Report“, published in 2019, says (on p.8) that “there are some challenges in accessing the local countryside. Generally, the number of rights of way is somewhat limited. In a recent consultation ‘access to more parks and green spaces’ was highlighted as the biggest priority for local residents”.
- The “Chatteris Community Plan: Findings and Action Points” (2018) said that “there were a number of suggestions about how the environment could be improved, most notably the development of more parks and open spaces and providing more footpaths”. The report carried the recommendation that the council should: “develop more green open spaces and footpaths”.
- The “Growing Fenland: Chatteris Final Report“, published in 2019, says (on p.8) that insufficient access to green space “may be connected to some health outcomes in Chatteris being worse than national and local averages”, with 25.9% of adults being classed as obese compared to the Cambridgeshire average of 20.9%.
- The “Growing Fenland: Chatteris Final Report“, published in 2019, says (on p.11) that improving access to the outdoors was the most important issue for residents (>40% of people selected it), but none of the schemes that received funding seek to address this issue.
- The Fenland Local Plan contains objectives that the plan aims to meet. Objective 3.1 is to “preserve and where appropriate, enhance buildings, monuments, sites, areas and landscapes that are designated or locally valued for their heritage interest; and protect/enhance their settings”. Objective 3.3 says the council will “retain the distinctive character of Fenland’s landscape”. These plans neither retain the Fen Landscape nor preserve this meadow which is clearly “locally valued”.
- On 6th September, local MP Steve Barclay noted that “the pandemic has been a period when many people have spent more time outdoors, and reconnected with or appreciated to a greater degree the importance of the nature around us”. Wenny Meadow was very busy during the pandemic, with a census carried out by residents finding more than 45 people using the meadow within a one hour period on multiple occasions. Mr Barclay said he wants to “promote more nature sites with public access given the wider health benefits this offers”.
- Wenny Meadow fits every criterion for Designated Local Green Space as laid out in the National Planning Policy Framework (NPPF 101-102, p.29): reasonable proximity to the community it serves; demonstrably special to a local community, having beauty, historic significance, recreational value, tranquillity and richness in wildlife; and it is local in character and not an extensive tract of land.
- The Local Green Space Submissions Report (February 2020) for the new local plan says (on p.6) that of the 46 nominations to have land designated as “Local Green Space” within Fenland, 33 of these nominations were for Wenny Meadow. The National Planning Policy Framework (NPPF 48, p.14) says “Local planning authorities may give weight to relevant policies in emerging plans”.
- Policy LP1 of The Adopted Fenland Local Plan states: “at the heart of the strategy for Fenland is a desire to deliver sustainable growth… that brings benefits for all sectors of the community – for existing residents as much as for new ones”. We can demonstrate that The Meadow is precious to many residents in Chatteris, and that the loss of this amenity would be to the serious detriment of existing residents.
- Policy LP7 of The Adopted Fenland Local Plan states that urban extensions should “provide, commensurate with the scale of the urban extension, a network of open spaces and green infrastructure for amenity, play, sport and recreation, including allotments, local nature reserves, woodlands, green spaces, wildlife corridors and stepping stones for the migration, dispersal and exchange of wild species”. This development removes green space, to the detriment of both new and existing residents. Appendix B of the local plan goes on to say: “Natural green spaces are very important to our quality of life. They provide a wide range of benefits for people and the environment. All residential development within Use Classes C3 and C4 will be required to provide or contribute towards open space provision.”
- You may wish to research why access to natural green space is important more generally. There are some helpful resources that you can quote, such as those published by The Land Trust, The National Trust, Public Health England, and The Kings Fund.
Here are some ideas of things you might include in your comments:
All of this is taken from the developer’s own ecology report, which is the document named “ECOLOGY REPORTS (HISTORIC)” on the planning portal.
- The Fenland District Council Adopted Local Plan (LP7) cites that urban extensions should seek to provide green spaces and wildlife corridors for the migration, dispersal and exchange of wild species. This development removes green space.
- The protection and recovery of priority species is listed as a requirement of planning policy (National Planning Policy Framework paragraph 179b, p.51). There are multiple priority species on site.
- Section 40 of The Natural Environment and Rural Communities (NERC) Act requires all public bodies to have regard to biodiversity conservation when carrying out their functions.
- The Fenland Local Plan (LP19, p.77) says the council will “promote the preservation, restoration and re-creation of priority habitats, and the preservation and increase of priority species identified for Fenland in the Cambridgeshire and Peterborough Biodiversity Action Plans”. There are eleven species identified as priority species in the Cambridgeshire and Peterborough BAP on site: house sparrow, song thrush, yellowhammer, bullfinch, barbastelle bat, soprano pipistrelle bat, brown long-eared bat, noctule bat, common lizard, slow worm, and grass snake.
- A minimum of ten species of bat were recorded during the bat survey. A full list can be found in the report. Four of these species (barbastelle, soprano pipistrelle, brown long-eared bat and noctule) are Species of Principal Importance and Cambridgeshire & Peterborough Biodiversity Action Plan (BAP). The report says that the highest number of species of bats was consistently found at the monitoring locations within Wenny Meadow. The report says that: “the assemblage of bats utilising the site is diverse and included several records of species rare in the county. It is therefore considered that the site is a valuable foraging resource for bats in the local area that will be, at least partially, lost to the development”.
- The barbastelle bat is a UK Species of Principle Importance. A factsheet on the Cambridgeshire BAP website describes this species as “very rare”, and that it “is very sensitive to disturbance, together with the loss of roost-sites and food resources”. The developer’s ecology report notes that “there are very few records of this species from Cambridgeshire”.
- The Fenland Local Plan (LP19, p.77) says the council will “refuse permission for development that would cause demonstrable harm to a protected habitat or species, unless the need for and public benefits of the development clearly outweigh the harm and mitigation and/or compensation measures can be secured to offset the harm and achieve, where possible, a net gain for biodiversity.” Bats are a protected species.
- The report says that a total of thirty-one species of bird were recorded during the surveys, including eight notable species. Of the notable species, five were confirmed as breeding on site (house sparrow, song thrush, starling, dunnock and linnet), and three were confirmed as possible breeding species (barn owl, yellowhammer and bullfinch).
- Of the remaining twenty-three bird species, six were confirmed as breeding (blackbird, blue tit, chiffchaff, great tit, long-tailed tit and rook), twelve were probable breeding species, two were possible breeding species and one was considered to be non-breeding.
- The report details the loss of bird breeding sites in-depth. It discusses the loss of breeding sites in bramble, scrub, and grasses in particular.
- The report says: “The loss of this single large area of grassland, a habitat which is poorly represented in the wider landscape, is likely to have a detrimental impact on barn owls which are known to hunt over the site. Other suitable habitat within the wider landscape is present in the form of field margins and ditch banks but these are much smaller in extent and more dispersed.”
- The report says: “The site presents habitats that are less common in the wider Fenland landscape (hedgerows, woodland, scrub and scattered trees) and these habitats were widely exploited by a mixture of notable and commonly found species.
- The report says: “Using CIEEM’s standard guidance on ecological impact assessment (2018), the breeding bird assemblage recorded on site during surveys was considered to be of District importance.”
- The ecology survey confirmed the presence of common lizard, slow worm and grass snake. Presence of three species qualifies the site as a “Key Site” for reptiles (Froglife, 1999).
- The common lizard is a UK priority species, according to a factsheet from the Cambridgeshire BAP.
- The report says: “Good quality reptile habitat is limited within the surrounding area. Vast expanses of arable agricultural land dominate the landscape and the only modes of connectivity that remain are the ditches, as e.g. hedgerow and woodland are rare in the district.”
- The report says that the site is of particular county importance due to local rarity of reptiles.
- There has been no invertebrate survey, and we believe one should be carried out.
- The developer’s submission for the East Chatteris Broad Concept Plan (3.8, p.32) says that the 2014/2015 ecology reports, carried out in the course of preparing the BCP, found “811 different kinds of invertebrates”. It notes that “the site was of county importance for invertebrate community”.
- The site is likely to meet the criteria for designation as a County Wildlife Site, both due to the presence of barbastelle bats and due to achieving a score of 10 for birds found on scrub land within the criteria set out by the county council.
- The National Planning Policy Framework (NPPF 120b, p.35) says that planning policies should “recognise that some undeveloped land can perform many functions, such as for wildlife, recreation, flood risk mitigation, cooling/shading, carbon storage or food production”.
- The National Planning Policy Framework (NPPF 179) says that plans should “identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity”. It goes on to say that plans should “promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species”.
- You may want to talk about research from The Wildlife Trust explains the health benefits of having access to nature and wildlife.
Here are some ideas of things you might include in your comments:
- As COP26 approaches, the world’s attention is focusing on climate change and environmental concerns. Building on greenfield sites is damaging to the environment in comparison to the development of brownfield sites.
- Additional developments in Chatteris, which does not have a railway station and has no evening public transport provision, will result in more car journeys – and more pollution – than an equivalent development in any of the other Fenland towns.
- The meadow floods on a regular basis, and building upon it could put other homes on Wenny Road and Cricketer’s Way at risk.
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Local Infrastructure and Amenities
Here are some things you might include in your comments:
- 1,000 homes have been approved at Tithe Barn and 250 homes have been approved at Womb Farm. Combined, these developments already increase the size of Chatteris by 27.5% in comparison with the number of households in Chatteris at the time of the 2011 census.
- A frequent complaint within the town is that the GP surgery is very busy and unable to cope with demand, with this matter being a topic of discussion at several Town Council meetings (June 2021, September 2021).
- The “Chatteris Community Plan: Findings and Action Points” report from 2018 said: “Chatteris residents were very concerned about the availability of doctors and the difficulties of getting in a prompt appointment at the surgery. Overwhelmingly people took the view that the current surgery (and number of staff) needed to be expanded to cope with the growth in demand.”
- In their “HEALTH IMPACT ASSESSMENT”, the developer says that “with the new health centre in place, the proposal would not significantly impact upon the provision of other existing health services in the local area or result in an under-provision of services for the existing and proposed population” The health care centre referred to by the developer was due to be built as part of the Tithe Barn, but this was removed from the scheme in favour of a monetary contribution towards healthcare. Therefore, the health impact assessment cannot be correct.
- There is no dentist accepting NHS patients within Chatteris.
- The applicant’s “HEALTH IMPACT ASSESSMENT” appears to assess capacity for both the GP surgery and dentists assuming only 93 new homes above today’s baseline, and fails to include the 1,250 homes already approved at Tithe Barn and Womb Farm.
- The applicant’s “HEALTH IMPACT ASSESSMENT” says that the town’s secondary school, Cromwell Community College, has spare capacity for 161 pupils. According to Ofsted, the spare capacity is now just 81 pupils. The report makes no attempt to take into account the education needs of the 1,250 new households approved for Tithe Barn and Womb Farm.
- The “Chatteris Community Plan: Findings and Action Points” report (2018) says that there were “critical comments about the lack of adult education provision, especially in the evening”.
- Chatteris has insufficient leisure facilities to support its existing population. For example, there is no public swimming pool and swimming lessons at the community pool are often already oversubscribed. The “Chatteris Community Plan: Findings and Action Points” report (2018) says that “when asked about desired improvements to social activities, many people mentioned the need for improved swimming facilities”.
Traffic and Transport
- The National Planning Policy Framework was updated in July 2021. The new version includes a new requirement (NPPF 73, p.20) for developments to provide a “genuine choice of transport modes”. Given that Chatteris has an extremely limited evening bus service, there are no cycle routes into or out of the town, and there is no train station it is impossible to see how this condition is met. This is of particular concern because the “Chatteris Community Plan: Findings and Action Points” report (published in 2018) found that about a quarter of respondents travelled out of the town for work. The report said: “Most people travelled at least 20 miles to get to work and it was clear that for most of these it was not possible for them to find a similar job in Chatteris.”
- The additional traffic puts pupils at the new primary school on Wenny Road at increased risk.
- The proposed access roads from Wenny Road are unsuitable, due to the curvature of the road, and would require the destruction of many trees to create sufficient “splay”.
- The additional burden of the traffic from this development would put further pressure on the junction onto Ireton’s Way, and make access out of Cricketers Way more difficult.
- This development would further exacerbate the problem of out-commuting described in the Fenland Local Plan (p.8) which says: “Growth in employment in Fenland has not matched workforce expansion and outcommuting is increasing. Currently, almost 40% of Fenland’s working population commute out of the district for work. To meet the needs of the growing workforce, Fenland requires growth in employment land and business opportunities, leading to an improved range of jobs for everyone. To achieve this, infrastructure needs to be improved to retain and attract employers, and the district needs to keep its presence and appeal in front of potential investors.”
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- Due to the reduction in site size (from the East Chatteris Broad Concept Plan, covering many fields, to a single field) the capacity of the Birch Fen Awarded Drain will not be exceeded. However, it is very likely capacity will be exceeded if/when Phase 2/3 of the BCP go forward – making these developments less attractive.
- The current application should take into account surface water management in later phases of the Broad Concept Plan.
History and Archaeology
Here are some things you might include in your comments:
Architectural and social history
- The meadow is the former Manor Park, that was attached to Chatteris’ Manor House. Evidence suggests it was deliberately designed as an early 1800s landscape park, very much like that imagined in Jane Austen’s Mansfield Park, and a similar idea to the park at Holkham Hall. LIDAR imaging shows evidence of “tree rings” consistent with a managed landscape park of that era.
- The meadow appears almost entirely unchanged since the 1888 Ordnance Survey (25 inch) map of the area. The land consists of open park land surrounded by a shelterbelt of trees, which appear in the 1888 map, in an early 1900s photograph and still exist to this day.
- Countless newspaper articles between 1868 and 1954 show that the Manor Park was used for the likes of the Chatteris Shire Foal Society annual show, Temperance Society demonstrations, Galas, Sports Days and Sunday School picnics. It appears that it has long been used as a community space.
- The loss of the meadow would have an impact on the setting of the associated Grade II Listed buildings that surround it: the Manor House, the ice house, various outbuildings, and even the wall surrounding the Manor House which is listed in its own right.
- An earthwork survey by Oxford Archaeology East shows surviving and widespread medieval ridge and furrow earthworks across the meadow. These are also visible on LIDAR surveys of England, and extend to adjacent fields lying north of the meadow. The Oxford Archaeology East report lists the ridge and furrow earthworks as being between 1066AD and 1539AD.
- In her talk to Chatteris Past, Present & Future, Dr Sarah Spooner, Associate Professor in Landscape History & Engagement at UEA, said that such ridge and furrow earthworks are relatively uncommon in the Fens.
- Francis Pryor, the archaeologist who discovered Flag Fen and used to appear on Channel 4’s Time Team, described plans to build on Wenny Meadow as “nothing short of landscape vandalism“.
General Planning Policy Points
Here are some things you might include in your comments:
The target number of houses in the local plan
- The Fenland Local Plan (LP4, p.19) says that the target number of houses for Chatteris is 1,598. This target has already been met thanks to the developments that have taken place at Treeway and Lancaster Way along with the approved developments at Womb Farm, Tithe Barn, and West Street.
Section 106 payments and affordable housing
- The applicant has only offered £28,000 in Section 106 payments towards local amenities, which equates to £300 per dwelling.
- The applicant has only offered 10% affordable housing, despite the Fenland Local Plan (LP5) stating that for sites of 10 or more dwellings there should be 25% affordable housing.
- The report passed by Fenland District Council’s planning committee when approving the East Chatteris Broad Concept Plan said that “further public consultation will be undertaken when a planning application is submitted”, but no new public consultation is taking place.
- The public consultation referenced by the developer in their application took place in July 2016. That consultation is now more than five years old. The context of this application has changed a lot since then. A new primary school has been built nearby, increasing the number of journeys children are making on-foot in the area, and the 1,250 new houses at Tithe Barn and Womb Farm have been approved since the 2016 consultation took place.
Risk that the East Chatteris Broad Concept Plan is not delivered in full
- An agent acting on behalf of landowners, Peter Humphrey, has submitted a comment to the planning portal complaining that “there has been no communication with adjoining land owners prior to the submission”. He goes on to say that “this application appears to be a ‘stand alone’ application without any consideration for the Master Plan for the whole BCP area” and that there “is no ‘connectivity’ with ALL adjoining sites”.
- Failure to consider drainage issues across the site as a whole could result in this application for 93 homes on Wenny Meadow rendering the wider East Chatteris Broad Concept Plan as economically unviable, and therefore undelivered.
- Mr Humphrey also expresses concern that the applicant could be “cherry picking” the best bits of the wider development plan, something explicitly prohibited by policy LP7 of the Fenland Local Plan.
Submitting your objection
You’ll need to enter your personal details, choose some reasons why you’re objecting from the list, and then paste in your comment.
Make sure you pick the “object” option when the form asks for your stance.
Tips and advice:
- Try to avoid simply copying and pasting information from this page – the more personal you can make your comments, the more impactful they will be.
- Please be polite.
- Don’t accuse the developers or councillors of wrong doing, working for financial gain, etc.
- Multiple people in one household can submit an objection (we think you may have to be over 18, but this isn’t clear).
- If you later decide you want to write a more detailed comment, you can submit a second objection (but please don’t abuse this or make too much work for planning officers).
- The form on the Fenland planning portal “times out” after a period of time. If you are writing a long submission, we suggest writing it in a separate application and copying it into the form before you send it.
- If you have any problems (e.g, the Fenland website isn’t working) follow the instructions for submitting via email. They are a little further down this page.
If your submission is longer than 2,500 characters, includes formatting (section headers), or you want to submit photos, diagrams, or other evidence
The form on the Fenland District Council website only permits 2,500 characters to be submitted. It doesn’t allow any formatting like headings, etc, and it doesn’t allow you to submit attachments.
If you want to do any of these things, you need to either email or post your submission to the council. They should then upload your submission to the planning portal within a few days.
You must quote the application reference “F/YR21/0981/F” and you must include your postal address in your email or letter.
Send your comments via email to email@example.com
Send your comments via post to: Development Services, Fenland Hall, County Road ,March, PE15 8NQ
We recommend that you keep an eye on the documents page of the planning portal to ensure your comment gets uploaded. If it hasn’t appeared within a week or so, you should check that the council has received it successfully. If you need any help, contact us.
Campaign’s plan of action
- Engage with Fenland District Council, and organise letters (and petitions) to demonstrate the strength of feeling in the town.
- Request a site visit to demonstrate the beauty of the place
- Conduct tree “audit” and examination of Tree Preservation Order status (TPO)
- Write to local MP
- Raise awareness in the town through posters, contact cards, leafletting, door-to-door petitioning, events, press coverage, etc
- Seek out potential funding solutions for purchase of the site and ongoing upkeep…
- National bodies who may be able to help us with the campaign, or provide funding to purchase the meadow e.g:
- National Trust
- Woodland Trust
- Campaign for Protection of Rural England
- Open Spaces Society
- Lottery Heritage Funds
- Street Pride
- Wildlife Trust
- Green Party