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

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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: 26756

Received: 26/11/2019

Respondent: Countryside Properties

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Allocation of Unit Numbers

Whilst Countryside Properties can confirm their support of the draft Local Plan in principle, and in particular
the allocation of land at Chelmsford Road and Doddinghurst Road for residential development, it is noted that
the Focussed Changes relate exclusively to the reduction of unit numbers on 4 sites that are proposed for
allocation within the Pre-Submission Local Plan, and the respective increase of the number of homes
proposed for delivery as part of Dunton Hills Garden Village to accommodate the reductions.

Countryside Properties remain concerned in relation to an over-reliance on large scale strategic development
for the provision of housing over the Plan period (2033). Brentwood Borough Council should protect those
sites that are immediately available for the short term delivery of housing within the early stages of the Local
Plan period.

Should there be specific reasons why the 4 sites have a lower capacity than initially understood, alternative
sites proposed for allocation, such as land at Chelmsford Road and Doddinghurst Road have sufficient
capacity to accommodate an increase in unit numbers to protect overall housing delivery numbers for the
Borough. This would help to balance the reliance on Dunton Hills Garden Village for housing delivery whilst
ensuring the efficient use of small to medium scale sites which are available to deliver housing immediately.
Countryside are able to confirm an intention for the three developer parties with land interests at Shenfield to
agree a Statement of Common Ground, which is expected to provide further reassurance of the short term
delivery of this particular allocation in due course.

It should also be acknowledged that no growth of the sustainable settlement of Hutton has been proposed,
despite its sustainability credentials and offering of small scale development sites such as land at Bayleys
Mead. Such sites currently make a negligible contribution to the Green Belt and would not contribute to
coalescence of settlements given the scale and enclosed nature of the site, as has been demonstrated in
information submitted alongside previous representations at earlier stages of this Local Plan.

Full text:

Brentwood Local Plan - Regulation 19 Focussed Consultation
This letter has been prepared by Strutt & Parker on behalf of Countryside Properties, in respect of their land interests in Brentwood and in particular, the following three sites that have been promoted to date as part of the emerging Local Plan:
1. Land at Chelmsford Road, Shenfield (Ref: R03)
2. Land at Doddinghurst Road, Brentwood (Ref: Policy R16 & R17)
3. Land at Bayleys Mead, Hutton
Representations were made on the Pre-Submission Local Plan (Reg 19) in relation of all three of the above sites. Countryside Properties hereby provide consent that their personal contact details, and those of their planning agent, Strutt & Parker, can be shared with the Planning Inspectorate and Programme Officer for the purposes of administering the Examination of the Local Plan when it is submitted by the Council.
Allocation of Unit Numbers
Whilst Countryside Properties can confirm their support of the draft Local Plan in principle, and in particular the allocation of land at Chelmsford Road and Doddinghurst Road for residential development, it is noted that the Focussed Changes relate exclusively to the reduction of unit numbers on 4 sites that are proposed for allocation within the Pre-Submission Local Plan, and the respective increase of the number of homes proposed for delivery as part of Dunton Hills Garden Village to accommodate the reductions.
Countryside Properties remain concerned in relation to an over-reliance on large scale strategic development for the provision of housing over the Plan period (2033). Brentwood Borough Council should protect those sites that are immediately available for the short term delivery of housing within the early stages of the Local Plan period.
Should there be specific reasons why the 4 sites have a lower capacity than initially understood, alternative sites proposed for allocation, such as land at Chelmsford Road and Doddinghurst Road have sufficient capacity to accommodate an increase in unit numbers to protect overall housing delivery numbers for the Borough. This would help to balance the reliance on Dunton Hills Garden Village for housing delivery whilst ensuring the efficient use of small to medium scale sites which are available to deliver housing immediately.
Countryside are able to confirm an intention for the three developer parties with land interests at Shenfield to agree a Statement of Common Ground, which is expected to provide further reassurance of the short term delivery of this particular allocation in due course.
It should also be acknowledged that no growth of the sustainable settlement of Hutton has been proposed, despite its sustainability credentials and offering of small scale development sites such as land at Bayleys Mead. Such sites currently make a negligible contribution to the Green Belt and would not contribute to coalescence of settlements given the scale and enclosed nature of the site, as has been demonstrated in information submitted alongside previous representations at earlier stages of this Local Plan.
Policy R03
In addition to the comments above, we have also previously raised a recommendation for policy wording relating to an inflexible provision of employment land (2ha) to be amended or removed. This is in respect of an over-provision of employment land that has been allocated in comparison to the need identified within the Plan, and also in the interests of providing an employment use at Chelmsford Road that best meets the market demand and Borough Council objectives for this site.
Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide a key gateway into Shenfield and onto Brentwood in this location.
Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely to generate a visually prolific building or a flagship/feature, or be desirable in this edge of settlement location. B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway to the area, and would also have implications on the A12 gyratory through the associated movements of HGVs and other vehicles.
We are aware of interest in the use of the site for other employment generating and commercial uses which would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in this location. It is recognised however that the spatial requirements of such uses are again unlikely to meet a full 2ha of land.
The proposed provision of employment uses on this site has not been justified and is not effective. The provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts with the deliverability of new homes on the site to meet the Council's housing need. Countryside Properties are confident of the ability to deliver this either through exemplary residential and landscape-led design at the entrance to the site, or through a smaller provision of employment land which is respective of the current market and likely demand in this location. As such, the provision of 2ha of land for employment purposes should be removed from the policy.
Policy R16 & R17
Countryside maintain concerns over the amendment to the wording of Policy R16 & R17 that was made without justification during the previous iteration of the draft Local Plan. The previous iteration of the policy required vehicular access to be provided from "Doddinghurst Road for both site and/or Karen Close and Russell Close". The current policy is worded to allow for vehicular access from Doddinghurst Road only.
Whilst access from Doddinghurst Road is accepted as the preferred strategy for all parties, initial appraisal work in this respect has recognised a potential requirement for significant levelling and land movement which could have implications on the viability of housing delivery on the site. It is therefore requested that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways. The use of these accesses may also better support the design of scheme that is fully integrated with existing development.
Countryside continue to support Brentwood in the progression of their Local Plan, but wish to emphasise the continuing importance of minor amendments to specific policies, alongside the need for consistent housing delivery across the entire Plan period. This is important to ensure that the Plan is deliverable and found sound at Examination.

Object

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

Sustainability Appraisal

Representation ID: 26757

Received: 26/11/2019

Respondent: Countryside Properties

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Policy R03
In addition to the comments made separately, we have also previously raised a recommendation for policy wording
relating to an inflexible provision of employment land (2ha) to be amended or removed. This is in respect of
an over-provision of employment land that has been allocated in comparison to the need identified within the
Plan, and also in the interests of providing an employment use at Chelmsford Road that best meets the
market demand and Borough Council objectives for this site.

Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide
a key gateway into Shenfield and onto Brentwood in this location.

Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an
entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely
to generate a visually prolific building or a flagship/feature, or be desirable in this edge of settlement location.
B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway
to the area, and would also have implications on the A12 gyratory through the associated movements of
HGVs and other vehicles.

We are aware of interest in the use of the site for other employment generating and commercial uses which
would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in
this location. It is recognised however that the spatial requirements of such uses are again unlikely to meet
a full 2ha of land.

The proposed provision of employment uses on this site has not been justified and is not effective. The
provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts
with the deliverability of new homes on the site to meet the Council's housing need. Countryside Properties
are confident of the ability to deliver this either through exemplary residential and landscape-led design at the
entrance to the site, or through a smaller provision of employment land which is respective of the current
market and likely demand in this location. As such, the provision of 2ha of land for employment purposes
should be removed from the policy.

Full text:

Brentwood Local Plan - Regulation 19 Focussed Consultation
This letter has been prepared by Strutt & Parker on behalf of Countryside Properties, in respect of their land interests in Brentwood and in particular, the following three sites that have been promoted to date as part of the emerging Local Plan:
1. Land at Chelmsford Road, Shenfield (Ref: R03)
2. Land at Doddinghurst Road, Brentwood (Ref: Policy R16 & R17)
3. Land at Bayleys Mead, Hutton
Representations were made on the Pre-Submission Local Plan (Reg 19) in relation of all three of the above sites. Countryside Properties hereby provide consent that their personal contact details, and those of their planning agent, Strutt & Parker, can be shared with the Planning Inspectorate and Programme Officer for the purposes of administering the Examination of the Local Plan when it is submitted by the Council.
Allocation of Unit Numbers
Whilst Countryside Properties can confirm their support of the draft Local Plan in principle, and in particular the allocation of land at Chelmsford Road and Doddinghurst Road for residential development, it is noted that the Focussed Changes relate exclusively to the reduction of unit numbers on 4 sites that are proposed for allocation within the Pre-Submission Local Plan, and the respective increase of the number of homes proposed for delivery as part of Dunton Hills Garden Village to accommodate the reductions.
Countryside Properties remain concerned in relation to an over-reliance on large scale strategic development for the provision of housing over the Plan period (2033). Brentwood Borough Council should protect those sites that are immediately available for the short term delivery of housing within the early stages of the Local Plan period.
Should there be specific reasons why the 4 sites have a lower capacity than initially understood, alternative sites proposed for allocation, such as land at Chelmsford Road and Doddinghurst Road have sufficient capacity to accommodate an increase in unit numbers to protect overall housing delivery numbers for the Borough. This would help to balance the reliance on Dunton Hills Garden Village for housing delivery whilst ensuring the efficient use of small to medium scale sites which are available to deliver housing immediately.
Countryside are able to confirm an intention for the three developer parties with land interests at Shenfield to agree a Statement of Common Ground, which is expected to provide further reassurance of the short term delivery of this particular allocation in due course.
It should also be acknowledged that no growth of the sustainable settlement of Hutton has been proposed, despite its sustainability credentials and offering of small scale development sites such as land at Bayleys Mead. Such sites currently make a negligible contribution to the Green Belt and would not contribute to coalescence of settlements given the scale and enclosed nature of the site, as has been demonstrated in information submitted alongside previous representations at earlier stages of this Local Plan.
Policy R03
In addition to the comments above, we have also previously raised a recommendation for policy wording relating to an inflexible provision of employment land (2ha) to be amended or removed. This is in respect of an over-provision of employment land that has been allocated in comparison to the need identified within the Plan, and also in the interests of providing an employment use at Chelmsford Road that best meets the market demand and Borough Council objectives for this site.
Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide a key gateway into Shenfield and onto Brentwood in this location.
Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely to generate a visually prolific building or a flagship/feature, or be desirable in this edge of settlement location. B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway to the area, and would also have implications on the A12 gyratory through the associated movements of HGVs and other vehicles.
We are aware of interest in the use of the site for other employment generating and commercial uses which would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in this location. It is recognised however that the spatial requirements of such uses are again unlikely to meet a full 2ha of land.
The proposed provision of employment uses on this site has not been justified and is not effective. The provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts with the deliverability of new homes on the site to meet the Council's housing need. Countryside Properties are confident of the ability to deliver this either through exemplary residential and landscape-led design at the entrance to the site, or through a smaller provision of employment land which is respective of the current market and likely demand in this location. As such, the provision of 2ha of land for employment purposes should be removed from the policy.
Policy R16 & R17
Countryside maintain concerns over the amendment to the wording of Policy R16 & R17 that was made without justification during the previous iteration of the draft Local Plan. The previous iteration of the policy required vehicular access to be provided from "Doddinghurst Road for both site and/or Karen Close and Russell Close". The current policy is worded to allow for vehicular access from Doddinghurst Road only.
Whilst access from Doddinghurst Road is accepted as the preferred strategy for all parties, initial appraisal work in this respect has recognised a potential requirement for significant levelling and land movement which could have implications on the viability of housing delivery on the site. It is therefore requested that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways. The use of these accesses may also better support the design of scheme that is fully integrated with existing development.
Countryside continue to support Brentwood in the progression of their Local Plan, but wish to emphasise the continuing importance of minor amendments to specific policies, alongside the need for consistent housing delivery across the entire Plan period. This is important to ensure that the Plan is deliverable and found sound at Examination.

Object

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

Sustainability Appraisal

Representation ID: 26758

Received: 26/11/2019

Respondent: Countryside Properties

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Policy R16 & R17
Countryside maintain concerns over the amendment to the wording of Policy R16 & R17 that was made without justification during the previous iteration of the draft Local Plan. The previous iteration of the policy required vehicular access to be provided from "Doddinghurst Road for both site and/or Karen Close and Russell Close". The current policy is worded to allow for vehicular access from Doddinghurst Road only.
Whilst access from Doddinghurst Road is accepted as the preferred strategy for all parties, initial appraisal work in this respect has recognised a potential requirement for significant levelling and land movement which could have implications on the viability of housing delivery on the site. It is therefore requested that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways. The use of these accesses may also better support the design of scheme that is fully integrated with existing development. Countryside continue to support Brentwood in the progression of their Local Plan, but wish to emphasise the continuing importance of minor amendments to specific policies, alongside the need for consistent housing delivery across the entire Plan period. This is important to ensure that the Plan is deliverable and found sound
at Examination.

Full text:

Brentwood Local Plan - Regulation 19 Focussed Consultation
This letter has been prepared by Strutt & Parker on behalf of Countryside Properties, in respect of their land interests in Brentwood and in particular, the following three sites that have been promoted to date as part of the emerging Local Plan:
1. Land at Chelmsford Road, Shenfield (Ref: R03)
2. Land at Doddinghurst Road, Brentwood (Ref: Policy R16 & R17)
3. Land at Bayleys Mead, Hutton
Representations were made on the Pre-Submission Local Plan (Reg 19) in relation of all three of the above sites. Countryside Properties hereby provide consent that their personal contact details, and those of their planning agent, Strutt & Parker, can be shared with the Planning Inspectorate and Programme Officer for the purposes of administering the Examination of the Local Plan when it is submitted by the Council.
Allocation of Unit Numbers
Whilst Countryside Properties can confirm their support of the draft Local Plan in principle, and in particular the allocation of land at Chelmsford Road and Doddinghurst Road for residential development, it is noted that the Focussed Changes relate exclusively to the reduction of unit numbers on 4 sites that are proposed for allocation within the Pre-Submission Local Plan, and the respective increase of the number of homes proposed for delivery as part of Dunton Hills Garden Village to accommodate the reductions.
Countryside Properties remain concerned in relation to an over-reliance on large scale strategic development for the provision of housing over the Plan period (2033). Brentwood Borough Council should protect those sites that are immediately available for the short term delivery of housing within the early stages of the Local Plan period.
Should there be specific reasons why the 4 sites have a lower capacity than initially understood, alternative sites proposed for allocation, such as land at Chelmsford Road and Doddinghurst Road have sufficient capacity to accommodate an increase in unit numbers to protect overall housing delivery numbers for the Borough. This would help to balance the reliance on Dunton Hills Garden Village for housing delivery whilst ensuring the efficient use of small to medium scale sites which are available to deliver housing immediately.
Countryside are able to confirm an intention for the three developer parties with land interests at Shenfield to agree a Statement of Common Ground, which is expected to provide further reassurance of the short term delivery of this particular allocation in due course.
It should also be acknowledged that no growth of the sustainable settlement of Hutton has been proposed, despite its sustainability credentials and offering of small scale development sites such as land at Bayleys Mead. Such sites currently make a negligible contribution to the Green Belt and would not contribute to coalescence of settlements given the scale and enclosed nature of the site, as has been demonstrated in information submitted alongside previous representations at earlier stages of this Local Plan.
Policy R03
In addition to the comments above, we have also previously raised a recommendation for policy wording relating to an inflexible provision of employment land (2ha) to be amended or removed. This is in respect of an over-provision of employment land that has been allocated in comparison to the need identified within the Plan, and also in the interests of providing an employment use at Chelmsford Road that best meets the market demand and Borough Council objectives for this site.
Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide a key gateway into Shenfield and onto Brentwood in this location.
Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely to generate a visually prolific building or a flagship/feature, or be desirable in this edge of settlement location. B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway to the area, and would also have implications on the A12 gyratory through the associated movements of HGVs and other vehicles.
We are aware of interest in the use of the site for other employment generating and commercial uses which would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in this location. It is recognised however that the spatial requirements of such uses are again unlikely to meet a full 2ha of land.
The proposed provision of employment uses on this site has not been justified and is not effective. The provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts with the deliverability of new homes on the site to meet the Council's housing need. Countryside Properties are confident of the ability to deliver this either through exemplary residential and landscape-led design at the entrance to the site, or through a smaller provision of employment land which is respective of the current market and likely demand in this location. As such, the provision of 2ha of land for employment purposes should be removed from the policy.
Policy R16 & R17
Countryside maintain concerns over the amendment to the wording of Policy R16 & R17 that was made without justification during the previous iteration of the draft Local Plan. The previous iteration of the policy required vehicular access to be provided from "Doddinghurst Road for both site and/or Karen Close and Russell Close". The current policy is worded to allow for vehicular access from Doddinghurst Road only.
Whilst access from Doddinghurst Road is accepted as the preferred strategy for all parties, initial appraisal work in this respect has recognised a potential requirement for significant levelling and land movement which could have implications on the viability of housing delivery on the site. It is therefore requested that the policy retains flexibility for the use of the other accesses from Karen Close and Russell Close as a worst case scenario, in the interests of protecting the deliverability of the southern parcel of the site, particularly as these routes of access have been previously agreed with Essex County Council Highways. The use of these accesses may also better support the design of scheme that is fully integrated with existing development.
Countryside continue to support Brentwood in the progression of their Local Plan, but wish to emphasise the continuing importance of minor amendments to specific policies, alongside the need for consistent housing delivery across the entire Plan period. This is important to ensure that the Plan is deliverable and found sound at Examination.

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