Object

Representation ID: 424

Received: 02/10/2013

Respondent: Joy Fook Restaurant

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.

Object

Representation ID: 426

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

Given that the Council has decided 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 or provide only a limited, Green Belt function. On this basis Joy Fook Restaurant (falls within catogory c above) and should be identified for residential development.

Support

Representation ID: 427

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

We generally support the proposed settlement hierarchy (paragraphs 2.12 to 2.16), together with the role ascribed to each settlement therein.
Although we do not express a view either way, we note a potential inconsistency between criterion c and the NPPF requirement to plan for 'objectively assessed housing needs'. In that respect, there is also a potential conflict between criteria c and g.

Support

Representation ID: 430

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

The company supports the objectives underlying this policy. We do, however, consider that there is a potential conflict between Policy CP8 and Policy DM24. The latter acknowledges that, whilst the Council will seek 35% of all new dwellings to be affordable, this target may be reduced, and that, 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 as per attachment.

Object

Representation ID: 433

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

The Council must seek to maximise the amount of land it allocates and including the identification of existing developmet sites (Joy Fook restaurant) in the gb.
Whilst not advocating a 'root and branch' review of the Green Belt, we consider that the Council will also need to review its boundaries and remove that 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: 434

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

Whilst the objectives underlying this draft policy are to be welcomed, greater recognition needs to be given to the fact that the incorporation of sustainable construction and renewable energy technologies, within a scheme, can significantly increase the cost of new development and can, therefore, in certain instances, threaten viability. Greater flexibility needs to be built into the policy, with the third paragraph being reworded as follows:-
Where development viability is compromised by these standards, the developer/applicant will need to provide evidence as to why the targets cannot be met (either in their entirety or in part).

Support

Representation ID: 435

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

We consider that this policy should be reworded. Whilst no objection is raised, in principle, to any of the matters to which it relates, only larger development schemes will need to, and will be capable of, addressing
all the matters set out therein. As currently drafted, the policy applies to "all new development‟, whether it is a strategic site or a small scale extension to an existing property. It should be amended as per attachment.

Comment

Representation ID: 436

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

We consider that further guidance should be set out in the supporting text, to the policy, describing how the Council will assess the provision of, or contributions required to, that necessary off-site infrastructure, which it will seek from new development, in advance of it adopting a CIL Charging Schedule. Currently, the
Council has no mechanism for doing this -or for assessing the impact of new development.

Object

Representation ID: 437

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

As currently worded, this policy is unacceptable in that it states that planning permission will be refused where a proposal has any adverse impact on matters such as visual amenity, the character or appearance of the surrounding area, highway conditions or highway safety, health, environment or amenity etc.
There are very few forms of development that do not have some form of adverse impact, whatever benefits they may bring, on some interest of acknowledged planning importance. This needs to be reworded as per attachment.

Support

Representation ID: 438

Received: 02/10/2013

Respondent: Joy Fook Restaurant

Agent: JTS Partnership LLP

We generally support the objectives underlying this policy, but consider that it needs substantial amendment in order to bring it into line with relevant NPPF guidance.