Support

Representation ID: 510

Received: 02/10/2013

Respondent: JTS Partnership LLP

Agent: JTS Partnership LLP

JTS generally supports this policy. We consider that the policy introduces, in accordance with NPPF guidance, a degree of flexibility and will allow genuine in-fill plots, which, although currently located in the Green Belt, in practice, serve no Green Belt function, to be brought forward for development.
However, we are of the view that there are many more 'relevant frontages', than are currently listed in the policy, to which it should apply. Accordingly, the Council should review the frontages to which the policy applies.

Object

Representation ID: 512

Received: 02/10/2013

Respondent: JTS Partnership LLP

Agent: JTS Partnership LLP

This policy needs to be substantially reviewed as it is inconsistent with NPPF guidance and, accordingly, is unsound.The way that the policy is currently worded, suggests that the Council will only grant permission for residential extensions in the Green Belt in 'very special circumstances'.
Clearly, however, 'very special circumstances' do not need to be proven for appropriate development - i.e. an extension or alteration to a residential building that does not result in a disproportionate addition. The policy must be reworded to reflect NPPF guidance (Paragraph 89).

Object

Representation ID: 513

Received: 02/10/2013

Respondent: JTS Partnership LLP

Agent: JTS Partnership LLP

This policy is unsound and needs to be reviewed in order to bring it into line with the National Planning Policy Framework.

Object

Representation ID: 514

Received: 02/10/2013

Respondent: JTS Partnership LLP

Agent: JTS Partnership LLP

This policy must be reviewed in order to ensure that it is consistent with NPPF guidance (paragraph 90). The only tests set out in the NPPF, are that: -
* the proposal should preserve openness; and that,
* the building should be of permanent and substantial construction. All other criteria should be omitted from the policy as they are dealt with by other policies in the plan (i.e. Policy DM1).

Re: Criterion fii) is entirely inconsistent with both NPPF policy and also the significant shortfall in Brentwoods land requirment to meet 'objectively assessed housing needs'.

Support

Representation ID: 3379

Received: 02/10/2013

Respondent: JTS Partnership LLP

JTS supports this policy, which is reflective of relevant guidance set out in the NPPF. We are, however, of the opinion that it will take a "sea change" in the culture of the planning department, and an injection of significant additional resources, if it to deliver the commitment to, "work proactively with applicants jointly to find solutions..", so that, "..proposals can be approved wherever possible.."

Support

Representation ID: 3380

Received: 02/10/2013

Respondent: JTS Partnership LLP

Subject to the reservations expressed in relation to Policies S1 and S2, we generally support the proposed settlement hierarchy (paragraphs 2.12 to 2.16), together with the role ascribed to each settlement therein. Although we not express the view either way, we note a potential inconsistency between criterion c and the NPPF requirement to plan for "objectively assesssed housing needs." In that respect, there is also a potential conflict between criteria c and g.

We consider that a draft Proposal Map should have been published alongside the draft Plan. This would have helped with an understanding, and interpretation of proposed policies.

Object

Representation ID: 3381

Received: 02/10/2013

Respondent: JTS Partnership LLP

As a preliminary point, we highlight a concern that the Council has not yett published the Objectively Assessed Needs for Brentwood housing report. As an objective assessment of housing needs should form the basis of the growth strategy, which underpins the Plan, the absence of such information considerably compromises the ability of stakeholders to prepare full representations.