Schedule of Potential Main Modifications

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Schedule of Potential Main Modifications

MM101

Representation ID: 29735

Received: 11/11/2021

Respondent: The Ursuline Sisters Brentwood CIO

Agent: JTS Partnership LLP

Representation Summary:

The upward revision to 75 dwellings is welcomed and better reflects the NPPF requirement to make efficient use of land although our previous response on F78 demonstrated how greater provision can be achieved while continuing to reflect local character.

1(e) and Para.9.175 - Any financial contribution being sought should be proportionate to the historic provision which was as a single playing pitch. The Council have not provided details of how such a contribution is calculated.

Full text:

The upward revision to 75 dwellings is welcomed and better reflects the NPPF requirement to make efficient use of land although our previous response on F78 demonstrated how greater provision can be achieved while continuing to reflect local character.

1(e) and Para.9.175 - Any financial contribution being sought should be proportionate to the historic provision which was as a single playing pitch. The Council have not provided details of how such a contribution is calculated.

Object

Schedule of Potential Main Modifications

MM29

Representation ID: 29736

Received: 11/11/2021

Respondent: The Ursuline Sisters Brentwood CIO

Agent: JTS Partnership LLP

Legally compliant? Yes

Sound? Yes

Representation Summary:

New paragraph 5.145 states that "designated Urban Open Spaces....provide an important multi-functional local resource to residents and therefore, are to be protected." The Local Plan Proposals Map is largely unchanged in respect of such designations, however, the 2017 Brentwood Open Space Strategy assessed the value of all sites. Site ID19b was ranked at the lowest level (1 out of 5) for public accessibility and Recreational Value, and 2 fore amenity value. This low value rating conflicts with the above statement and questions the worthiness of their protection.

Full text:

New paragraph 5.145 states that "designated Urban Open Spaces....provide an important multi-functional local resource to residents and therefore, are to be protected." The Local Plan Proposals Map is largely unchanged in respect of such designations, however, the 2017 Brentwood Open Space Strategy assessed the value of all sites. Site ID19b was ranked at the lowest level (1 out of 5) for public accessibility and Recreational Value, and 2 fore amenity value. This low value rating conflicts with the above statement and questions the worthiness of their protection.

Object

Schedule of Potential Main Modifications

MM33

Representation ID: 29739

Received: 11/11/2021

Respondent: The Ursuline Sisters Brentwood CIO

Agent: JTS Partnership LLP

Legally compliant? Yes

Sound? Yes

Representation Summary:

Criteria A(a) of Policy NE05 provides the exception to the presumption against development of open spaces, where assessment can demonstrate the function it performs is "surplus to requirements". Such wording is vague and unhelpful and will be extremely subjective. New paragraph 5.145 (see MM29) states that the presumption against will exist for open spaces which "provide a significant amenity resource". This is the much clearer test that should be applied and better reflects the multi-functional qualities of open space which are not always best assessed against a test of being surplus to requirements.

Full text:

Criteria A(a) of Policy NE05 provides the exception to the presumption against development of open spaces, where assessment can demonstrate the function it performs is "surplus to requirements". Such wording is vague and unhelpful and will be extremely subjective. New paragraph 5.145 (see MM29) states that the presumption against will exist for open spaces which "provide a significant amenity resource". This is the much clearer test that should be applied and better reflects the multi-functional qualities of open space which are not always best assessed against a test of being surplus to requirements.

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