Fig. 5. Spatial Strategy

Showing comments and forms 1 to 8 of 8

Support

Preferred Site Allocations 2018

Representation ID: 18285

Received: 12/03/2018

Respondent: Hermes Investment Management

Agent: McGough Planning Consultants

Representation:

Hermes Investment Management supports the allocations shown at West Horndon and land south of East Horndon Hall

Full text:

Hermes Investment Management supports the allocations shown at West Horndon and land south of East Horndon Hall

Object

Preferred Site Allocations 2018

Representation ID: 18917

Received: 28/03/2018

Respondent: Miss Emily Dimond

Representation:

More assessment should be carried out on brownfield land or within larger settlements which are more accessible with better facilities, or within the larger new Dunton Hills Garden village settlement.

Full text:

1. I object to the allocations of 076 and 077 on grounds of excessive development in Blackmore Village - the proposed sites represent over 28% increase in houses in the village which is unsustainable. Of the proposed sites listed in 'Green Belt - Larger Villages' section of the LDP, nearly 70% of the proposed houses are in Blackmore and Tipps Cross Ward (116 houses out of a total of 169). This is an excessive and unwarranted increase for this small historic village which cannot be justified. In contrast neighbouring villages such as Doddinghurst have no proposed sites for development. Blackmore has limited facilities and is fairly isolated from major centres, with poor public transport services.

2. The sites 076 and 077 are Green Belt fields with the protection that designation provides - development should only be considered in exceptional circumstances. Green Belt was established to protect the boundary of built development of the village and the open countryside.

3. The proposed development will cause degradation of environment and damage to wildlife. Site 076 is home to many rare birds which are protected species such as skylark, barn owls and turtle doves which are regular visitors to the field in question.

Turtle doves have been seen and heard on the site for the past 3 years and field 076 is a known breeding site for turtle doves. The turtle dove is a Section 41 species which is of principal importance for conservation of biodiversity, and they are vulnerable to global extinction. They have suffered a 91% UK population decline since 1995. More than half the remaining turtle doves breed in East Anglia with Essex being identified as one of the important 'hotspots'. The loss of this site to housing would inevitably mean the loss of this important breeding site and further loss of appropriate habitat. Turtle doves favour wide undisturbed field margins and this is not the sort of habitat which can be incorporated into housing development. Furthermore, the fact that the site is a breeding site for turtle doves raises the question as to what other species exist there. A detailed assessment of both site 076 and 077 should be undertaken to establish the ecological importance of the sites; such assessments should not be left until the planning application is submitted as it may result in the site being undeliverable and therefore Brentwood Borough Council will not be able to meet their housing requirements in respect of these sites. It is also within a priority area for the Lapwing bird species and has records of Corn Bunting and Yellow wagtail sightings in the last 10 years which are all protected species under the IUCN Red List of Threatened Species (2010) and Biodiversity Action Plan UK listed species (Please see attachment 1).


4. The site is also recorded as a Nitrate Vulnerable Zone as of 2017, which may cause potential problems surface and groundwater contamination as a result of the proposed development (Please see attachment 2 for site designations).


5. The fact that Red Rose Lane, a narrow country lane, runs East/West to the north of the village seems to have been used to justify the allocations 076 and 077 as appropriate pieces of land.
These sites are not self-contained village infill as suggested in the LDP- the sites are on open land outside the village, and the road which is being viewed as a border -Red Rose Lane - is a narrow country lane and unsuitable for anything other than light traffic. When these sites are viewed in reality rather than on a plan, the area is open countryside and a very important part of the Green Belt.


6. Infrastructure - Red Rose Lane which borders the proposed development is a narrow country lane unsuitable for heavy traffic. Blackmore is surrounded by minor roads and is unsuited to the large increase in traffic that this development would bring. There are already problems with parking and congestion around the village shop and this will be greatly exacerbated by the proposed increase in housing.


7. Traffic - access to the sites from Red Rose Lane will be difficult and dangerous due to narrow nature of lane. In particular, if site 076 is accessed through Orchard Piece this will cause greatly increased traffic flow in what is currently a quiet cul-de-sac and will cause a danger and disturbance to current residents and their children.


8. School - Blackmore has a small primary school which is currently at capacity. Proposed development would put excessive pressure on school and facilities, and would result in insufficient spaces being available for the children of the village.


9. Health and transport - no GP surgery within parish boundary, and nearest GP surgery is full to capacity with considerable problems obtaining appointments at short notice. Bus services which link the village to Chelmsford and Brentwood are part time only.


10. Flooding - Red Rose Lane is often subject to flooding in times of heavy rain. A site immediately adjacent to field 076 (site 250 Post Field) was rejected for development on the grounds of flooding and surface water problems. Field 076 is actually lower lying and Red Rose Lane in the area of Red Rose farm has become impassable at times due to flooding. Development would make flooding worse as green field land would be lost to housing and hard-standing.

If the development attempted to address the flooding and surface water issue by the creation of a pond for instance this would make the housing targets undeliverable.




My objections are supported by the response of Blackmore Parish Council. I urge Brentwood Borough council to reconsider these allocations and retain this important section of Green Belt land. Whilst recognising the pressure for additional housing more assessment should be carried out on brownfield land or within larger settlements which are more accessible with better facilities, or within the larger new Dunton Hills Garden village settlement.

A recent study by the CPRE the State of Brownfield 2018, has highlighted that more should be done to develop brownfield rather than release greenbelt for housing.

Attachments:

Object

Preferred Site Allocations 2018

Representation ID: 19609

Received: 12/03/2018

Respondent: Mr Jon Nicholls

Representation:

We object to the strategy to rely on a new settlement to deliver a large proportion of growth. We suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations. We support the spatial strategy, as set out at paragraph 31 - prioritises using brownfield land. The capacity of brownfield sites has been fully explored and needs further work. This has resulted in site 183 being discounted. Site is already serviced by infrastructure and would support sustainable development and transport.

Full text:

In regards to Spatial Strategy: We object to the strategy to rely on a new settlement to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. Instead we suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations. Smaller allocations increase the flexibility that is in supply, attract smaller house building companies who will not be present upon larger strategic sites, ensure that there is variation in the timescales over which sites can be delivered and provide the consumer (i.e. the future resident) with choice about where they live. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have less complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver. We support the spatial strategy, as set out at paragraph 31, to focus upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with the NPPF (paragraphs 17 and 111). It is also in accordance with the draft policies in the new NPPF consultation proposals March 2018; Chapter 11 reinforces and strengthens this aim. However, we do not consider that the capacity of brownfield sites has been fully explored. The Site Assessment Methodology and Summary of Outcomes (January 2018) states that the approach was to prioritise using brownfield land first and then consider growth in settlements in terms of their relative sustainability linked to services and facilities. However, the process actually discounts sites where they are considered to be in an unsustainable location, which included sites in the Green Belt with no connecting boundary to an existing urban area, before considering the potential to exploit brownfield land. This has resulted in sites such as site 183 being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable. Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail. Paragraph 32 of the NPPF requires that: "...the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure". On this basis, it is considered that the site is sufficiently sustainable to support a small to mid-sized residential development. In regards to Dunton Hills Garden Village: We object to this policy to propose a new settlement to deliver 2,500 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged. We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF. It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example nearby Uttlesford District Council. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings. Adopting the lag of seven years and a Plan adoption date before the end of 2019 would mean there would be no deliveries on site until 2026. There are no circumstances that suggest that Dunton Hills Garden Village can deliver more quickly than the seven years recommended by the above research. As such, we object to the reliance on this site for such a large proportion of the Borough need and consider that a greater number of smaller sites should be allocated to allow for flexibility and earlier delivery. In regards to Housing Need: We object to the planned housing need on the basis that it is insufficient to meet the Borough's needs. Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The consultation document assumes a housing need of circa 380 dwellings per annum or 7,600 dwellings across the plan period (2013-33). However, the Department for Communities and Local Government consultation on the methodology for a standardised approach to calculating local housing need in England demonstrates a housing need of 454 dwellings per annum in Brentwood Borough, an increase of 74 dwellings per year over the planned figure. Whilst it is appreciated that under the current timetable the Borough are expecting to take advantage of the transitional provisions in the draft NPPF currently open for consultation, the Plan should nevertheless take account of Governments direction of travel. A cursory 'overprovision' of only 663 dwellings does not do enough to account for the significant upward housing pressure in the Borough. Whilst the transitional provisions currently open for consultation in the draft NPPF suggest that any plans submitted this year will be examined under the old (current) NPPF, the Brentwood Local Plan is still at a relatively early stage of production. We also consider the current timetable, which allows only six months to consider representations to the current consultation and publicise and submit the Regulation 19 Plan, to be extremely ambitious. As such, the deadline to take advantage of the transitional provisions could well be missed. In this instance, the Council will have to go back to Regulation 18 stage to consider the new housing need. However, planning for the higher housing need at this stage will enable for the Plan to continue to examination, even if this deadline is missed. The "fallback position", should the Council need to accommodate this significant increase in housing need, is consideration of whether the delivery of Dunton Hills Garden Village could be accelerated to increase its dwelling yield within the plan period. However, this has not been fully explored and, as set out in our comments in relation to the Dunton Hills allocation, the current anticipated delivery is ambitious, making accelerated delivery wholly unrealistic. Failing to meet the objectively assed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound. Notwithstanding the above objection to the quantum of the housing need, we also object to the proposed strategy to deliver this need. Figures 8 and 9 demonstrates how the housing need will be met. These show an intention to deliver 663 dwellings in excess of the identified need of 7,600 dwellings. However, this includes both a windfall allowance and "Forecast Forward - additional completions and permissions between 1st April 2017 and 31st March 2018". Both of these figures are uncertain and taken together total 757 which exceeds the 'overprovision' of 663 dwellings. The plan does not appear to include any non-implementation allowance, therefore, in order to meet the objectively assessed need every single extant consent, allocation, permitted development, plus the "forecast forward" and windfall allowance must come forward during the plan period in order to meet the minimum need requirement. As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF. In regards to Settlement Heirachy: Whilst we support the classification of Ingave as a "Category 3 - Large Village", we object to the inconsistent treatment
of this settlement in comparison to other settlements occupying the same level in the hierarchy. For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave. The moratorium of growth in these villages is contrary to the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities (paragraph 55). The new draft NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 80). Allocation of additional land for housing at Ingrave would not only meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.

Support

Preferred Site Allocations 2018

Representation ID: 19656

Received: 12/03/2018

Respondent: Chilmark Consulting Limited

Representation:

Barwood Land and Estates support the Spatial Strategy shown in Figure 5 (page 17). The Spatial Strategy shows a realistic overall distribution of growth. It focuses on sustainable urban locations and the best opportunities for Green Belt release in/adjacent to existing higher order settlements in order to meet identified housing and economic growth objectives of the Local Plan.

Full text:

This representation is made on behalf of our client, Barwood Land and Estates Ltd.
Barwood Land and Estates (BLEL) support the proposed allocation of Land at Honeypot Lane, Brentwood (reference 022) as a Brentwood Urban Area, A12 Corridor Urban Extension as set out at page 77 of the Local Plan. The proposed allocation follows the settlement hierarchy and proposed spatial distribution of housing set out in other plan policies and objectives. BLEL support the proposed housing allocation of Land at Honeypot Lane but raise a number of more specific comments as follows: BLEL consider that Land at Honeypot Lane has an indicative development capacity for >200 dwellings based on masterplanning and detailed site analysis/testing undertaken to date by BLEL and shared with the Borough Council. The proposed allocation information should therefore be updated accordingly for up to 250 dwellings total. The next iteration of the Local Plan Sustainability Appraisal should also take this quantum into account. BLEL note that the Honeypot Lane site is also identified as a potential location for a C2 Use Class care home and query where this indicative land use proposal originates as it has not been proposed to the Borough Council or discussed with BLEL as the development promoter to date. The reference to C2 Care Home appears to refer to paragraph 9.2.5 of the Interim Sustainability Appraisal Report that notes that there is a potential for some 40 bed space C2 Use Class provision for the site and itself purports to draw this from the latest version of the Borough's Strategic Housing Market Assessment. Land at Honeypot Lane is described as a 'self-contained urban extension' but clearly the development would be integrated with Brentwood and particularly with surrounding areas including St Faiths Country Park. Indeed, the site's location supports the potential for a high degree of integration rather than self-containment. BLEL suggest that the wording of the Local Plan text be modified accordingly in this respect. With respect to housing delivery, BLEL consider that Land at Honeypot Lane is capable of delivery within the five year period rather than in the longer 5-10 year period. The site is suitable, available and achievable and has a willing landowner, developer and investor. The potential for early delivery in the plan period has been discussed with the Borough Council and BLEL suggest that the Local Plan text be updated to reflect the ability to bring this site forward early in the plan period. Barwood Land and Estates support the Spatial Strategy shown in Figure 5 (page 17). The Spatial Strategy shows a realistic overall distribution of growth. It focuses on sustainable urban locations and the best opportunities for Green Belt release in/adjacent to existing higher order settlements in order to meet identified housing and economic growth objectives of the Local Plan. Barwood Land and Estates (BLEL) support the proposed Housing-led Allocation set out in Figure 9 (pages 26 - 27). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. Land at Honeypot Lane is a sustainable location and a deliverable housing site within the urban area of Brentwood. The site can come forward early in the Plan period without the need for extensive new infrastructure. Release of the site from the Green Belt will ensure development can be achieved in a timely manner and that this site can contribute to supplying much needed new housing in Brentwood. BLEL has undertaken an extensive and detailed technical and design analysis of the Honeypot Lane site and has concluded that the site is capable of delivering more than 200 dwellings without causing adverse effects on highways, landscape, amenity or other matters. BLEL has previously shared this analysis with the Borough Council. On this basis BLEL consider that the site is capable of sustainably accommodating up to 250 dwellings and the Local Plan should be updated accordingly at Figure 9 (and elsewhere where the Plan identifies a proposed allocation quantum for the site) to reflect this. Barwood Land and Estates (BLEL) support the proposed Settlement Hierarchy set out in Figure 14 (page 35). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. The proposed settlement hierarchy represents the current pattern of activity and forms a realistic approach to guiding future sustainable development patterns of activity and land use in the Borough. The hierarchy clearly and appropriately identifies Brentwood, Shenfield, Hutton, Warley, Brook Street and Pilgrims Hatch as 'Category 1 - Main Towns'. Barwood Land and Estates (BLEL) has reviewed the Interim Sustainability Appraisal Report (SA)
that supports the Local Plan Site Allocations and has the following comments with respect to paragraphs 10.5.4 (page 44); 10.10.2 (page 52); and the Site Appraisal of BLEL's site and Honeypot Lane, Brentwood (022) on page 81. Paragraph 10.5.4 (page 44) BLEL note that the Honeypot Lane site is proposed for a reduced level of housing (200 dwellings compared to 250 dwellings) when comparing the current Site Allocations Plan with the previous 2016 draft Local Plan. BLEL are not aware of any site specific reason why there should be a reduction and have considers (based on extensive technical assessments and site masterplanning that the site should be allocated for up to 250 dwellings. The SA should therefore be updated and revised accordingly in this respect. BLEL agree with the SA at 10.5.4 that the Land at Honeypot Lane site is associated with an opportunity to support enhanced pedestrian links through St Faiths Country Park. The SA notes at 10.5.4 that the potential for noise and potentially air pollution on the Honeypot Lane site arising from the A12 road. BLEL considers that the site's design and specific technical measures respond to the context of the site, including proximity to the A12 road and that the emerging scheme design includes appropriate buffers and mitigations for noise and air pollution amenity accordingly. The SA text should therefore be updated accordingly in this respect. A small watercourse running through the Honeypot Lane site is noted in the SA at 10.5.4 and the text highlights this as an example of the factors that will need to be taken into account in developing the site. BLEL has undertaken extensive technical analysis including physical surveys and assessments of the site and can confirm that site and surrounding area physical characteristics have been taken fully into account in concluding that the site can deliver up to 250 dwellings. Paragraph 10.10.2 (page 52) Paragraph 10.10.2 of the SA Interim Report identifies a lower level of housing delivery at Land at Honeypot Lane (and other Green Belt sites in Brentwood) as potentially having a lower landscape effect than earlier proposals and also potential for more green space on the site. BLEL's conclusion, following extensive technical analysis including landscape and visual impact assessment work is that Land at Honeypot Lane can deliver more than the 200 dwellings set out in the Site Allocations Plan and it can do so without adverse landscape effects. The site can achieve this while supporting levels of new amenity and green infrastructure to high degree. Honeypot Lane can therefore deliver more housing than the current version of the Plan identifies and can do so without adverse landscape effects given sensitive site design and the effective use of the site's natural topography and natural boundary vegetation as appropriate. Honeypot Lane Site Appraisal (page 81) BLEL note that the SA Interim Report has provided a high level sustainability appraisal of the Honeypot Lane site (page 81). BLEL concur with the analysis and note that the Site performs well in relation the analytical criterion. BLEL notes that the SA site assessment criteria covering issues such as access to primary and secondary schools and GP's surgeries is based on existing local provision and does not consider the potential future provision arising from new development as the Local Plan is implemented. I.e. the SA site assessment does not consider the potential for an enhanced level of site sustainability where development has supported the provision of new or expanded facilities. It is also important, in BLEL's view that that the SA site assessments consider factors such as the quality or capacity of facilities and services as well as a site's distance from such facilities. Quality and capacity are equally important sustainability factors. The Red Amber Green (RAG) scoring system used for the SA's site sustainability appraisals has no green scores in relation to a number of criteria. For example, Air Quality Management Areas and proximity to SSSI designations. This means that all sites are either scored red or amber for such criteria. Similarly, the distance from a Local Nature Reserve criteria is scored as either Red or Green (there is no amber). The RAG scoring system is, in BLEL's view, helpful but rather confusing overall as it mixes two and three RAG scoring codes depending on the criterion in question. BLEL is of the view that the assessment criteria and RAG scoring should be used consistently in respect of each criteria in the next version of the Sustainability Appraisal of the Local Plan. Barwood Land and Estates (BLEL) support the Local Plan at paragraph 43 (page 19) concerning objectively assessed housing need. BLEL support the higher OAN figure (380 dpa) calculated in the latest version of the Strategic Housing Market Assessment, but consider it is realistic and appropriate to now plan on basis of the Government's standardised methodology as set out in the new consultation draft NPPF and in revisions to the NPPG. It is clear that Government intends to adopt the standardised methodology in future and the Local Plan should reflect this now. Therefore, the Plan should set out opportunities and sites to deliver the 454 dpa (+74 dpa over the OAN). This supports and emphasises the need for a choice and mix of sites to ensure delivery and focuses the Plan into ensuring release of sufficient brownfield land and Green Belt sites at sustainable locations in order to deliver. Barwood Land and Estates (BLEL) support paragraph 54 (page 22) of the Local Plan that is concerned with the supply of housing sites. BLEL agree that it is appropriate to review, test and evaluate (and discount where necessary) a wide range of housing sites through the HELAA process. The process undertaken has been thorough in identifying potential sites and in evidencing those selected for allocation in the Plan. The Vision (page 11) supports sustainable growth and makes best use of brownfield and greenfield
land. This represents a realistic approach to the need to release Green Belt land to fully support housing and economic delivery objectives of the Local Plan.

Support

Preferred Site Allocations 2018

Representation ID: 19665

Received: 12/03/2018

Respondent: Childerditch Properties

Agent: Strutt & Parker LLP

Representation:

Figure 5 of the Consultation document identifies Junction 29 of the M25 as a key
location for employment led development and identifies Childerditch Industrial Park as
a location for new employment land. This approach is fully supported and recognises
the importance of this location for new employment opportunities.

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Representation ID: 19685

Received: 12/03/2018

Respondent: Catesby Estates Plc.

Agent: Strutt & Parker LLP

Representation:

It is considered that the land at Wyatts Green Lane, Wyatts Green, relates well to this spatial strategy. The Assessment concludes the site would be suitable for development as it would follow the existing build line and would form a logical boundary. The development of this site would not lead to coalescence and it would not encroach on the open countryside. We welcome the change to the assessment of Wyatts Green, which now sees the village categorised as a Category 3-Large Village, and consider Wyatts Green Lane is suitable for inclusion. We urge the review of the Site Selection Methodology.

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Representation ID: 19691

Received: 12/03/2018

Respondent: Marden Homes Ltd.

Agent: Strutt & Parker LLP

Representation:

Generally supported and ensures the majority of development is focused in locations most accessible to services, employment and the transport network. It is considered that the strategy does not allocate sufficient smaller opportunity sites for residential development, in particular in Hutton. Hutton is a sustainable settlement with excellent links to transport, facilities and services, it should be considered for development. The site is designated as Green Belt, however preforms poorly in respect of the five functions of the Green Belt (NPPF, Para. 80). The release of the land would not result in an adverse effect on the Green Belt.

Full text:

See attached.

Support

Preferred Site Allocations 2018

Representation ID: 19801

Received: 12/03/2018

Respondent: St Modwen Properties PLC

Agent: Strutt & Parker LLP

Representation:

Figure 5 in the consultation document identifies M25 Junction 29 as a key location for
employment led development. This approach is strongly supported and recognises the
importance of this strategic location.

Full text:

See attached.