Policy CP2: Managing Growth
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 57
Received: 09/09/2013
Respondent: Mr Stephen Priddle
Undeveloped areas will not be hit
Undeveloped areas will not be hit
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 323
Received: 02/10/2013
Respondent: Mr Richard Lunnon
Agent: JTS Partnership LLP
We generally support the settlement hierarchy as set out at paragraphs 2.12-2.16 together with the role ascribed to each settlement therein.
The potential conflict with criterion c with the NPPF and planning for Objectively Assessed Needs is noted. In this respect there is potential conflict with criterion c and g.
See Atteched
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 427
Received: 02/10/2013
Respondent: Joy Fook Restaurant
Agent: JTS Partnership LLP
We generally support the proposed settlement hierarchy (paragraphs 2.12 to 2.16), together with the role ascribed to each settlement therein.
Although we do not express a view either way, we note a potential inconsistency between criterion c and the NPPF requirement to plan for 'objectively assessed housing needs'. In that respect, there is also a potential conflict between criteria c and g.
See Attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 431
Received: 02/10/2013
Respondent: Herongate and Ingrave Parish Council
9. Albeit the proposals are to build on Grade 3 farmland this is still a loss of food production for a country that is unable to feed itself without importation. Building on existing farmland is dangerous and exacerbates the inability for UK to feed itself. This, potentially, affects everyone.
On behalf of Herongate and Ingrave Parish Council I am writing to register our objection to the Local Plan 2015-2030 Preferred Options Consultation for the following reasons;
1. Should the draft Local Plan be approved southern Brentwood will lose, amongst others, 2 significant chunks of Metropolitan greenbelt situated directly between London and Brentwood thus undermining the 'green ribbon' around London. Herongate and Ingrave Parish Council does not wish to go the same way as Romford, in 1964, when Havering was incorporated as a new London Borough of Havering and no longer part of Essex County Councils administrative area.
Metropolitan Greenbelt was so named because the instigators of the scheme recognised the exceptional importance of preventing London from sprawling, uncontrollably, across the Home Counties. They saw this as a unique problem due to the size of our capital and the multiplicity of Local Authorities who have a legitimate interest in its growth. It is incumbent on Planners in Essex to pay particular note to this fact and to avoid damaging our green belt at their whim.
2. Any future commitment to greenbelt policy will be permanently undermined given the original 'commitments' to it made by the post-war generation politicians who clearly envisaged situations such as this.
The proposals set a significant precedent for building on greenbelt land of which Herongate and Ingrave has.
3. Herongate and Ingrave Parish Council recommends that the current greenbelt, as set out in the 2005 current Brentwood Local Plan, is retained.
4. Appropriate infrastructure will not be in place to accommodate 1500 extra homes, when built, in West Horndon. West Horndon currently has around 700 homes. Facilities used by Herongate and Ingrave residents will be under increased pressure be it for Hospitals, Doctors, Dentists, Schools, roads and other services.
The proposed massive increase in the population of West Horndon will inevitably compound the problems that we already experience at peak times on the A128. The villages of Herongate and Ingrave create an inevitable ?pinch point? for this congestion. What consideration has been given to coping with the additional loading on our main road?
5. No consultation has taken place with C2C with regards to the increased usage of West Horndon train station and car park. Many residents of our villages use the train station and car park but there are no plans to increase train platform length and car park capacity that is already under strain.
6. There are no planned new secondary schools for the proposed West Horndon development. All the Brentwood secondary schools are oversubscribed and St Martin's has a planning condition not to go beyond 1805 pupils due to congestion. St Martin's is the local secondary school that most Herongate and Ingrave children go to and parents already experience significant traffic congestion during school runs.
7. The proposed movement of West Horndon's industrial premises to the designated greenbelt, as defined in the current 2005 Brentwood Local Plan, to the M25/A127 junction fails to consider public transport for workers that the current industrial site enjoys via a bus service and the regular train service some 50m away. This will increase local road traffic congestion and exclude potential workers that are unable to travel to the proposed new greenbelt industrial site.
8. The proposed Local Plan 2015-2030 acknowledges that 80% of Brentwood's growth will be from outside the borough. Clearly it does not serve the needs of local Brentwood Residents to build on greenbelt land increasing demand on existing, under pressure, services. There are absolutely no guarantees that new housing will meet local demand and that much of this will not be bought for financial investment as part of the buy to let phenomenon.
9. Albeit the proposals are to build on Grade 3 farmland this is still a loss of food production for a country that is unable to feed itself without importation. Building on existing farmland is dangerous and exacerbates the inability for UK to feed itself. This, potentially, affects everyone.
10. In the event that any new West Horndon development is flooded other Brentwood Borough taxpayers are likely to have an increase in Council Tax to pay for improved flood defences.
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 455
Received: 02/10/2013
Respondent: Sans Souci Enterprises Limited
Agent: JTS Partnership LLP
Subject to the reservations expressed in relation to Policies S1 and S2, the Company generally supports the proposed settlement hierarchy (para‟s 2.12 to 2.16), together with the role ascribed to each settlement therein.
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 525
Received: 02/10/2013
Respondent: Ursuline Sisters
Agent: JTS Partnership LLP
The Sisters generally support this policy for managing growth. However it is considered that the Council should also have regard to the ability of a site to bring forward significant community and other benefits when allocating or granting planning permission. Where such benefits clearly outweigh the harmful impact of the development, planning permission should be granted. Consequently, the following criteria (h) should be added to Policy CP2:
"h. The opportunity to secure significant community or other benefits,
consistent with the Spatial Strategy and the presumption in favour of
sustainable development".
See Attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 555
Received: 02/10/2013
Respondent: Hansteen Holdings Plc
Agent: McGough Planning Consultants
Most of this policy is sound and overall aims are supported. However, for CP2(a) refer to comments on para 2.15. CP2(b) requires provision of employment/infrastructure development to be delivered before or at the same time as the housing. Potential costs like wider infrastructure/employment may be uneconomic to deliver until housing and other higher value uses have been delivered. Concern that CP2(b) may undermine viability of large scale redevelopment because of punitive upfront costs. Employment/infrastructure can be delivered as part of s106 or CIL. LPA should frame the policy to allow flexibility and not frontload punitive cost on development.
See attached
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 604
Received: 23/09/2013
Respondent: Ingatestone and Fryerning Parish Council
Please note the reference to The Chelmsford Flood Alleviation Scheme in our response to the Sustainability Appraisal (see below).
[Extract from Parish Council SA response (see attached for more detail): The Parish Council objects to planning application 12/01320/FUL for the Chelsmford Flood Alleviation Scheme on the basis that:
- it would be inappropriate development in Green Belt,
- it would have a detrimental effect on landscape, and
- when filled to capacity there will be an area at increased risk of flooding, threatening wildlife, trees, ancient woodland and a Grade II listed bridge.]
See attachments
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 709
Received: 02/10/2013
Respondent: CLM Ltd
Agent: JTS Partnership LLP
Subject to the reservations expressed in relation to Policy S1, the Company generally supports the proposed settlement hierarchy (paragraphs 2.12 to 2.16), together with the role ascribed to each settlement therein.
Although the Company does not express a view either way, it again notes the potential inconsistency between criterion c and the NPPF requirement to plan for 'objectively assessed housing need'. In that respect, there is also a potential conflict between criteria c and g.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 732
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
This policy requires a consequential amendment resulting from our representations to policies S1 and S2 to enable development of appropriate Green Belt sites. Policy CP2: Managing Growth should be amended to read as follows:
"The Council expects the majority of new development to be provided within or adjoining existing settlements, as identified on the Policies Map, through the development, conversion of previously developed land and buildings or release of appropriate Green Belt sites. In allocating sites..."
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 839
Received: 17/10/2013
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
Policy CP2 is noted in that it confirms the locations for growth within the Borough, and that in selecting sites for allocation, or granting planning permission, the Council will have regard to, inter alia, areas where development should not take place (e.g. undeveloped Green Belt sites) and the need to ensure a flexible and responsive supply of land, and to prioritise the re-use of previously developed land.
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 860
Received: 26/09/2013
Respondent: Environment Agency
We advise that this policy would benefit from the inclusion of the text set out in italics below:
"c. Areas where development should not take place (eg. undeveloped Green Belt, land valuable for food production or at risk of flooding or of high landscape value, or nature conservation areas)."
We consider this to be beneficial to emphasise the importance of minimising impacts on biodiversity as set out in paragraph 109 of the National Planning Policy Framework.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 956
Received: 02/10/2013
Respondent: Barwood Land and Estates Ltd
Agent: Chilmark Consulting Limited
The aims of this policy as drafted are incompatible with The National Planning Policy Framework. The policy approach fails to provide the necessary flexibility and contingency to deliver Brentwood's full objectively assessed housing needs and does not reflect the critical importance of securing housing delivery and in boosting the supply of housing in accordance with The Framework.
See Attached
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 965
Received: 02/10/2013
Respondent: Natural England
Natural England will comment on individual sites as appropriate, as they are brought forward for potential development, especially in respect of any sites within or adjacent to our areas of interests, such as the SSSI's mentioned above.
Opportunities to enhance and or increase biodiversity as part of sustainable development should be encouraged and promoted - as per our comments under Chapter 2 [spatial strategy Policy S1].
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1149
Received: 02/10/2013
Respondent: Highcross
Agent: Rapleys LLP
We agree that the policy should confirm the presumption in favour of sustainable development as per NPPF. Furthermore we recognise the support given, in principle, to the flexible use of land and the priority in favour of the re-use of previously developed land. We consider our clients site, represents a suitable brownfield site which has been unable to attract suitable re-use and therefore the Council should afford greater flexibility to its re-use.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1172
Received: 02/10/2013
Respondent: S J & C M Norris
Agent: Strutt & Parker LLP
This representation has been submitted and sets out why land to the north of the A1023 (Shenfield) should be allocated for a hospitality/leisure use with the opportunity for Park and Ride as part of the emerging Local Plan.
See attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1206
Received: 01/10/2013
Respondent: Strutt & Parker LLP
We consider that development on the edge of settlements (i.e. the rural areas) provides a sustainable form of development in accordance with national policy. The NPPF acknowledges that development in the rural areas will differ in its sustainability when judged against development in the urban areas, but this need not mean that planning permission cannot be granted.
We consider that the policy should be amended to reflect the need and benefits of providing development in rural areas, and in particular adjacent to rural settlements.
See Attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1896
Received: 24/10/2013
Respondent: Historic England
We welcome part f) referring to well designed places that respect local character
See attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 3380
Received: 02/10/2013
Respondent: JTS Partnership LLP
Subject to the reservations expressed in relation to Policies S1 and S2, we generally support the proposed settlement hierarchy (paragraphs 2.12 to 2.16), together with the role ascribed to each settlement therein. Although we not express the view either way, we note a potential inconsistency between criterion c and the NPPF requirement to plan for "objectively assesssed housing needs." In that respect, there is also a potential conflict between criteria c and g.
We consider that a draft Proposal Map should have been published alongside the draft Plan. This would have helped with an understanding, and interpretation of proposed policies.
see attached