Support

Representation ID: 820

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We support the policy approach of Policy CP14.

Object

Representation ID: 821

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Criteria (f) refers to biodiversity. In our view, the wording of criteria (f) is too general and the reference to "around developments" is too vague. Whilst measures to incorporate biodiversity within development sites should be encouraged, the ability to deliver biodiversity opportunities on land outside of the application site boundary or allocated site boundary may prove difficult and ultimately affect the delivery of the site. Therefore the wording of criteria (f) of Policy DM1 should be changed and the reference to "around developments" deleted.

Object

Representation ID: 822

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We would question whether Policy DM2 is required as this policy appears to duplicate Policy DM1. Whilst we acknowledge that development proposals are required to address links with adjoining sites, incorporate features of value and design-out crime, these could be (and arguably are already) incorporated within Policy DM1.

Object

Representation ID: 823

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

This policy is overly prescriptive in terms of density requirements. Whilst we support the Council's aspirations to meet its housing requirements through the Local Plan and agree that developers are required to use land efficiently, a policy that sets a blanket density requirement across the Borough may create viability/deliverability issues for sites coming forward. Similarly, it may also be directly at odds with Policy DM1 in requiring higher residential densities than those in the surrounding area, affecting the general character of the area.

Object

Representation ID: 826

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Whilst we note that Policy DM11 broadly follows the guidance on Green Belts as set out in the NPPF, we are concerned that the Green Belt and Landscape Sensitivity Study (part of the evidence base) is not currently available at the time of the public consultation exercise. Therefore it is difficult to fully assess the soundness of this policy. We are of the view that a review of Green Belt boundaries should be carried out. We strongly believe that Officers Meadow should be removed from the Green Belt and allocated as a major housing site under Policy DM23.

Object

Representation ID: 828

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The policy is very precise on smaller sites and the amount of affordable housing required.

Whilst we accept that the Borough has a high level of housing need, such a prescriptive policy for smaller development sites is likely to have an effect on development viability and may ultimately affect the delivery of smaller sites.

Similarly the requirement for 'at least' 35% affordable dwellings may cause viability problems for the delivery of some larger sites. Setting a 35% target for all sites of 15 dwellings or more would be more realistic and more effective in delivering housing sites across the Borough.

Object

Representation ID: 829

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We do not support the policy as it relates to Lifetime Homes, which we consider to be unduly onerous. We would however support a revised policy wording requiring that a reasonable proportion of homes on new developments should meet Lifetime Homes Standard.

Support

Representation ID: 830

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We support the principle of SuDs drainage and would emphasise that the preliminary drainage strategy for Officers Meadows has been designed accordingly.

Object

Representation ID: 3400

Received: 02/10/2013

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy S1 requires that all development sites are to be identified in accordance with the selection criteria. Policy S1 also states that other than the strategic allocation at West Horndon and minor changes to accommodate proposed development on existing developed sites in the Green Belt, no change to Green Belt boundaries is envisaged. We disagree with this approach for a number of reasons:
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.