1
The site is within the Metropolitan Green Belt and the proposed development would not align
fully with any of the exceptions set out in paragraphs 154 and 155 of the NPPF and would
constitute inappropriate development within the Green Belt. The proposed development is
considered to result in substantial harm to the openness of the site by reason of layout and
overall height and siting of the proposed development and there are not demonstrated to be
any very special circumstances sufficient to justify the harm. The proposed development would
form a harmful urbanisation of the site which would have a material adverse impact on the
openness of the Green Belt in this location. In the absence of any Very Special Circumstances
which would outweigh the harm, by reason of inappropriateness and substantial harm to
HAVPDECR (ODB Jan 2022) P1698.24 - 13th August 2025 2 of 5
openness, the proposed development is unacceptable in principle and in contrast to the
objectives of the NPPF and Policy G2 of the London Plan.
2
The proposals would, by reasons of the scale, massing, height, design, layout and loss of
original fabric of site, give rise to an unacceptable form of development, which also diminishes
the positive contribution the site currently makes to the significance of Havering-Atte-Bower
Conservation Area and adversely affect the rural character through an undue urbanising effect,
which would harm the character of the site and the significance of the Conservation Area and
would not preserve or enhance the special character of this part of the Conservation Area
contrary to Policies 26 and 28 of the Local Plan, Policy HC1 of the London Plan and the NPPF
2024.
3
In the absence of a satisfactory justification for the loss of the existing recreation facility or
demonstration of adequate replacement provision, the proposal would be contrary to Policy 18
of the Local Plan 2021.
4
The application fails to demonstrate that the proposal, having regard to the narrow road and
the poor visibility splays at the junction of Wellingtonia Avenue and Bower Farm Road, in
combination with the anticipated level of vehicle movements to and from the site, would not
result in conflict between those vehicles entering and leaving the site and other road users and
pedestrians, contrary to policies 23 and 24 of the Local Plan 2021.
5
Inadequate information has been provided within the arboricultural survey submitted with the
application to fully assess the impact on trees as a result of the development. In the absence
of definitive evidence of the impact of the development on tree numbers the development
would be materially harmful to the character and amenity of the site and surrounding area,
contrary to Policies 27 of the Local Plan and the NPPF 2024
6
Insufficient information has been submitted as part of the application in order to fully assess
the likely impact of the proposed development on Reptiles, Great Crested Newts and
Badgers. Full survey reports should be provided prior to determination in order for there to be
certainty of likely impacts on protected species, and in the absence of such information the
proposal is contrary to Policy 30 of the Local Plan 2021.
7
The application fails to make appropriate provision for affordable housing or demonstrate no
provision is required and therefore is contrary to Policy 4 of the Local Plan 2021 and the
National Planning Policy Framework, which require appropriate mitigation to address
affordable housing needs.
8
Based on the details submitted with the application, it is unclear whether the proposal would
comply with its statutory duties and its biodiversity duties under s.4 NERC Act 2006 (as
amended), in the absence of such clarity the proposal is contrary to Policy 30 of the Local Plan
2021.
1
The site is within the Metropolitan Green Belt and the proposed development would not align
fully with any of the exceptions set out in paragraphs 154 and 155 of the NPPF and would
constitute inappropriate development within the Green Belt. The proposed development is
considered to result in substantial harm to the openness of the site by reason of layout and
overall height and siting of the proposed development and there are not demonstrated to be
any very special circumstances sufficient to justify the harm. The proposed development would
form a harmful urbanisation of the site which would have a material adverse impact on the
openness of the Green Belt in this location. In the absence of any Very Special Circumstances
which would outweigh the harm, by reason of inappropriateness and substantial harm to
HAVPDECR (ODB Jan 2022) P1698.24 - 13th August 2025 2 of 5
openness, the proposed development is unacceptable in principle and in contrast to the
objectives of the NPPF and Policy G2 of the London Plan.
2
The proposals would, by reasons of the scale, massing, height, design, layout and loss of
original fabric of site, give rise to an unacceptable form of development, which also diminishes
the positive contribution the site currently makes to the significance of Havering-Atte-Bower
Conservation Area and adversely affect the rural character through an undue urbanising effect,
which would harm the character of the site and the significance of the Conservation Area and
would not preserve or enhance the special character of this part of the Conservation Area
contrary to Policies 26 and 28 of the Local Plan, Policy HC1 of the London Plan and the NPPF
2024.
3
In the absence of a satisfactory justification for the loss of the existing recreation facility or
demonstration of adequate replacement provision, the proposal would be contrary to Policy 18
of the Local Plan 2021.
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4
The application fails to demonstrate that the proposal, having regard to the narrow road and
the poor visibility splays at the junction of Wellingtonia Avenue and Bower Farm Road, in
combination with the anticipated level of vehicle movements to and from the site, would not
result in conflict between those vehicles entering and leaving the site and other road users and
pedestrians, contrary to policies 23 and 24 of the Local Plan 2021.
5
Inadequate information has been provided within the arboricultural survey submitted with the
application to fully assess the impact on trees as a result of the development. In the absence
of definitive evidence of the impact of the development on tree numbers the development
would be materially harmful to the character and amenity of the site and surrounding area,
contrary to Policies 27 of the Local Plan and the NPPF 2024
6
Insufficient information has been submitted as part of the application in order to fully assess
the likely impact of the proposed development on Reptiles, Great Crested Newts and
Badgers. Full survey reports should be provided prior to determination in order for there to be
certainty of likely impacts on protected species, and in the absence of such information the
proposal is contrary to Policy 30 of the Local Plan 2021.
7
The application fails to make appropriate provision for affordable housing or demonstrate no
provision is required and therefore is contrary to Policy 4 of the Local Plan 2021 and the
National Planning Policy Framework, which require appropriate mitigation to address
affordable housing needs.
8
Based on the details submitted with the application, it is unclear whether the proposal would
comply with its statutory duties and its biodiversity duties under s.4 NERC Act 2006 (as
amended), in the absence of such clarity the proposal is contrary to Policy 30 of the Local Plan
2021.