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: 807

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

We agree with the site selection criteria put forward in Policy S1. With regard to Officers Meadow, as set out in the SHLAA (October 2011), this site is suitable for development as it is located in a sustainable location, close to the Shenfield shopping area and rail station.The site has been promoted by Croudace Strategic for many years. Throughout the Local Plan preparation process a number of technical studies have been carried out to demonstrate that development is deliverable and that any adverse impacts can be minimised. The site is currently available and can come forward for development in the immediate future ,thus offering an excellent opportunity to contribute to the requirement to deliver much needed new housing.

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Local Plan 2015-2030 Preferred Options for Consultation

2.29

Representation ID: 809

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Para 2.20 of the Local Plan states that the Council has carried out a technical exercise to objectively assess development needs, and the preferred spatial strategy seeks to accommodate a 'significant proportion of this need'. Para 2.20 goes on to state that "due to significant capacity constraints, however, it is not possible to accommodate fully the scale of growth implied within the context of a coherent spatial strategy in accordance with sustainable development principles set out in the NPPF". By implication, BBC must be looking to neighbouring authorities to meet its unmet need through a 'Duty to Cooperate'. As matters stand it is unclear what the Council is actually doing in terms of "exploring options" with adjoining districts as there is no evidence available to demonstrate that BBC has effectively cooperated to plan for issues with cross-boundary impacts (NPPF Para 181). Given that neighbouring authorities are relying on housing to be delivered beyond their boundaries, it is unlikely that BBC's unmet housing needs will be able to be accommodated sustainably elsewhere. No definitive solution to the identified shortfall in future housing provision has been put forward.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy DM23 Housing Land Allocations - Major Sites

Representation ID: 812

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

It is evident in the draft Local Plan that there are no (our emphasis) major sites identified in Shenfield, despite the availability of a highly sustainable site at Officers Meadow which was included in the SHLAA (ref. G091) as a potential Greenfield site. The Officers Meadow site is a 20.4 ha site with capacity to accommodate in the region of 500 dwellings, together with generous public open space. Officers Meadow is one of only two Greenfield Sites assessed and deemed to have potential for residential development' in Shenfield within the SHLAA. The other Greenfield site in Shenfield assessed to have potential is site ref G143 Land Adjacent to 110 Priests Lane which only has capacity for an infill development of one dwelling.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP13: Sustainable Transport

Representation ID: 813

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

The Council has not discussed the 'Park and Walk' proposal with either the landowners of Officers Meadow or Croudace Strategic. Consequently the full implications of the Council's aspirations remain something of a mystery. Whilst we agree that Officers Meadow constitutes a highly sustainable location for development, it would not be appropriate to develop the entire site as a car park. Such an outcome would be considered as a sadly missed opportunity in the context of meeting objectively assessed housing needs and identifying sustainable sites for residential development in Shenfield.

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Local Plan 2015-2030 Preferred Options for Consultation

S3: Job Growth and Employment Land

Representation ID: 814

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Given the NPPF requirement and considering the Heart of Essex Economic Futures Study, we maintain the view that the Council cannot use the Borough's Green Belt location as an excuse for not meeting the necessary land requirements. There are sites on the edge of the Borough's main settlements which can accommodate new homes and employment floorspace in order to facilitate local economic growth and address housing pressures whilst at the same time protecting the most valuable Green Belt land.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP3: Strategic Sites

Representation ID: 815

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Three out of four of the strategic sites identified in Policy CP3 are within Brentwood. We are very concerned that there are no strategic sites identified within Shenfield, despite the Council's preferred spatial strategy as set out in Policy S1. The lack of a strategic site in Shenfield undermines the overall spatial strategy for the Borough. In our view, Officers Meadow is recognised as being in a sustainable location within easy walking distance of Shenfield and its station.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP4: West Horndon Opportunity Area

Representation ID: 816

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

1. The Council's preferred option appears to be a combination of Alternative Options 1 and 2. A large proportion of new development is expected to take place in Brentwood, but there are limits as to how much development the town could accommodate. It is therefore necessary to consider more than one strategic location for development. Alternative Option 2 puts forward transport led growth, with development at settlements with a rail station (i.e. Brentwood, Shenfield, Ingatestone and West Horndon). The Local Plan states that growth is planned for all places with a rail station, apart from Ingatestone which is excluded due to infrastructure constraints and a lack of suitable sites.
2. We are perplexed by the absence of any strategic sites being put forward at Shenfield. We are equally bemused by the decision to include West Horndon as a strategic location. Whereas Brentwood and Shenfield are sustainable locations for growth, given their excellent transport links, access to jobs and services and town centre facilities. West Horndon conversely requires "significant improvements to infrastructure and services" (para 2.4 of the Local Plan).
3. In terms of the settlement hierarchy set out in the background to Policy S1, Brentwood and Shenfield fall within Settlement Category 1 Main Town and are recognised as offering "the most scope to develop in accordance with sustainable development principles" (para 2.13 of the Local Plan). West Horndon by contrast falls within Settlement Category 3 Larger Villages. Whilst development on existing previously developed sites/redundant industrial land in West Horndon could be delivered in the short term, the infrastructure constraints associated with this village cannot support extensive sustainable development and we are not convinced that the necessary substantial infrastructure improvements will come forward during the Plan period.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP8: Housing Type and Mix

Representation ID: 817

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

The policy goes on to state that sites of six units or above are required to provide at least 50% one and two bed units. Whilst we support a mix of dwelling types and sizes, we are concerned that the background evidence to support this policy is not available during the consultation process on the Preferred Strategy. Without the ability to review these documents, it is difficult to make a judgement on the appropriateness of the preferred strategy, particularly in relation to the 50% one and two bed unit requirement.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP10: Green Belt

Representation ID: 818

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

The draft Local Plan provides an opportunity to review Green Belt boundaries and to make adjustments where necessary. In Brentwood Borough, where over 80% of the Borough lies within the Green Belt, it is inevitable that in order to meet housing land requirements, a review of the Green Belt boundary is necessary as part of the Local Plan process. It is therefore a real concern that a key document in the evidence base to this policy is not available at the time of the consultation process- Landscape Sensitivity Testing and Green Belt Assessment.

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Local Plan 2015-2030 Preferred Options for Consultation

Policy CP11: Strong and Competitive Economy

Representation ID: 819

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

We support this policy approach and note in particular the sentiments of Policy CP 11 which seeks to capitalise on the economic benefits that arise from Crossrail. We maintain the view that economic development requires the delivery of new homes as well as the creation of jobs and workplaces. Whilst the Borough does have existing constraints in terms of Green Belt, it is important to provide sufficient sites in and around the main centres to meet housing need and economic growth requirements. A review of the Green Belt boundary is therefore essential.

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