Object

Representation ID: 376

Received: 02/10/2013

Respondent: JTS Partnership LLP

We note that the overriding priority given to protecting the Green Belt means that the Council has chosen not to plan for 'objectively assessed housing needs'. As such, we consider that Brentwood Council may find it difficult to convince an
Inspector that the Plan is 'sound. It is our view that the Plan would be more robust if the Council could find additional housing sites, consistent with the Spatial Strategy set out in the policy, and if it also undertook a limited review of the Green Belt, in order to remove that land which clearly serves no Green Belt function.

Object

Representation ID: 377

Received: 02/10/2013

Respondent: JTS Partnership LLP

The Council in deciding to plan for a figure well below 'objectively assessed housing needs' makes it all the more important that it maximises, in order of preference, the potential of:
a) existing developed sites within the urban areas;
b) suitable undeveloped sites within the urban areas;
c) suitable existing developed sites in the Green Belt; and,
d) suitable undeveloped sites in the Green Belt (i.e. sites which fulfil no or a limited Green Belt function).
It is the Partnership's view that the Council will need to identify sites if it is to produce a 'sound' Local Plan.

Support

Representation ID: 378

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS supports the strategic sites identified by the Borough Council, but we again note our concerns about the failure to provide for 'objectively assessed housing
needs'. We also highlight the fact that it may be necessary for the Council to identify further large, strategic, sites, if the Plan is to be found 'sound' and consistent with NPPF guidance.

Support

Representation ID: 379

Received: 02/10/2013

Respondent: JTS Partnership LLP

Whilst we generally support the identification of the former M25 Works Compound for development as a new business park, we have to question whether it can be considered as a previously developed 'brownfield' site. It is our understanding that the M25 Work Compound was constructed, under permitted development rights, as part of the recent widening of the M25 motorway. With the M25 improvements completed, and the site vacated, the General Permitted Development Order requires that the land be returned to its original state (i.e. open countryside). Accordingly, it is questioned whether it can be defined as 'previously developed' land.

Support

Representation ID: 380

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS generally supports the objectives underlying this policy, which provides sufficient flexibility for schemes to take account of local circumstances and any particular constraints appertaining to a site. Hence, we consider that there is a potential conflict between Policy CP8 and Policy DM24. The latter
acknowledges that, whilst 35% of all new dwellings should be affordable, this target may be reduced, in certain circumstances, it may not be possible to provide any affordable housing, where this threatens the viability of a scheme.
This needs to be reflected in Policy CP8 and the second paragraph needs amending-see attachment.

Object

Representation ID: 382

Received: 02/10/2013

Respondent: JTS Partnership LLP

Given the inability of the Council to make provision for 'objectively assessed housing needs'it must seek to maximise the amount of housing land it can allocate in accordance with its preferred spatial strategy, including identification of existing developed sites in the Green Belt. Whilst not advocating a 'root and branch' review of the Green Belt, we consider that the Council will
need to review its boundaries and remove land which clearly does not serve a Green Belt function or which can, otherwise, be developed without causing
harm to the openness of the Green Belt.

Comment

Representation ID: 383

Received: 02/10/2013

Respondent: JTS Partnership LLP

We commend the Council's commitment to fostering economic growth and, in particular, the support expressed for development that diversifies, and grows, the local economy.
We are, however, disappointed that the policy does not recognise the contribution that tourism can make to the local economy, growth prospects and the provision of new jobs. An additional criterion should be added to the policy confirming the Borough Council's support for proposals which increase visitor numbers to the
Borough and/or which provide visitor accommodation.

Support

Representation ID: 384

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS generally supports this policy and, in particular, the commitment to make the best use of previously developed land. However, and given the inability of the Council to plan for 'objectively assessed housing needs', the Council has to give consideration to also releasing, and identifying, undeveloped sites, within the existing urban area, which serve no particular
function.

Comment

Representation ID: 385

Received: 02/10/2013

Respondent: JTS Partnership LLP

We note the Council's preferred growth option and the fact that it seeks to identify both existing employment sites and land for new employment development. However, we consider that the Council has omitted a number of sites which are currently being used for employment purposes and that, accordingly, this part of the policy needs to be reviewed. We fully support Brentwoods decision to reallocate a number of existing employment sites for
alternative development (such as the Wates Way Industrial Estate), where the proposed alternative use(s) make more efficient use of the land and helps satisfy the shortfall in housing land.

Support

Representation ID: 386

Received: 02/10/2013

Respondent: JTS Partnership LLP

We support the preferred growth option underlying this policy and the emphasis placed on meeting the need for additional comparison, and convenience, retail floor space primarily in Brentwood town centre and at West Horndon.