Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

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Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Policy R01 (I): Dunton Hills Garden Village Strategic Allocation (page 252)

Representation ID: 26660

Received: 18/11/2019

Respondent: Sow & Grow Nursery

Agent: MR ALAN WIPPERMAN

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

2 However, they are all concerned that the Council's reliance on the large new community development at Dunton Green inherently carries more risk in providing housing over the Plan period, given the size of allocation and annual deliveries required, as it may be subject to delays arising from large scale finance and infrastructure provision as well as housing and finance market fluctuations, such that there can be substantial risks to the annual and overall housing delivery for the District during the Plan period.
3 Accordingly, they are of the view that there should be no further preferred smaller site reallocations currently identified as preferred development sites into the Dunton Green allocation for the Plan period, without sound and convincing reasoning to support this.
4 The many smaller sites identified as preferred sites, such as at the Sow N Grow Nursery site R07, provide for a more secure and dispersed risk in provision of housing delivery as these will tend to have far less upfront and complimentary infrastructure provision required before development can commence. In addition there will tend to be less upfront financial investments by developers, builders, and also by infrastructure providers making development potentially easier and quicker. The exposure to local market fluctuations may also be lessened with sites dispersed throughout the District and site assembly will not often be required. This allows the Plan to be more robust in housing delivery annually and for the Plan period.
5 Further re-allocations would also conflict with the National Planning Policy Framework, in particular, paragraphs 67- 76, and para. 68 in particular.
6 The Family also remains concerned that the supporting documents and assessments also published for this Consultation still do not have regard to the full potential of the Sow N Grow Nursery site which, together with the land owned by Mrs Dunbar, comprising the wider site R07, has again been assessed to 38 dwellings. There is clearly scope for many more, perhaps 50 dwellings plus in total as drawings used in pre-application discussions suggested. (These are in abeyance pending the Adoption of the Plan).
7 However no matters raised in the documents being consulted upon appear to in anyway significantly or adversely impact on the site being selected as a preferred site for development and release from the Green Belt, provided the approach is not extended further to other sites. The Adopted Plan is awaited, so that pre-application discussions can recommence.
The Plan and Focussed Changes continue to be supported for the earliest adoption and it is trusted that this Letter as a Response to the Focussed Changes and Supporting Documents being submitted for the above members of the Armiger Family will be brought to the Inspector's attention.

Full text:

SOW N GROW NURSERY AND ADJOINING SITES MAKING UP SITE R07.
BRENTWOOD DISTRICT LOCAL PLAN - ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REGULATION 19 FEBRUARY 2019 AND RELATED DOCUMENTS.

CONSULTATION RESPONSE FOR MR DEREK ARMIGER, MS KIM ARMIGER AND MS MAXINE ARMIGER, ("THE ARMIGER FAMILY"), C/O THE BUNGALOW, SOW N GROW NURSERY, PILGRIMS HATCH, BRENTWOOD, ESSEX CM15 9JH.
I have once again been instructed as Agent by Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger, i.e. the Armiger family, by way of their personal and family Responses, as being the joint owners of the larger part of the land comprising the Sow N Grow Nursery Allocated Site and Bungalow, and dwelling, as defined in Policy R07, and as shown in part, on the plan on page 324 of the Pre-Submission Local Plan. (The balance of the site, separated by a trackway to the allotments and of unknown ownership, is owned by Mrs Heather Dunbar).
Please accept this letter of Response to the Addendum of Focussed Changes to the Pre-Submission Local Plan, and other supporting documents issued for this consultation on behalf of the said, Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger and the Armiger Family.
1 The Armiger Family members individually and collectively have no objection to the Focussed Changes to the Pre-Submission Local Plan with regard to the deleted sites and dwellings allocated in Blackmore and Shenfield and their re-allocation and incorporation into land allocated for residential development in Dunton Green.
2 However, they are all concerned that the Council's reliance on the large new community development at Dunton Green inherently carries more risk in providing housing over the Plan period, given the size of allocation and annual deliveries required, as it may be subject to delays arising from large scale finance and infrastructure provision as well as housing and finance market fluctuations, such that there can be substantial risks to the annual and overall housing delivery for the District during the Plan period.
3 Accordingly, they are of the view that there should be no further preferred smaller site reallocations currently identified as preferred development sites into the Dunton Green allocation for the Plan period, without sound and convincing reasoning to support this.
4 The many smaller sites identified as preferred sites, such as at the Sow N Grow Nursery site R07, provide for a more secure and dispersed risk in provision of housing delivery as these will tend to have far less upfront and complimentary infrastructure provision required before development can commence. In addition there will tend to be less upfront financial investments by developers, builders, and also by infrastructure providers making development potentially easier and quicker. The exposure to local market fluctuations may also be lessened with sites dispersed throughout the District and site assembly will not often be required. This allows the Plan to be more robust in housing delivery annually and for the Plan period.
5 Further re-allocations would also conflict with the National Planning Policy Framework, in particular, paragraphs 67- 76, and para. 68 in particular.
6 The Family also remains concerned that the supporting documents and assessments also published for this Consultation still do not have regard to the full potential of the Sow N Grow Nursery site which, together with the land owned by Mrs Dunbar, comprising the wider site R07, has again been assessed to 38 dwellings. There is clearly scope for many more, perhaps 50 dwellings plus in total as drawings used in pre-application discussions suggested. (These are in abeyance pending the Adoption of the Plan).
7 However no matters raised in the documents being consulted upon appear to in anyway significantly or adversely impact on the site being selected as a preferred site for development and release from the Green Belt, provided the approach is not extended further to other sites. The Adopted Plan is awaited, so that pre-application discussions can recommence.
The Plan and Focussed Changes continue to be supported for the earliest adoption and it is trusted that this Letter as a Response to the Focussed Changes and Supporting Documents being submitted for the above members of the Armiger Family will be brought to the Inspector's attention. I should be pleased to discuss any matters arising from this Letter and Response with the Local Planning Authority should it wish to do so.
Yours sincerely
Alan Wipperman BA MRICS MRTPI C Dip AF
Copies: Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Policy R01 (I): Dunton Hills Garden Village Strategic Allocation (page 252)

Representation ID: 26661

Received: 18/11/2019

Respondent: Sow & Grow Nursery

Agent: MR ALAN WIPPERMAN

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

2 However, they are all concerned that the Council's reliance on the large new community development at Dunton Green inherently carries more risk in providing housing over the Plan period, given the size of allocation and annual deliveries required, as it may be subject to delays arising from large scale finance and infrastructure provision as well as housing and finance market fluctuations, such that there can be substantial risks to the annual and overall housing delivery for the District during the Plan period.
3 Accordingly, they are of the view that there should be no further preferred smaller site reallocations currently identified as preferred development sites into the Dunton Green allocation for the Plan period, without sound and convincing reasoning to support this.
4 The many smaller sites identified as preferred sites, such as at the Sow N Grow Nursery site R07, provide for a more secure and dispersed risk in provision of housing delivery as these will tend to have far less upfront and complimentary infrastructure provision required before development can commence. In addition there will tend to be less upfront financial investments by developers, builders, and also by infrastructure providers making development potentially easier and quicker. The exposure to local market fluctuations may also be lessened with sites dispersed throughout the District and site assembly will not often be required. This allows the Plan to be more robust in housing delivery annually and for the Plan period.
5 Further re-allocations would also conflict with the National Planning Policy Framework, in particular, paragraphs 67- 76, and para. 68 in particular.
6 The Family also remains concerned that the supporting documents and assessments also published for this Consultation still do not have regard to the full potential of the Sow N Grow Nursery site which, together with the land owned by Mrs Dunbar, comprising the wider site R07, has again been assessed to 38 dwellings. There is clearly scope for many more, perhaps 50 dwellings plus in total as drawings used in pre-application discussions suggested. (These are in abeyance pending the Adoption of the Plan).
7 However no matters raised in the documents being consulted upon appear to in anyway significantly or adversely impact on the site being selected as a preferred site for development and release from the Green Belt, provided the approach is not extended further to other sites. The Adopted Plan is awaited, so that pre-application discussions can recommence.
The Plan and Focussed Changes continue to be supported for the earliest adoption and it is trusted that this Letter as a Response to the Focussed Changes and Supporting Documents being submitted for the above members of the Armiger Family will be brought to the Inspector's attention.

Full text:

SOW N GROW NURSERY AND ADJOINING SITES MAKING UP SITE R07.
BRENTWOOD DISTRICT LOCAL PLAN - ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REGULATION 19 FEBRUARY 2019 AND RELATED DOCUMENTS.

CONSULTATION RESPONSE FOR MR DEREK ARMIGER, MS KIM ARMIGER AND MS MAXINE ARMIGER, ("THE ARMIGER FAMILY"), C/O THE BUNGALOW, SOW N GROW NURSERY, PILGRIMS HATCH, BRENTWOOD, ESSEX CM15 9JH.
I have once again been instructed as Agent by Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger, i.e. the Armiger family, by way of their personal and family Responses, as being the joint owners of the larger part of the land comprising the Sow N Grow Nursery Allocated Site and Bungalow, and dwelling, as defined in Policy R07, and as shown in part, on the plan on page 324 of the Pre-Submission Local Plan. (The balance of the site, separated by a trackway to the allotments and of unknown ownership, is owned by Mrs Heather Dunbar).
Please accept this letter of Response to the Addendum of Focussed Changes to the Pre-Submission Local Plan, and other supporting documents issued for this consultation on behalf of the said, Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger and the Armiger Family.
1 The Armiger Family members individually and collectively have no objection to the Focussed Changes to the Pre-Submission Local Plan with regard to the deleted sites and dwellings allocated in Blackmore and Shenfield and their re-allocation and incorporation into land allocated for residential development in Dunton Green.
2 However, they are all concerned that the Council's reliance on the large new community development at Dunton Green inherently carries more risk in providing housing over the Plan period, given the size of allocation and annual deliveries required, as it may be subject to delays arising from large scale finance and infrastructure provision as well as housing and finance market fluctuations, such that there can be substantial risks to the annual and overall housing delivery for the District during the Plan period.
3 Accordingly, they are of the view that there should be no further preferred smaller site reallocations currently identified as preferred development sites into the Dunton Green allocation for the Plan period, without sound and convincing reasoning to support this.
4 The many smaller sites identified as preferred sites, such as at the Sow N Grow Nursery site R07, provide for a more secure and dispersed risk in provision of housing delivery as these will tend to have far less upfront and complimentary infrastructure provision required before development can commence. In addition there will tend to be less upfront financial investments by developers, builders, and also by infrastructure providers making development potentially easier and quicker. The exposure to local market fluctuations may also be lessened with sites dispersed throughout the District and site assembly will not often be required. This allows the Plan to be more robust in housing delivery annually and for the Plan period.
5 Further re-allocations would also conflict with the National Planning Policy Framework, in particular, paragraphs 67- 76, and para. 68 in particular.
6 The Family also remains concerned that the supporting documents and assessments also published for this Consultation still do not have regard to the full potential of the Sow N Grow Nursery site which, together with the land owned by Mrs Dunbar, comprising the wider site R07, has again been assessed to 38 dwellings. There is clearly scope for many more, perhaps 50 dwellings plus in total as drawings used in pre-application discussions suggested. (These are in abeyance pending the Adoption of the Plan).
7 However no matters raised in the documents being consulted upon appear to in anyway significantly or adversely impact on the site being selected as a preferred site for development and release from the Green Belt, provided the approach is not extended further to other sites. The Adopted Plan is awaited, so that pre-application discussions can recommence.
The Plan and Focussed Changes continue to be supported for the earliest adoption and it is trusted that this Letter as a Response to the Focussed Changes and Supporting Documents being submitted for the above members of the Armiger Family will be brought to the Inspector's attention. I should be pleased to discuss any matters arising from this Letter and Response with the Local Planning Authority should it wish to do so.
Yours sincerely
Alan Wipperman BA MRICS MRTPI C Dip AF
Copies: Mr Derek Armiger, Ms Kim Armiger and Ms Maxine Armiger.

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