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Strategic Growth Options

Question 1

Representation ID: 6616

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

The Borough logically splits itself into three identified areas, which are of different character. The Borough contains two main infrastructure corridors, with more rural villages to the north and each area provides different development opportunities. The growth figure of 5,500 dwellings for the next 15 years is supported, however it is considered optimistic that 2,500 dwellings will come from the brownfield sites within the urban area.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Comment

Strategic Growth Options

Question 2

Representation ID: 6617

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Comment

Strategic Growth Options

200 Entire Land East of A128, south of A127

Representation ID: 6618

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

Very unlikely that Dunton Garden Suburb will make any contribution to current 5 year housing supply or that will be built out in this Local Plan period. It is an allocation that will cover two Local Plan periods and the Council will therefore need to allocate additional land in this Local Plan.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Comment

Strategic Growth Options

Question 3

Representation ID: 6619

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with para 84 and 85 NPPG guidance. Boundaries to follow clear, recognisable, physical features and Green Belt not to include land which is unnecessary to keep open (such as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Comment

Strategic Growth Options

Question 4

Representation ID: 6620

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Comment

Strategic Growth Options

Question 5

Representation ID: 6621

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Comment

Strategic Growth Options

Question 6

Representation ID: 6622

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

These comments have been directed to the main urban area.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Support

Strategic Growth Options

Question 7

Representation ID: 6623

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Support

Strategic Growth Options

Question 8

Representation ID: 6624

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

No further comment

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

Attachments:

Support

Strategic Growth Options

Question 9

Representation ID: 6625

Received: 17/02/2015

Respondent: JTS Partnership LLP

Representation Summary:

There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Full text:

Q1: Yes - The Borough logically splits itself into three identified areas, which are also of
different character. It is sensible to look at the main infrastructure corridors as
individual areas. In particular to identify the central A12 Corridor as this includes the
main settlements of Brentwood and Shenfield and which is favourable in
sustainability terms.
Q2: Yes and No - There is the implied suggestion in Paragraph 2.17 that development opportunities will only be considered alongside opportunities surrounding the urban area within the Green Belt. As the main centres are the most sensible and sustainable to focus development the LPA should look at all sites including greenfield within the urban area, as well as the urban edges.

Q3: Yes - There are a number of urban edge sites in sustainable locations which will be logical rounding off or infill within the Green Belt, which will make good housing sites, contributing to the relevant small local communities as well as indirectly established community facilities.

The Council should follow a hierarchical approach to identifying land to meet
residential need, along the following lines:

1. Existing urban areas
2. Existing developed sites in Green Belt
3. Review of Green Belt boundaries to ensure consistency with Para 84 and 85
NPPG guidance. Boundaries to follow clear, recognisable, physical features
and Green Belt not to include land which is unnecessary to keep open (such
as land surrounded by development or which is part of a village).
4. Release of sites on the edge of existing settlements.
5. New settlements (Dutton Garden Suburb).

It is only by following a hierarchical approach, and analysing the impact of the Green
Belt at each stage, that the Council can assure itself that the overall impact of the
Green Belt will be minimised.

If this analysis justifies the release of the Dutton Garden Suburb then (for the
reasons that we indicate in the following question) it is very unlikely that it will make
any contribution to current 5 year housing supply or that will be built out in this Local
Plan period. It is an allocation that will cover two Local Plan periods and the Council
will therefore need to allocate additional land in this Local Plan.

Q4: The focus of this submission is centred on the A12 Corridor and key housing sites. This firm makes representations on other employment issues in separate representations.

Q5: Yes - See comments under Q3 above. Having looked within the urban areas at all potential sites it is sensible and in accordance with the NPPF to consider releasing sites on the edge of urban areas within this corridor. It is evidenced from the housing needs data that the LPA will need to consider the long term need of the
Borough and release sustainable edge of urban area sites, as well as any longer term strategic releases.

Q6: These comments have been directed to the main urban area.

Q7: Yes - Employment comments have been made in separate representations but we would consider that the most sustainable approach is to allocate new sites close to the strategic highway network and provide a wide choice of sites.

Q8: Yes - No further comment.

Q9: Yes - There are opportunities to take a more pragmatic approach to open space to ensure deliverability of some space for public use where none currently exists.

Q12: Yes - No comment.

Q13: No comment.

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