Local Plan 2015-2030 Preferred Options for Consultation

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Local Plan 2015-2030 Preferred Options for Consultation

S1: Spatial Strategy

Representation ID: 706

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

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.

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Local Plan 2015-2030 Preferred Options for Consultation

2.29

Representation ID: 707

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

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

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP1: Sustainable Development

Representation ID: 708

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

The Company generally supports this policy, which is reflective of relevant guidance set out in the NPPF. It is, 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 (particularly in terms of manpower), if it is to deliver the commitment to, "work proactively with applicants jointly to find solutions ...", so that, "... proposals can be approved wherever possible ...".

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP2: Managing Growth

Representation ID: 709

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

Subject to the reservations expressed in relation to Policy S1, the Company generally supports the proposed settlement hierarchy (paragraphs 2.12 to 2.16), together with the role ascribed to each settlement therein.
Although the Company does not express a view either way, it again notes the potential inconsistency between criterion c and the NPPF requirement to plan for 'objectively assessed housing need'. In that respect, there is also a potential conflict between criteria c and g.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP8: Housing Type and Mix

Representation ID: 710

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

The Company generally supports the objectives underlying this policy, which it considers to be NPPF compliant, whilst, at the same time, providing sufficient flexibility for schemes to take account of local circumstances and any particular constraints appertaining to a proposed development.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP10: Green Belt

Representation ID: 711

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

Given the inability of the Council to make provision for 'objectively assessed housing need' the Council must seek to maximise the amount of housing land it can allocate in accordance with its preferred spatial strategy (as expressed in Policy CP1), including the identification of existing developed sites in the Green Belt. Whilst not advocating a 'root and branch' review of the Green Belt, the Council should also review its boundaries and remove that land which clearly does not serve one of the Green Belt functions as set out in paragraph 80 of the NPPF.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP14: Sustainable Construction and Energy

Representation ID: 712

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

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. 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).

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP16: Enjoyable and Quality Public Realm

Representation ID: 713

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

The Company considers that this policy should be reworded. 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 such the second sentence of the policy should be re-drafted to read:-
New development must be based on a thorough site and contextual appraisal, which is appropriate to the form, nature and scale of the development being proposed, and it should be sensitive to its context, and where appropriate, incorporate:

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Local Plan 2015-2030 Preferred Options for Consultation

Policy DM1: General Development Criteria

Representation ID: 714

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

As currently worded, this policy is unacceptable in that, on a literal interpretation, any development proposal that has an 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. would have to be refused planning permission. There are very few forms of development that do not have some form of adverse impact. The policy needs to be reworded to reflect this and the words 'no significant unacceptable impact' (or similar words to that effect) need to be added to each of the criteria.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy DM11: New Development in the Green Belt

Representation ID: 715

Received: 02/10/2013

Respondent: CLM Ltd

Agent: JTS Partnership LLP

Representation Summary:

The Council needs to review Policy DM11 in order to make sure it is entirely consistent with the NPPF definitions of appropriate and inappropriate development. As the policy currently stands, there is a conflict and it is unsound.
Furthermore, the test used to judge impact on 'openness' should be that set out in the NPPF (i.e. 'preserve openness') and the policy should be amended where a different form of wording is used.

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