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

Search representations

Results for CEG Land Promotions Limited search

New search New search

Object

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

POLICY SP06: EFFECTIVE DELIVERY OF DEVELOPMENT

Representation ID: 23958

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Not specified

Representation Summary:

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.

Attachments:

Object

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

POLICY BE02: SUSTAINABLE CONSTRUCTION AND RESOURCE EFFICIENCY

Representation ID: 23959

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy BE02, Sustainable Construction (page 67 - 68)
Paragraph 153(a) of the National Planning Policy Framework (NPPF) states that "In determining planning applications, local planning authorities should expect new development to: (a) comply with any development plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable;..."
Policy BE02(f) is currently inconsistent with the NPPF as it does not reflect that this should not apply in circumstance where it is not feasible or viable. It is also inconsistent with Policy BE03 which states that "Proposals for renewable, low carbon or decentralised energy schemes will be supported provided they can demonstrate that they will not result in adverse impacts..." i.e. this recognises that this approach may not be appropriate in all circumstances. This approach is sound and consistent with the NPPF.
It is important that Policy BE02 and BE04 are consistent with the NPPF and do not unintentionally result in a policy expectation that over burdens development and undermines viability. This is particularly important in relation to Dunton Hills Garden Village which is important to the delivery of housing in the Local Plan.
Modifications are proposed to Policy BE02 in our response to question no. 6 to ensure consistency with the NPPF and between policies in the Plan.

Attachments:

Object

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

POLICY BE02: SUSTAINABLE CONSTRUCTION AND RESOURCE EFFICIENCY

Representation ID: 23960

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? No

Sound? Yes

Duty to co-operate? Not specified

Representation Summary:

Paragraph 153(a) of the National Planning Policy Framework (NPPF) states that "In determining planning applications, local planning authorities should expect new development to: (a) comply with any development plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable;..."
Policy BE02(f) is currently inconsistent with the NPPF as it does not reflect that this should not apply in circumstance where it is not feasible or viable. It is also inconsistent with Policy BE03 which states that "Proposals for renewable, low carbon or decentralised energy schemes will be supported provided they can demonstrate that they will not result in adverse impacts..." i.e. this recognises that this approach may not be appropriate in all circumstances. This approach is sound and consistent with the NPPF.
It is important that Policy BE02 and BE04 are consistent with the NPPF and do not unintentionally result in a policy expectation that over burdens development and undermines viability. This is particularly important in relation to Dunton Hills Garden Village which is important to the delivery of housing in the Local Plan.
Modifications are proposed to Policy BE02 in our response to question no. 6 to ensure consistency with the NPPF and between policies in the Plan.

Attachments:

Object

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

POLICY BE04: ESTABLISHING LOW CARBON AND RENEWABLE ENERGY INFRASTRUCTURE NETWORK

Representation ID: 23961

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network (page 77 - 79)
Policy BE04 is currently inconsistent with paragraph 153 of the NPPF, which states that local plans can expect to comply with such provision where it is feasible or viable, and with Policy BE03 of the Local Plan. Modifications are proposed in our response to question no. 6 to ensure consistency with the NPPF and between policies in the Plan.

Attachments:

Support

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

POLICY BE11: STRATEGIC TRANSPORT INFRASTRUCTURE

Representation ID: 23962

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Representation Summary:

BE11 Strategic Transport Infrastructure (page 92 - 94)
CEG supports the objectives of Policy BE11, particularly improving multi modal integration and/or capacity at train stations, which is consistent with the NPPF (paragraph 110(a)). In relation to criterion B(ii) a modification is proposed to ensure consistency with Policy R01.

Attachments:

Object

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

POLICY BE22: OPEN SPACE IN NEW DEVELOPMENT

Representation ID: 23963

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The NPPF states at paragraph 56 that planning obligations must only be sought where they meet all of the following tests:
a) necessary to make the development acceptable in planning terms;
b) directly related to the development; and
c) fairly and reasonably related in scale and kind to the development.
Policy BE22 is not positively prepared or consistent with paragraph 56 of the NPPF because it is not reasonable to request financial contributions in circumstances where a developer is providing functional open space on-site. To ensure the policy is positively prepared consistent with the NPPF modifications are proposed in our response to question no. 6.

Attachments:

Object

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

POLICY HP01: HOUSING MIX

Representation ID: 23964

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Self-build and/or custom build housing is supported by the National Planning Policy Framework (NPPF) and its contribution can help to diversify a housing offer, thus supporting housing delivery overall (Letwin, October 2018). CEG is committed to the delivery of self and custom build housing at Dunton Hills Garden Village (DHGV). Planning for a variety of housing types, including self and custom build assists in the delivery of housing on large sites. However, the minimum target of 5% set out in criterion A. c. (i) is not justified by an appropriate evidence base.

CEG is aware that the current level of interest on the Council's Self and Custom Build Register is relatively limited and the need for such housing does not, therefore, justify a minimum level of 5% being required. Indeed, if such a level isn't needed setting such a high minimum requirement could effectively prevent land being released for other types of housing which are needed.

In the 12 month period ending in October 2018 it is understood that 47 individuals and no associations were registered with the Council. Of the total number, 9 indicated a preference for village locations across the Borough, which in the future might include DHGV.

It is acknowledged that the Register is relatively new and the need for this type of housing might change over time. Considering this, a lower minimum requirement should be sought, probably at 1%, to support this type of housing at a level proportionate to the likely need. DHGV will provide for 2,700 new homes over the plan period, and 1% of this would amount to 27 self-build homes in total.

Overall CEG considers the 5% is too high and a lower figure should be adopted.

Attachments:

Object

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

POLICY HP03: RESIDENTIAL DENSITY

Representation ID: 23965

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy HP03, Residential Density (page 128)

The policy is positively prepared. Taking a design led approach to density should enable development to achieve a net density of at least 35 dph or higher. This approach is consistent with Chapter 11 of the NPPF which seeks to make efficient use of land and optimise the density of development. A modification is proposed to reflect that density across a site should be an average.

Attachments:

Support

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

POLICY HP05: AFFORDABLE HOUSING

Representation ID: 23966

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Representation Summary:

CEG supports the approach set out at paragraph 6.35 which explains that the 'need' for 86% social rent and 14% other forms of affordable housing will be used to inform negotiations between the Council and developers to determine the appropriate tenure and mix of affordable housing.

This 'need' is then expressed as an 'indicative requirement' in Figure 6.2 and a 'requirement' in Policy HP05(B). The Policy currently requires a specific tenure split (86% social rent and 14% other forms of affordable housing) which may not be appropriate for the life of the Plan or for Strategic Allocations in the Plan. CEG supports the approach set out in paragraph 6.35 to ensure there is an appropriate amount of flexibility, for example, to accommodate changing circumstances over the lifetime of the Plan; and ensure the right mix and balance is created where Strategic Allocations are concerned.

Attachments:

Object

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

POLICY HP19: CONSERVATION AND ENHANCEMENT OF HISTORIC ENVIRONMENT

Representation ID: 23967

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Paragraph 185 of the NPPF, requires that "Plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account: a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation;..."
In relation to designated heritage assets, paragraphs 195 and 196 provide for harm to heritage assets to be weighed against the public benefits of a proposal. As such, there are circumstances where not all heritage assets will be "sustained and enhanced". A modification is proposed in our response to question no. 6 to ensure consistency with the NPPF.

Attachments:

For instructions on how to use the system and make comments, please see our help guide.