Object

Representation ID: 14733

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Paragraph 1 - Whilst we would normally support the Council's intention to meet the identified needs for sites, we must object as the Policy contains no references to 'plots' or 'travelling showpeople' with regard to this provision.

This does not take into account of any requirement for 'plots' in the plan period, contrary to Government guidance. Again, we note that Paragraph 25 of the PPTS is clear that LPAs should be avoiding development of travellers sites that are not allocated. In this respect, this policy is 'unsound' in it does not allocate enough sites to meet its needs, both from pitches and plots. To correct this, we request that travelling showpeople's provisions are included in the Policy, alongside allocated sites (including land at Chequers Road).

Object

Representation ID: 14734

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Paragraph 2 - Object to the Council's approach to identify the provision via both allocations and through the grant of planning permissions. In particular, PPTS Paragraphs 9 and 10 are clear that the Council must identify deliverable sites for the next 5-years (which in Paragraph 7.79 of the same section indicates to be some 59 pitches). This is reinforced in Paragraph 25 where it indicates LPAs should strictly limit the development of new traveller sites are not allocated in the Development Plan. We therefore request that allocations for the next five-years, and also for 6-to-10 years are identified in accordance with this guidance. The land at Chequers Road should be allocated in this respect.

Object

Representation ID: 14735

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

The policy as a whole does not identify any 'plots' and does not identify sufficient 'pitches' for the demand, and in particular, provides no allowance for any issues arising from sites that are allocated but do not come forward for a variety of reasons. As with housing allocations, NPPF Paragraph 47 sets out additional buffers should be incorporated into the plan for housing, and we consider the same should also apply to 'pitches' and 'plots'. We therefore consider that that this paragraph of the draft Local Plan is 'unsound' in respect of both the NPPF and PPTS, in ensuring appropriate provision is planned for. We request the Council provide for such provision, as allocated sites.

Object

Representation ID: 14736

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Criteria of Paragraph 2 - We object to this paragraph generally, as it does not reflect the criteria for considering planning applications as set out in Paragraphs 24 and 26 of the PPTS.

Object

Representation ID: 14737

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

We object to Criteria a, on the basis that travelling showpeople's sites are incompatible with being located in well-settled locations. Paragraph 7.78 of the draft Local Plan already acknowledges that much of the Borough is Green Belt, and there are limited options for sites. We consider the client's site [ Land at Chequers Public House,South Weald] to be a suitable brownfied site and we therefore request its allocation as a showmen's yard.

Object

Representation ID: 14738

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Object to criteria b, on the basis that this reflects a requirement only for other travellers, but it is clear from guidance and elsewhere that showmen's yards should not necessarily be located immediately adjacent to residential neighbourhoods given their mixed-use nature. The GTAA specifically indicates in Paragraphs 4.35-4.37 that there is no benefit for having shops or a bus stop near to the site, and a preference of showpeople to live in Green Belts in Paragraph 4.58 given the reduction in conflict with neighbouring uses. When taking this together with the separation requirements as emphasised in the Showmen's Guild's model standards [see full text, Section 6], it is clear that 'well-related' is not appropriate when considering the needs of showpeople. We request this criteria is deleted.

We request other criteria are also included, particularly those set out in the PPTS.

Object

Representation ID: 14740

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

This Policy makes no reference to the 'significant material consideration' of any planning application where the LPA cannot demonstrate a 5 - year supply of deliverable sites (Paragraph 27 of PPTS). We consider the policy as a whole is therefore 'unsound' as it does not ensure the Council maintains a five year deliverable supply as well as a 6 to 10 year developable supply, or adequately address planning applications in the absence of sufficient allocations, contrary to the PPTS.

Object

Representation ID: 14746

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Paragraphs 3 and 4 - Object to these paragraphs, as there is only a reference to an allocation of six pitches, and does not allocate any 'plots'. It is therefore considered to be 'unsound' when considered against the requirements set out in the PPTS, particularly Paragraphs 9 & 10. We request that the policy properly identify enough pitches and plots, to meet both a five-year deliverable and 6-to-10 year developable requirements of the PPTS. We request that land at Chequers Road [See full text for site plan] be allocated for a showmen's yard for these purposes.

Object

Representation ID: 14750

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Paragraph 7.79 refers to the GTAA, and the need for 84 pitches, but it does not indicate the need for plots in Brentwood. We therefore object to this paragraph. We request that references to unidentified needs, including those determined via market signals, and through a 'Duty to Cooperate', will be pro-actively addressed by the Council.

Object

Representation ID: 14754

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Object to Paragraph 7.82. While the Council may have been able to identify windfall sites in the past, the PPTS is clear in Paragraphs 9 & 10 that the Council should be identifying and allocating sites, and when coupled with Paragraph 25 of the PPTS (restricting development on unallocated sites), it is absolutely clear from the Government's advice that Policy 7.10 should be allocated pitches and plots based on needs. We therefore consider Paragraph 7.82 to be 'unsound', and needs to be re-written in accordance with the PPTS, taking on board our requests.

Comment

Representation ID: 14770

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

request that the Council allocate Land at Chequers Public House, Chequers Road, South Weald for a showmen's yard in accordance with guidance set out in the NPPF and the PPTS. We are not asking for the site to be de-allocated from the Green Belt, but remain inside the Green Belt but also be designated for use as showmen's yard.

The Site is deliverable in the contents of the NPPF, it is PDL and it is already developed with a similar use operating at present.

We consider that the site is acceptable for use as a showmen's yard given the criteria found in the PPTS [see full text for detailed breakdown of how the site addresses each of the criteria] the draft emerging Local Plan as well as the Showmen's Guild of Great Britain's guidance. It is also found to be sustainable development within the context of the NPPF.

Comment

Representation ID: 14958

Received: 26/04/2016

Respondent: Crest Nicholson

Agent: AECOM

The policy states that Dunton Hills Garden Village is identified as a broad location for future provision to be planned in an integrated way as part of a mixed use development. Provision will be made for 20 pitches as part of this strategic allocation. We would request that this land [Crest Nicholson's land interests within the allocation for Dunton Hills Garden Village] is not considered in locations adjacent to market housing identified for the site.

Comment

Representation ID: 15283

Received: 03/05/2016

Respondent: London Borough of Havering

Welcome plans to meet its own need for Gypsy and Traveller sites within the borough. However it is unclear where these will be provided. Noted that a revised Gypsy and Traveller Accommodation Assessment is being prepared in light of new National Planning Policy for travellers Sites. Havering welcome continued dialogue and engagement as this assessment progresses.

Comment

Representation ID: 15588

Received: 10/05/2016

Respondent: Castle Point Borough Council

The Plan's provision for Gypsy and Traveller pitches is supported; however the Plan states that, due to possible changes to the definition of Gypsy and Travellers, this could change. It would be more prudent to deal with this uncertainty through a process of monitoring and review of the effectiveness of the Plan.

Object

Representation ID: 15635

Received: 10/05/2016

Respondent: Basildon Borough Council

Brentwood Borough Council have an identified need for Gypsy and Traveller pitches within the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment (GTAA). The Assessment established a need for 84 pitches for the plan period of 2013-2033. It is not clear where all of the proposed Gypsy and Traveller pitches would be located and further evidence of this should be provided. The Brentwood Borough Council Draft Local Plan recognises the recent changes made to national policy relating to Gypsies and Travellers. Policy 7.10 and the supporting text does however detail that following these changes the pitch requirement, as set out in the GTAA (completed in July 2014), may potentially be reduced.

Object

Representation ID: 15637

Received: 10/05/2016

Respondent: Basildon Borough Council

Basildon Borough Council has prepared a Gypsy and Traveller Site Potential Study, in order to identify the available supply of land for the provision of pitches for Gypsy and Travellers within Basildon Borough. This assessment was unable to identify sufficient land for such purposes, giving rise to an un-met need of 136 pitches as set out in the Council's Draft Local Plan which is currently out for consultation until 24th March 2016. In progressing their Local Plan, Brentwood Borough Council, as a neighbouring LPA to Basildon, is strongly requested to cooperate with Basildon Borough Council in helping to make provision for this un-met need, and is asked to give further consideration to evidence as to how this un-met need, or a proportion thereof, could be met within the Brentwood Borough area.

Comment

Representation ID: 15638

Received: 10/05/2016

Respondent: Basildon Borough Council

Basildon Borough Council will await the forthcoming review of the GTAA for Brentwood Borough Council which is being undertaken during 2016 in light of the national policy changes, and where the level of need for Brentwood Borough Council may be subject to change and potentially be reduced, Basildon Borough Council would ask for assistance in meeting the un-met need arising from Basildon Borough.

Object

Representation ID: 15640

Received: 10/05/2016

Respondent: Basildon Borough Council

It is also noted that within the proposal for Dunton Hills Garden Village a requirement for a 20 pitch site is included. It is good practice that sites should comprise no more than 15 pitches in order to ensure a comfortable environment which would be easier to manage. Brentwood Borough Council should therefore re-consider whether this larger site allocation is the most appropriate.

Comment

Representation ID: 15657

Received: 10/05/2016

Respondent: Basildon Borough Council

Basildon Borough Council is unable, as demonstrated by evidence to make sufficient provision for Gypsy and Traveller pitches within the Basildon Borough area, and Brentwood Borough Council is requested to consider making provision for at least a proportion of this un-met need within the Brentwood Draft Local Plan as it is progressed to submission.

Support

Representation ID: 16362

Received: 18/05/2016

Respondent: London Borough of Havering

Agent: London Borough of Havering

Welcome the Borough's approach to meet its own need for G&T. However the plan identifies a need for 89 pitches and makes provision for 22 pitches with an additional 20 proposed at Dunton Hills Garden Village. It is unclear how or where the remaining 47 pitches will be provided. It is noted that a revised G&T Accommodation Assessment is being prepared in light of new National Planning Policy for Traveller Sites. Havering would welcome continued dialogue and engagement as this assessment progresses.

Object

Representation ID: 17830

Received: 31/03/2016

Respondent: Mrs Christine Rogers

The Council's continued "Travellers" policy is also of great concern. I think that the Zone in Blackmore should continue to be utilised together with a similar site at Dunton Garden Village. These sites should certainly not be created by using existing spaces and gaps across the borough. Many residents would be greatly affected by this unforeseen and unwanted change to both their surroundings and lives.