Policy 10.6: High Quality Design Principles

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Object

Draft Local Plan

Representation ID: 13211

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

In view of the importance attached to promoting and enhancing health and well-being in the plan's strategic objectives (SO11), an additional criterion should be added to the policy which expects new developments to promote active lifestyles (through being designed to encourage physical activity and sport) and thereby contribute to the wider health and well-being objective.

Full text:

In view of the importance attached to promoting and enhancing health and well-being in the plan's strategic objectives (SO11), an additional criterion should be added to the policy which expects new developments to promote active lifestyles (through being designed to encourage physical activity and sport) and thereby contribute to the wider health and well-being objective. The supporting text to the policy should refer to Sport England's and Public Health England's Active Design guidance
http://www.sportengland.org/facilities-planning/planning-for-sport/planning-tools-and-guidance/active-design/ which provides Government endorsed guidance (that has recently been refreshed) on how the design and layout of new developments can be planned to make communities more active and healthier.

Support

Draft Local Plan

Representation ID: 13606

Received: 23/03/2016

Respondent: Historic England

Representation Summary:

Historic England would recommend additional policy text at the bottom of criterion (f) that sensitive use of heritage assets consistent with their most appropriate conservation use (the optimum viable use) .... (policy continues) ....will be encouraged'.

Full text:

Policies 9.5, 9.6, 9.7, 10.5 and 10.6.

The Local Plan as a whole should be able to demonstrate that it sets out a positive strategy for the historic environment. This means that, on balance, the Local Plan has a positive effect on the historic environment and heritage assets. Policies throughout the plan should help deliver the conservation of the historic environment. The Council have a specific historic environment policy at Policy 9.5 'Listed Buildings', at Policy 9.6 'Conservation Areas' and Policy 9.7 'Ancient Monuments and Archaeological Remains'. Additionally, Policy 10.5 'Public Realm' and Policy 10.6 'High Quality Design Principles' also applies to the historic environment at criterion (f) regarding designated and non-designated 'heritage assets' and at criterion (g) to include information sufficient to assess the potential impact on the significance of the asset and including matters of archaeological significance.

Historic England recommends s additional text is added to Policy 10.6.
For Policy 10.6 'High Quality Design Principles' Historic England would recommend that (f) introduces the concept of optimum viable use at the end of the policy text, dealing with the most appropriate conservation use. National Planning Policy Guidance states that 'If there is only one viable use, that use is the optimum viable use. If there is a range of alternative viable uses, the optimum use is the one likely to cause the least harm to the significance of the asset, not just through necessary initial changes, but also as a result of subsequent wear and tear and likely future changes. The optimum viable use may not necessarily be the most profitable one (guidance continues). Reference is Paragraph: 016Reference ID: 18a-016-20140306 dated 6 03 2014.
Historic England recommends additional suggested text as underlined.
Policy 10.6.(f)
Historic England would recommend additional policy text at the bottom of criterion (f) that sensitive use of heritage assets consistent with their most appropriate conservation use (the optimum viable use) .... (policy continues) ....will be encouraged'.

Support

Draft Local Plan

Representation ID: 15181

Received: 28/04/2016

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Representation Summary:

The provision of a new self-sustaining garden village presents the unique opportunity to achieve the full range of high quality design principles in an integrated and inclusive manner.
The early evidence base prepared on behalf of the Promoters confirms how Dunton Hills Garden Village will be able to deliver all the principles of high quality design listed in policy 10.6.

Full text:

See attached

Attachments:

Support

Draft Local Plan

Representation ID: 15357

Received: 05/05/2016

Respondent: Countryside Properties

Agent: Colliers International

Representation Summary:

Agree that a high quality design is required for all developments, as it is an integral part of ensuring the delivery of sustainable development, as set out in the NPPF
Policy provides sufficient flexibility for the design of development to be guided through individual circumstances rather than being dictated by strict policy requirements. However, we consider that justification in respect of certain criteria, such as f) and g) should only be required by proposals for new development where the particular issues are material to the application. This is in accordance with Paragraph 59 of the NPPF.

Full text:

see attached

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Comment

Draft Local Plan

Representation ID: 15684

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

It is considered that requirements contained within Policy 10.6 are sought to be addressed elsewhere in the DLP, and therefore can be removed for this Policy wording. Notably:

- Part (g) - Policy 9.5 addresses designated heritage assets
- Part (n) - Policy 10.4 considers the quality and design of new developments; and
- Part (p) - Policy 10.3 concerns sustainable construction and energy requirements.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15871

Received: 23/03/2016

Respondent: Sainsbury's Supermarkets Ltd

Agent: Indigo Planning

Representation Summary:

There are a number of prescriptive design policies. These design policies should reflect the guidance set out in the NPPF on design in terms of contributing positively to making places better for people.
The requirement to provide a thorough site and context appraisal for all developments is excessive. Any assessment of a development proposal against policy should be proportionate to what is being proposed.

Full text:

We write on behalf of our client, Sainsbury's Supermarkets Ltd (SSL), to submit
representations in relation to the draft Brentwood Local Plan, currently out on
consultation.
SSL currently operate a supermarket at William Hunter Way. As a result, they are keen to be involved in the Local Plan process.
Brentwood Draft Local Plan 2013-2033
Policy 4.2 states that provision will be made for 7,240 new homes to be built in the borough between 2013-2033. SSL welcome this proposed housing target which will help to address the borough's housing needs.
Policy 6.5 identifies Key Gateways and states that development proposals in the vicinity of these areas will contribute to enhancing a positive impression of the Borough. It should be recognised that there is a limitation to the extent to which some developments can contribute to enhancing the local area due to their nature and function.
Figure 6.1 identifies the location of these Key Gateways however it is of such a scale that it is not possible to clearly identify their boundaries. Each "Key Gateway" shown in this figure covers a wide area of land. A "Key Gateway"
should be a specific defined entrance or link, not an extensive wider area. This
figure should be amended accordingly.
It appears that the SSL site forms part of one of the Key Gateways. Given its
function as a supermarket and car park, much of which is set back from William
Hunter Way, SSL object to the store being included in the Key Gateway boundary and the boundary should be amended accordingly.
The boundary of the Brentwood Town Centre Conservation Area currently includes the southern frontage of William Hunter Way. This boundary should be
amended to exclude this area as there are no factors of special architectural or historic interest in this area that merit protection.
The requirements of Policy 10.3 in relation to Sustainable Construction and Energy are overly prescriptive. Whilst sustainability should be encouraged, policy should not be so prescriptive that it could comprimise the viability of new developments. Smaller scale developments such as extensions and small
refurbishements are unlikely to be able to achieve these targets. As such, a
flexible approach should be applied. The requirement to submit a Water Sustainability Assessment should be deleted as it places yet another unnecessary burden on developers.
There are a number of prescriptive design policies. These design policies should reflect the guidance set out in the NPPF on design in terms of contributing positively to making places better for people.
The requirement to provide a thorough site and context appraisal for all developments is excessive. Any assessment of a development proposal against
policy should be proportionate to what is being proposed.
Policy 10.8 states that new development proposals are expected to provide functional on-site open space and/or recreational amenities or where appropriate, financial contribution towards new or improved facilities nearby with the amount and type of provision required being determined according to the size, nature and location of the proposal. The wording of this policy suggests that all development will be required to make some provision regardless of what type of development is proposed. Provision of open space or recreational amenities is not always appropriate or necessary in order to make development acceptable. As such, this policy should be re-worded to make clear that in the provision of open space will be required where Regulation 122 compliant.
We trust that these representations will be taken into account in the next iteration of the Local Plan, however should you have any queries please do not hesitate to contact me or my colleague Helen McManus.

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