Local Plan 2015-2030 Preferred Options for Consultation
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Local Plan 2015-2030 Preferred Options for Consultation
Policy DM29: Accessible, Adaptable Development
Representation ID: 414
Received: 02/10/2013
Respondent: JTS Partnership LLP
As with affordable housing policy DM24, the need to provide 5% Lifetime Homes dwellings, in all new developments of 20 dwellings or more, should be subject to a viability assessment.
see attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM30: Provision of Open Space in New Development
Representation ID: 415
Received: 02/10/2013
Respondent: JTS Partnership LLP
Whilst JTS supports the policy, it objects to the requirement, set out in supporting paragraph 4.129, that 15% of a site, on which 50 or more dwelling units are to be proposed, should be set aside for public open space.
The objection is based on the fact that the draft Local Plan provides no justification for this figure and it would result in an efficient use of land.
see attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM31: Protection and Enhancement of Open Space, Community, Sport and Recreational Facilities
Representation ID: 417
Received: 02/10/2013
Respondent: JTS Partnership LLP
An objection is raised to this policy on the basis that it is not possible to assess its full impact until the Proposals Map has been published.
We can see no justification as to why the Council would have a starting position of protecting (i.e. set a presumption against the development of) "other previously undeveloped land" within urban areas. Given the shortage of housing land, which is in-built into the draft Plan , the Council needs to make the best use possible of all land within the urban areas, whether previously developed or previously undeveloped.
see attached
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM37: Contaminated Land and Hazardous Substances
Representation ID: 418
Received: 02/10/2013
Respondent: JTS Partnership LLP
JTS considers that the Borough Council should give consideration as to how the requirements of the second paragraph relate to the guidance set out in Circular 11/95: Use of Conditions in Planning Permissions.
Whilst it may be good practice to request that a Phase 1 Desk-Top Study be submitted with a planning application, Phase 2 and Phase 3 matters can often be dealt with by condition.
see attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM38: Parking
Representation ID: 419
Received: 02/10/2013
Respondent: JTS Partnership LLP
We welcome the flexibility built into this policy and, in particular, the inference that the Parking Standards, which have been adopted as supplementary planning guidance, will not be slavishly followed and that parking requirements will be assessed in relation to the type of development proposed, the intensity of use
and the location.
see attached
Comment
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM8: Supporting the Rural Economy
Representation ID: 420
Received: 02/10/2013
Respondent: JTS Partnership LLP
We note, with regret that the Council has not included a specific policy on riding schools and stables within the draft plan. Given the contribution that such business make to the rural economy, we request that policies, similar to those in the current local plan be included in the next draft- see attachement for wording.
see attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
S1: Spatial Strategy
Representation ID: 505
Received: 02/10/2013
Respondent: JTS Partnership LLP
Agent: JTS Partnership LLP
The Council‟s preferred spatial strategy seeks to focus the majority of new development, a) within the existing urban areas of Brentwood and Shenfield, b) at a new strategic allocation at West Horndon and c) on suitable previously developed sites in the Green Belt. Whilst it acknowledges the difficult balancing act that the Council has to perform, in preparing a Local Plan that fulfils the economic, social and environmental roles ascribed to the planning system by the NPPF (paragraph 7), it is noted that the overriding priority given to protecting the Green Belt means that the Council has chosen not to plan for OAN (as is required by paragraphs 17, 47 and 182 of the NPPF). As such, it considers that the Borough Council may find it difficult to convince an Inspector, at the forthcoming Examination, that the Plan is "sound‟. It is also noted that the failure to make provision for full housing need is inconsistent with the Plan‟s Vision, with Strategic Objective SO8 and with the Council‟s Corporate Plan. It is the Company‟s 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.
See Attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
2.29
Representation ID: 506
Received: 02/10/2013
Respondent: JTS Partnership LLP
Agent: JTS Partnership LLP
It is noted that the Borough Council has decided to place greater emphasis on the need to protect the Green Belt, than the need to provide for full OAN. As a result, the policy makes provision for 3,500 new dwellings against an interim OAN of 4,962 to 5,600 dwellings (331 to 373 homes a year). The fact that the Council has decided to plan for a figure well below this figure 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 only a limited, green belt function and which should be identified for residential development following a limited review of green belt boundaries). It is the Company‟s view that the Council will need to identify sites falling within all of the above four categories if it is to produce a "sound‟ Local Plan.
See Attached
Object
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM23 Housing Land Allocations - Major Sites
Representation ID: 507
Received: 02/10/2013
Respondent: JTS Partnership LLP
Agent: JTS Partnership LLP
The identified land (attached) are two small field parcels on each side of the entrance to Moat Farm. Moat Farm buildings to the north enclose the two field parcels while the defined settlement boundary and residential
dwellings of Pilgrims Close abut the west boundary. The southeast boundary is defined by Crow Green Road itself and residential development fronting onto the
road to the south and east. In summary the allocation of these small parcels is a 'logical rounding off' with no appreciable impact on the purposes of maintaining the green belt in this location.
See Attached
Support
Local Plan 2015-2030 Preferred Options for Consultation
Policy DM11: New Development in the Green Belt
Representation ID: 508
Received: 02/10/2013
Respondent: JTS Partnership LLP
Agent: JTS Partnership LLP
We generally support this objectives underlying this policy but consider that it needs substantial amendment in order to bring it into line with relevant NPPF guidance. See attachment.
See Attached