Object

Representation ID: 446

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

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 is acknowledged 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 also 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.

Object

Representation ID: 453

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

The fact that the Council has decided to plan for a figure well below "objectively assessed housing need‟
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 Company‟s view that Brentwood needs to identify additional sites to produce a "sound‟ Local Plan.

Support

Representation ID: 454

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

Sans Souci supports the Council's decision to adopt the growth option underlying this policy and the employment allocations arising there from.

In particular, the Company is pleased that the Borough Council had recognised the failings, and inadequacies, of the Wates Way Industrial Estate, as both a site, and location, for 'traditional' employment activities. Accordingly, the Company fully supports the Borough Council's decision to reallocate the site for residential development (Policy DM23) and to make provision, within Policy S3, for the nominal loss of existing employment land that will arise from the reallocation/redevelopment of the site.

Object

Representation ID: 455

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

Subject to the reservations expressed in relation to Policies S1 and S2, the Company generally supports the proposed settlement hierarchy (para‟s 2.12 to 2.16), together with the role ascribed to each settlement therein.

Support

Representation ID: 456

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

The Company supports the identification of the former M25 Works Compound for development as a new business park.

Support

Representation ID: 458

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

Sans Souci generally supports the objectives underlying this policy, whilst at the same time, providing sufficient flexibility for schemes to take account of local circumstances. The Company does, however, consider there is potential conflict between Policy CP8 and Policy DM24.

DM24 acknowledges that, whilst the policy seeks 35% of all new dwellings be affordable, this target may be reduced and 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. Accordingly, the second sentence, of the first paragraph, should be amended.

Object

Representation ID: 459

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

See reservations expressed with respect to Policies S1, S2 and CP1.

Support

Representation ID: 460

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

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, with a scheme, can significantly increase the cost of new development and can, therefore, in certain instances,
threaten viability. Accordingly, 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: 461

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

It is considered that this policy should be reworded as, whilst no objection, in principle is raised 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. Accordingly, the second sentence of the policy should be redrafted as per attached.

Comment

Representation ID: 462

Received: 02/10/2013

Respondent: Sans Souci Enterprises Limited

Agent: JTS Partnership LLP

The Company considers 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, necessary off-site infrastructure, that 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.