Object

Representation ID: 517

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The draft LDP does not appear to contain a Borough-wide map to allow for easy appreciation of those sites in DM23 in the context of their locality. Accordingly, it is recommended that a further plan be produced which identifies the 22 allocations (together with Alternative Allocations) within this context. Although Land at Priests Lane (Clients Site) would make for a reasonable alternative residential site, its specified reason for such a conclusion is relatively sparse. Therefore we wish to provide supporting evidence for land at Priests Lane as a sustainable and preferred alternative to other sites included in Policy DM23.

Object

Representation ID: 520

Received: 02/10/2013

Respondent: Ursuline Sisters

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: 523

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters consider that in identifying sites within the key location of the Brentwood and Urban Area, brownfield land within the designated Brentwood Town Centre has been overlooked - namely land at Eastfield Road, Brentwood.

Support

Representation ID: 524

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters generally support this policy, which reflects guidance set out in the NPPF. However, their experiences at both the pre-application and post submission stage is one of often considerable delays and it is therefore questionable whether such a commitment to "work proactively with applicants jointly to find solutions ..." so that "...proposals can be approved wherever possible..." is achievable without a significant investment in the department, in particular to provide a greater number of experienced planning officers.

Support

Representation ID: 525

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters generally support this policy for managing growth. However it is considered that the Council should also have regard to the ability of a site to bring forward significant community and other benefits when allocating or granting planning permission. Where such benefits clearly outweigh the harmful impact of the development, planning permission should be granted. Consequently, the following criteria (h) should be added to Policy CP2:
"h. The opportunity to secure significant community or other benefits,
consistent with the Spatial Strategy and the presumption in favour of
sustainable development".

Comment

Representation ID: 526

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters have no objection to the principle of this policy but do, however, find it to be inconsistent with Policy DM24. The final paragraph of Policy DM24 provides flexibility in the provision of affordable housing
to reflect any local circumstances and/or any particular constraints where its provision would threaten the viability of development. This needs to be reflected in Policy CP8. Accordingly, the second sentence of the first paragraph should be amended as follows:-
"Subject to the requirements of Policy DM24, the Council will seek to ensure
that all new residential schemes include a proportion of affordable new
homes."

Support

Representation ID: 527

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters are in support of the Council's policy to ensure future development is located in accessible locations and their commitment to promote improved sustainable transport links, in particular cycling and walking.

Object

Representation ID: 528

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Company considers that this policy should be reworded. 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 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: ..."

Comment

Representation ID: 529

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters consider that greater detail must be provided to set out how the Council intend to "assess all development proposals" when seeking "the provision of, or contribution to, the necessary on or off-site infrastructure" in the period up to the adoption of a new CIL Charging Schedule. Currently, no SPD, is in existence to either assess the impact of new development or provide a mechanism for determining the level of contribution. The absence of clarification may well lead to uncertainty for any developer.

Object

Representation ID: 530

Received: 02/10/2013

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

The Sisters object to the wording of DM1(a) which will likely have the effect of precluding almost all forms of new development. Very few forms of development will have "no adverse effect on visual amenity, the character or appearance of the surrounding locality" and it is incumbent on the Council, in seeking to achieve good planning, that all impacts of new development, whether positive or negative, are weighed against each other to reach a balanced decision.
Please amend as per attached.