26/00912/OUT
Great Bromley Parish Council objected for the following reasons:
The proposals conflict with the settlement strategy and represent unjustified countryside development;
The scale of development is disproportionate to Bromley Cross;
The applicant’s own LVIA identifies permanent adverse landscape harm;
The proposals would harm the dispersed rural settlement pattern;
The site is not in a genuinely sustainable location;
Existing public transport provision is limited and does not justify development of this scale;
Reliance on future Garden Community infrastructure is not an adequate basis for approval;
The enabling development case requires rigorous independent scrutiny;
The absence of policy-compliant affordable housing has not been justified;
Drainage, groundwater and surface water matters remain unresolved;
Health, infrastructure and practical accessibility have not been adequately resolved;
Habitats Regulations matters must be secured before any permission is granted;
Community concerns have not been overcome;
Designing out crime and public safety have not been properly embedded;
The application material is internally inconsistent and should not be determined in its present form; and
The application is not supported by Historic England.
Formal Objection Letter
To: Planning Services
Tendring District Council
By email
Date: Friday 10 July 2026.
Dear Planning Officer,
Objection to Planning Applications 26/00910/OUT & 26/00912/OUT
Land at Bromley Cross / Carringtons Road, Great Bromley, Essex
This objection relates to both:
Application 26/00910/OUT — outline application for up to 200 dwellings, together with local community facility, public open space, children’s play areas, allotments, community orchard, mobility hub, landscaping, drainage and infrastructure; and
Application 26/00912/OUT — outline application for up to 90 dwellings, together with local community facility, public open space, children’s play areas, allotments, community orchard, mobility hub, landscaping, drainage and infrastructure.
The two applications should not be considered in isolation. The applicant’s own Transport Assessment states that it considers two development options, comprising both a 90-dwelling and 200-dwelling scheme, dispersed across the same two parcels of land, with the same site boundary for both schemes. The applicant’s Travel Plan also states that the outline planning applications consider two varying scales of development: 90 dwellings and 200 dwellings. The Habitat Regulations Assessment confirms that two alternative scheme options are being advanced through parallel planning applications and that the 200-dwelling scheme has been assessed as the maximum development scenario.
For the reasons set out below, planning permission should be refused.
1. The proposals conflict with the settlement strategy and represent unjustified countryside development
The site lies outside the defined settlement boundary / main village envelope. The applicant’s Planning Statement for the 200-dwelling proposal acknowledges that the site is located outside the formal Settlement Development Boundary. The Design and Access Statement for the 90-dwelling proposal also describes the site as outside the main village envelope and adjacent to the dispersed rural settlement of Bromley Cross.
This is not a modest infill proposal. It is not a small-scale rural exception or organic rounding-off of the settlement. It is substantial residential development on agricultural land outside the settlement boundary.
The applicant’s own Design and Access Statement describes Bromley Cross as a small settlement of 69 houses centred around the crossroads and the pub. Against that baseline, even the 90-dwelling scheme would exceed the existing scale of the settlement described by the applicant. The 200-dwelling scheme would be transformational and plainly disproportionate.
The applications therefore fail to respect the adopted settlement strategy and would result in a major planned residential estate in the countryside. The fact that the Council may be unable to demonstrate a five-year housing land supply does not mean that any site outside a settlement boundary becomes acceptable. The tilted balance remains a site-specific assessment. It does not remove the need to consider the actual harm caused by the particular development proposed.
2. The scale of development is disproportionate to Bromley Cross
The proposed development would fundamentally alter the scale, form and identity of Bromley Cross.
The applicant seeks to characterise the development as landscape-led and reflective of the local dispersed settlement pattern. That position is not credible when assessed against the scale of the existing settlement. The applicant’s own evidence describes Bromley Cross as a settlement of only 69 houses.
On any reasonable assessment:
• the 90-dwelling proposal would be larger than the existing settlement described by the applicant; and
• the 200-dwelling proposal would amount to a wholly disproportionate new residential estate in a rural location.
This is not sensitive village growth. It is a substantial expansion into the countryside which would materially change the relationship between Bromley Cross, Carringtons Road and the surrounding agricultural landscape.
The 2021 Census shows 1,108 inhabitants in Great Bromley and the proposed development will significantly increase that population, possibly doubling it. Given the number of existing houses in Great Bromley, the proposed development is “high density” and thus inappropriate to the rural location.
Both proposed plans lack sympathy with the existing environment with minimal buffer/green zones around the perimeters.
3. The applicant’s own LVIA identifies permanent adverse landscape harm
The applicant’s own Landscape and Visual Impact Assessment provides clear evidence of harm.
The 200-dwelling LVIA places the site within Landscape Character Area 7A: Bromley Heaths, within an open rural plateau landscape characterised by productive agricultural fields, low-density rural settlement, narrow lanes and a “dramatic dominant skyscape”. It records that the area is visually sensitive because of its open and rural character and long views.
The LVIA accepts that development of the site would result in the loss of agricultural landscape and that the dispersed settlement pattern would be adversely affected by the scale of the proposed development.
For the 200-dwelling proposal, the LVIA identifies:
• effects on the study area as moderate adverse and permanent at Year 1 and Year 15; and
• effects on the site itself as major / moderate adverse and permanent at Year 1 and Year 15.
That is a significant admission. This is not a case where mitigation removes the harm over time. The applicant’s own evidence confirms that adverse landscape effects remain permanent even at Year 15.
The 90-dwelling LVIA does not overcome the issue. It identifies the same rural landscape context, including agricultural fields, mature hedgerows, dispersed rural settlement, open agricultural landscape, narrow rural lanes and the Bromley Heaths character area. It also states that the site is in agricultural use with a character consistent with the local landscape character area, and that development would result in the loss of agricultural landscape. [TRANSPORT_...26-2303534 | PDF]
The Council should attach substantial adverse weight to this harm.
4. The proposals would harm the dispersed rural settlement pattern
The applicant’s landscape evidence acknowledges that the dispersed settlement pattern would be adversely affected by the proposed development. [TRANSPORT_...26-2303534 | PDF]
That point is central. Bromley Cross is not a large village or urban edge location. It is a small rural settlement set within an agricultural landscape. The proposed development would not reinforce that character. It would materially alter it.
The proposed estate form, associated infrastructure, accesses, internal roads, parking, public open space, lighting, movement routes and community facilities would introduce an urbanising form of development into a rural context. That harm cannot be dismissed simply because parts of the site are bounded by existing vegetation or because new landscaping is proposed.
5. The site is not in a genuinely sustainable location
The applicant’s transport evidence demonstrates that the site is in a low-connectivity rural location.
The Transport Assessment identifies the site as around 8km from Colchester and around 7km from Manningtree. It records that St George C of E Primary School is approximately 2.3km from the site, that health facilities at Parsons Heath / Greenstead are around 5.7km to 5.8km away, and that Colchester Railway Station is approximately 9km from the site.
The Transport Assessment also states that there is no dedicated cycle infrastructure within the vicinity of the site or in Great Bromley. It further states that Carringtons Road does not currently benefit from walking or cycling provision, and that Hall Road has no pedestrian provision.
The Travel Plan classifies the site as a low connectivity location for parking purposes.
The applicant relies on cycling, walking, future bus improvements and a mobility hub. However, those measures do not change the baseline position: this is a rural location with limited current pedestrian and cycling infrastructure and restricted public transport frequency.
6. Existing public transport provision is limited and does not justify development of this scale
The Transport Assessment records that bus stops are approximately 450m from the site, but the actual service frequency is limited. It identifies service 105 as providing seven services a day and no Sunday service, service 107 as providing two services a day and no Sunday service, and services 77A and 721 as providing only one service a day with no weekend service.
The Travel Plan also records that Colchester Railway Station is approximately 9km from the site, requiring an approximate 36-minute cycle journey or 40-minute multi-modal bus journey.
This is not the profile of a site that can accommodate major housing growth without material reliance on private car travel. The proposed level of development would inevitably increase car dependency and vehicle movements on rural roads.
7. Reliance on future Garden Community infrastructure is not an adequate basis for approval
The applicant places weight on the future Tendring Colchester Borders Garden Community, stating that its future infrastructure, facilities, active travel links and rapid transport provision would improve the sustainability of the area.
That does not make this application acceptable now.
The Council must assess the applications on the basis of existing and secured infrastructure, not aspirational future improvements coming forward through a separate strategic development. The applicant has not demonstrated that the proposed homes would be served by a sufficiently robust, deliverable and secured package of active travel, public transport and local service infrastructure at the point of occupation.
8. The enabling development case requires rigorous independent scrutiny
The applicant relies heavily on the assertion that the residential development is required as enabling development to fund heritage works at St Osyth Priory. The 200-dwelling Planning Statement states that the proposal comprises enabling development to secure the long-term conservation and viable future of nationally significant heritage assets at St Osyth Priory.
The Heritage Impact Assessment states that enabling development is proposed to secure the long-term conservation and viable use of St Osyth Priory and that the proposals have been informed by an assessment of the conservation deficit.
However, enabling development must be necessary, proportionate and the minimum required to secure the heritage benefit. The submitted heritage material itself refers to the need to test the amount of enabling development required to resolve the deficit and identifies that the essential test is that enabling development should be the minimum possible required to address the deficit.
Furthermore, the AMION material referred to in the Heritage Impact Assessment records that the 200-unit “Mid Option” generated a Benefit Cost Ratio of 0.89, representing “poor” value for money, and states that the surplus generated by the 200-unit Mid Option remains insufficient to support addressing the identified conservation deficit.
That is a serious issue. If the 200-dwelling proposal is itself insufficient to resolve the conservation deficit, then the Council must understand precisely:
• what heritage works would be funded;
• when those works would be delivered;
• how they would be legally secured;
• whether the residential development is genuinely necessary;
• whether the scale proposed is the minimum necessary; and
• whether the claimed heritage benefits are sufficiently certain to outweigh the identified planning harms.
Without that clarity, the enabling development case cannot safely be relied upon to justify major countryside housing development.
9. The absence of policy-compliant affordable housing has not been justified
The 200-dwelling Planning Statement accepts that Local Plan Policy LP 5 expects 30% affordable housing, but states that because the proposal is promoted as heritage enabling development, there is no requirement for policy-compliant affordable housing.
That is a significant planning harm. The applicant is seeking permission for major residential development outside the settlement boundary, with acknowledged permanent landscape harm, while also seeking to avoid the normal affordable housing requirement.
That position should not be accepted unless supported by transparent, independently tested viability and enabling development evidence, with clearly secured heritage outputs. The Council should not allow the enabling development case to be used as a broad justification for setting aside normal development plan requirements without rigorous scrutiny.
10. Drainage, groundwater and surface water matters remain unresolved
The Flood Risk Assessment identifies that the site currently has no positive surface or foul water drainage systems and that irrigation ditches and field boundary drainage channels run across the site. It also states that the estimated position and depth of the ditches are to be confirmed by a full topographical survey before construction.
The FRA records that all three soakaway tests failed, that groundwater monitoring is ongoing, and that infiltration via soakaway structures is not viable.
It also identifies localised surface water flood risk and recommends further investigation of the surface water drainage network at the proposed vehicular access point.
These are not matters that should simply be left to post-permission detail. They go directly to the acceptability and deliverability of the proposed development, particularly given the scale of the proposal, the rural drainage context, the failed infiltration testing and the reliance on existing ditches and attenuation.
11. Health, infrastructure and practical accessibility have not been adequately resolved
The Health Impact Assessment for the 90-dwelling scheme states that the health profile of Bromley Cross and Great Bromley is shaped by rural accessibility, transport dependence and safe movement to essential services. It also states that access to schools, GP provision and dental services should be assessed not only by distance, but by the practicality of journeys for children, older people, disabled residents and households without private cars.
That is a material point. Given the low-connectivity location, limited bus frequency, lack of dedicated cycle infrastructure and lack of pedestrian provision on relevant roads, the Council should require robust application-specific assessment of health, education, service access and infrastructure capacity.
The issue is particularly acute for the 200-dwelling proposal, where the Health Impact Assessment material reviewed in the application pack referred to a proposal of up to 90 homes, rather than the 200-dwelling scheme.
12. Habitats Regulations matters must be secured before any permission is granted
The HRA confirms that Tendring District Council is the competent authority and that the assessment is required to inform the Council’s duties under the Habitats Regulations. It also states that the HRA process is based on the precautionary principle, and that where uncertainty or doubt remains, an adverse effect should be assumed.
The Council must therefore ensure that all mitigation, monitoring and legal obligations required to avoid adverse effects on protected habitats sites are secured before any planning permission is granted. This is particularly important because the HRA assesses the 200-dwelling scenario as the maximum development case while the two schemes are being advanced in parallel.
Badgers
Badgers and their setts are protected under the Protection of Badgers Act 1992, Schedule 6 of the Wildlife and Countryside Act 1981 (as amended) and by the Animal Welfare Act 2006.
Planning authorities should ask for a survey if either historical or distribution records show badgers to be active in the area, if there are signs of setts or badgers on the development site or nearby, or if there is suitable habitat for sett building or foraging by badgers at the location (Badger Trust).
With no mention of badgers in the Appraisal, it can be assumed that there has not been any effort to check records or badger activity or evidence in the area. Badger latrines have been found in the past within one hundred metres of the proposed development site.
Barn owls
Protected under The Wildlife and Countryside Act 1981. It is well known that barn owls are present and breeding in the area. As this species is not mentioned anywhere within the Appraisal then it is evident that no attempt has been made to check records of their activity in the area.
Common toads
Under section 41 of the NE and RC (NERC) Act 2006 the common toad is designated as a species of principal importance in England. Developers and local councils use standing advice to mitigate impacts on toads such as protecting migration routes and creating suitable breeding habitats. (Froglife).
Smooth newts
While not affording the protection of GCNs they are still protected under the Wildlife and Countryside Act 1981.
Common toads and smooth newts are known to be present in the local village pond, which bounds the proposed development site off Hall Road. Toads will usually return to the same pond where they were bred (Froglife).
Great Crested Newts
Great Crested Newts are protected under the Wildlife and Countryside Act 1981, The Conservation of Habitats, and species Regulations 2017 (European Protected Species).
Section 2.10 Page 24 of the Ecological Appraisal states that ‘due to the absence of suitable breeding habitat within 250m of the Site and the retention of boundary habitats including hedgerows and grass margins, the scheme will not impact upon GCN, and the works can proceed without the requirement for licencing. This species is not considered further within the report.’
The concern with that statement is the lack of detailed information regarding the surveying of water bodies in the area. There are only descriptions of where the ponds are located without a detailed plan indicating the exact location of these ponds. Natural England recommend that the search of records should be within 500m of the proposed development sit whereas the search according to the Appraisal has been restricted to within 250 metres.
With a development of the size proposed it is thought that more attention would be afforded such a heavily protected species.
13. Community concerns have not been overcome
The Statement of Community Involvement records that the applicant held a public exhibition on 10 April 2026, distributed leaflets to 969 properties, and had approximately 92 attendees.
The SCI records that key themes raised included overdevelopment, unsustainable location, flooding, traffic impacts, amenity and impact on local infrastructure.
A local objection submitted by Rebecca Bloomfield also raises concerns regarding conflict with the Local Plan, loss of countryside, rural character, highway safety, local infrastructure, drainage, ecology and precedent.
These concerns are not simply local preference. They align with material planning issues identified in the applicant’s own technical evidence.
The proposed access to the site in Carringtons Road is close to two sharp bends. The proposed widening of the road will not sufficiently improve safety.
Where the SCI states that completed feedback forms and email comments can be provided upon request, the Council should require the applicant to provide the full underlying feedback material so that the extent and substance of local concern can be properly understood.
14. Designing out crime and public safety have not been properly embedded
The Essex Police Designing Out Crime response states that there is no reference to security in the planning documents submitted by the applicant and requests continued engagement with the Essex Police Designing Out Crime team and the aim of achieving Secured by Design accreditation.
The Essex Police strategic response also recommends that a Crime Impact Statement should be included within the Design and Access Statement and highlights the need to incorporate Secured by Design standards and Police Crime Prevention Initiatives.
Given the proposed public open space, pedestrian routes, green corridors, community facilities and movement network, this is a material design issue. It should not be left unresolved.
15. The application material is internally inconsistent and should not be determined in its present form
There are clear inconsistencies in the submitted documents.
Most notably, the Land Use Parameter Plan submitted within the 90-dwelling application material refers to “up to 200 dwellings”.
The Transport Assessment and Travel Plan assess both 90 and 200-dwelling options across the same site. The HRA also assesses the 200-dwelling scheme as the maximum scenario while confirming that two parallel options are being advanced.
The Council should not determine either application until the applicant has clarified:
• which plans are operative for each application;
• what development quantum is being applied for under each application;
• which technical assessments relate to which scheme;
• whether the 90-dwelling and 200-dwelling proposals are alternative schemes, fallback schemes or potentially sequential / cumulative proposals; and
• how the enabling development case relates to each scheme.
In its current form, the submitted material does not provide a sufficiently clear or reliable basis for determination.
Conclusion
For the reasons set out above, the applications should be refused.
The proposals would conflict with the adopted settlement strategy, introduce disproportionate residential development outside the settlement boundary, cause acknowledged permanent adverse landscape and visual harm, rely on a low-connectivity rural location, depend on future and unsecured infrastructure, and seek to rely on an enabling development case which requires significantly greater scrutiny.
The applications are further weakened by the absence of policy-compliant affordable housing, unresolved drainage and groundwater matters, inadequate application-specific health and infrastructure assessment, outstanding HRA mitigation requirements, insufficient crime prevention evidence and clear inconsistencies in the submitted application material.
There are brown sites and previous industrial sites within Tendring which would be better used for any development.
The adverse impacts of the proposals would significantly and demonstrably outweigh the claimed benefits. Planning permission should therefore be refused.
If the Council is not minded to refuse the applications at this stage, it should at minimum require the applicant to correct and clarify the submitted material, provide application-specific technical assessments, submit independently reviewable viability and enabling development evidence, and secure all necessary mitigation and legal obligations before determination. It should also ensure that dates of each stage completion are stipulated and adhered to, the work is completed to a high standard and the actions on the promised facilities under the plan, are adhered to.
Any approval should substantially reduce the density of the both proposed developments to be in keeping with a rural location, with housing density perhaps closer to 20% of the site areas.
Great Bromley Parish Council