Object

Representation ID: 30055

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

The proposed wording in relation to non-designated heritage assets is not consistent with Paragraph 203 of the NPPF. Currently, the wording directly weighs harm/loss versus public benefit which goes beyond the policy test for non-designated heritage assets and has not been justified.

Object

Representation ID: 30063

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

CEG generally supports the proposed amendments to Policy SP02. However, an amendment is required to make the policy effective and to aid clarity. The quantum of housing development required to be built within the Borough across the plan-period is a minimum; at present it could be read that the figure is a cap. The change below would ensure consistency with the NPPF (2021); specifically paragraphs 60 and 61. It would also ensure the policy is positively prepared.

Object

Representation ID: 30064

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

Reviewing the wording of the proposed amendments to Policy BE08 (formerly BE11), the policy as
written is not justified. This is because contributions could be sought from developments for specific
infrastructure that do not directly relate to it as required by Paragraph 57 of the NPPF and article 122
of the 2021 Community Infrastructure Levy Regulations (as amended). For example, Dunton Hills
Garden Village on the proposed wording could be required to contribute to circulation arrangements,
public realm and multimodal integration around Brentwood, Shenfield and Ingatestone stations;
which would not be appropriate.

Object

Representation ID: 30065

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

CEG is committed to the delivery of self and custom build housing at Dunton Hills Garden Village. 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% is not justified by the current evidence base and this position has not changed since the Regulation 19 consultation during which CEG made similar objections to Policy HP01.
The wording of the policy does now account for this; linking self-build delivery to evidence of need. However, futher amendments should be made.

Object

Representation ID: 30066

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

Supports replacing SHMA reference with “housing evidence”. However, the policy needs to be more flexible for larger strategic sites which have specific challenges associated with delivering homes across multiple phases over the plan period. The current wording applies the tenure split too rigidly. For these developments, the policy needs to consider when infrastructure is delivered, viability, and the overall tenure split for the site as each plot comes forward. DHGV will be delivered up-to and post 2033. Hence there is a need to consider and account for potential for changes to the housing needs over such a long period.

Object

Representation ID: 30067

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? Yes

The policy (PC04, formerly PC08) is sound and CEG supports its aims. The addition of a reference to the two neighbourhood hubs – to be defined ‘local centres’ – at Dunton Hills Garden Village is supported as are the amendments to footnote 10. However, the wording of the policy should be amended to make it clearer.

Object

Representation ID: 30224

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

MM84 relates to changes to Policy R01(I). CEG support the amendments as these make the policy clearer and more effective; specifically, the proposed quantum and sizes of the various types of uses that will be accommodated at Dunton Hills Garden Village. This includes the potential for a co-located primary and secondary school on a 7.9ha site. However, amendments are still required to ensure the policy is effective (NPPF, Paragraph 35) and clearer.

Object

Representation ID: 30225

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

CEG is generally supportive of the changes to the policy including the consolidation of former Policy R01(III). However, there are some further amendments that are required to ensure the policy is positively prepared, justified, and effective (NPPF, Paragraph 35). They will also aid clarity. These relate to how the garden village will come forward, especially in respect of the order of development.