Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

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Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY HP06: STANDARDS FOR NEW HOUSING

Representation ID: 24043

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The nationally described space standard is an appropriate tool to use when considering the provision of good housing. However, this should not be limited to major development, but should extend to all emerging residential development, whilst allowing for the consideration of local circumstances and site-specific conditions, in order to accord the NPPF (Section 12, Achieving Well-Designed Places). The policy is therefore "unjustified" in relation to need and viability (our emphasis) in accordance with the NPPF. The adoption of nationally described space standards is also at the discretion of the LPA and should be decided upon in a local context.

Attachments:

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY HP12: PLANNING FOR INCLUSIVE COMMUNITIES

Representation ID: 24044

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Representation Summary:

Policy HP12: Planning for Inclusive Communities refers to the need to plan for and build inclusive environments that support communities. Proposals should provide access to good quality community spaces, services and infrastructure, encouraging social interaction, ensuring inclusivity and promoting safety. The policy is deemed "consistent" with NPPF (section 8) "Promoting Healthy and Safe Communities" which states that planning policies should aim to achieve healthy, inclusive and safe places which promote social interaction, are safe and accessible, and support healthy lifestyles. The policy is therefore considered sound.

Attachments:

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY HP13: CREATING SUCCESSFUL PLACES

Representation ID: 24045

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Representation Summary:

Policy HP13: Creating Successful Places seeks that proposals meet high design standards, in order to deliver safe, inclusive, attractive and accessible places. Elements A-M of policy HP13 identify measures considered to create successful places, in accordance with section 12 of the NPPF on "Achieving Well-Designed Places". The NPPF (para 128) states that design quality should be considered throughout the evolution and assessment of individual proposals. Policy HP13 is therefore considered to be "consistent" with the NPPF and sound.

Attachments:

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY HP16: BUILDINGS DESIGN

Representation ID: 24046

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Representation Summary:

Policy HP16: Buildings Design seeks for development to be well designed and of a high quality, having regard to Development Management criteria including scale, density, layout, siting, character and appearance. This policy is considered to be "consistent" with the NPPF having particular regard to Section 12 on "Achieving Well-Designed Places" and therefore sound.

Attachments:

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY PC02: JOB GROWTH AND EMPLOYMENT LAND

Representation ID: 24047

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Representation Summary:

Policy PC02: Job Growth and Employment Land seeks that provision is made for 5,000 additional jobs in the Borough over the Plan period at a rate of 250 per year. NPPF Section 6 on "Building a Strong, Competitive Economy" sets out that planning policies should support economic growth, in order to create jobs and prosperity by taking a positive approach to sustainable new development. The strategic allocation at Land North of Shenfield supports economic growth and creates new opportunities and is "consistent" with national guidance and is sound.

Attachments:

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY PC03: EMPLOYMENT LAND ALLOCATIONS

Representation ID: 24048

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Representation Summary:

Policy PC03: Employment Land Allocations highlights areas allocated by the Council for general employment and office development. Para 82 of the NPPF states that planning policies should recognise and address the specific locational requirements of different employment sectors. The allocations set out in policy PC03 are informed by the wider spatial strategy, which aims to retain the Borough's character and encourage employment growth in suitable locations, in accordance with national planning policy. This policy is therefore deemed to be "consistent" with the NPPF and considered to be sound.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY NE01: PROTECTING AND ENHANCING THE NATURAL ENVIRONMENT

Representation ID: 24049

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Wholly supports the principles of both NE09 and NE03; albeit as presently worded, they both contain contradictory requirements: Policy NE01 (para B) states that proposals that lead to deterioration or loss of the Borough's designated and non-designated biodiversity assets will not be permitted; whereas Policy NE01 (para C) goes on to state that where adverse impacts are unavoidable they must be adequately and proportionally mitigated (ie it appears to allow for deterioration where they are unavoidable and can be suitably mitigated). Policy NE03 (para A) contains a similar contradictory approach to the provisions of the remainder of the policy.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY NE03: TREES, WOODLANDS, HEDGEROWS

Representation ID: 24050

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Wholly supports the principles of both NE09 and NE03; albeit as presently worded, they both contain contradictory requirements: Policy NE01 (para B) states that proposals that lead to deterioration or loss of the Borough's designated and non-designated biodiversity assets will not be permitted; whereas Policy NE01 (para C) goes on to state that where adverse impacts are unavoidable they must be adequately and proportionally mitigated (ie it appears to allow for deterioration where they are unavoidable and can be suitably mitigated). Policy NE03 (para A) contains a similar contradictory approach to the provisions of the remainder of the policy.

Attachments:

Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY NE05: AIR QUALITY

Representation ID: 24051

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Representation Summary:

Policy NE05: Air Quality seeks to restrict development, which would directly or indirectly, impact air quality within the Borough. Measures to offset or mitigate those impacts are introduced as part of proposals to ensure that receptors would not be subject to unacceptable risk as a result of poor air quality. This policy is "consistent" with the objectives of the NPPF (para 181) and is therefore considered sound.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

POLICY NE06: FLOOD RISK

Representation ID: 24052

Received: 19/03/2019

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The majority of Policy NE06 therefore aligns with National guidance and therefore mostly sound. However, and as presently worded, it suggests tat applicants may be obligated to set aside land to provide flood management to benefit areas outside of that development. This is unduly onerous, inconsistent with National policy and therefore unsound. Similarly, the entirety of a development area does not need to remain operational at times of flood (such as access roads), if there is an alternative safe means of escape that is provided. Subsection c) of Policy NE06 is therefore not justified and also unsound.

Attachments:

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