Support

Representation ID: 11765

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Plan makers should ensure that the current evidence gathering and consultation exercises are used to sensitivity test some of the earlier conclusions.
For example, the strategic objective of "directing development growth to the existing urban areas of Brentwood, Shenfield and West Horndon" may need to be revisited if the new evidence suggests that an effective strategy to meet housing
requirements in full would be to develop a suitable large scale greenfield site still within the preferred broad area but on land currently in greenfield use divorced from the three identified urban areas.

Comment

Representation ID: 11767

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

The scale of development should be analysed using the full OAN and Employment need with up-to-date evidence, fulfilling the need for a positively prepared and justified plan with up-to-date and proportionate evidence as per the NPPF.
It will also be important to review the previous belief that 2,500 homes
can be accommodated on available brownfield land within the Borough, and we support paragraphs 2.11 and 3.3 stating the reasons for the increase in area needed for housing.

Object

Representation ID: 11772

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

No. We broadly agree with the issues raised within each of these areas. The most substantial issues are likely to relate to greenbelt release and infrastructure constraint / potential for improvement.

Comment

Representation ID: 11779

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

The Interim Sustainability Appraisal (SA) represents a useful start to the assessment of reasonable alternatives. It is noted that Option 1 (Dunton) is identified as ranking high in the order of preference under a number of appraisal headings. It is worth noting that where Option 1 might be seen as scoring less well there are likely to be appropriate mitigation solutions. This would be likely to apply for example in the cases of cultural heritage, flooding and soil / contamination. The attached Appendix A represents an early and more detailed assessment of the potential delivery advantages of development at Dunton.

Comment

Representation ID: 11781

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

All of the Options assessed in the interim SA and any development in the three broad areas will require the release of greenbelt land. The evidence base has always indicated that the strategic objective to "safeguard the greenbelt ..." cannot mean no encroachment into the greenbelt. There are clearly 'exceptional circumstances' to justify the alteration of the greenbelt. Under paragraph 83 of the NPPF a review should be undertaken through the preparation of the Local Plan taking into account the five purposes of the greenbelt (paragraph 80 of the NPPF) and the need to adopt a sound plan - 'positively prepared', 'justified', 'effective' and 'consistent with national policy'.

Comment

Representation ID: 11782

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

In order to satisfy the need to produce a sound plan a comprehensive greenbelt review study should be undertaken so that the impacts of all reasonable alternatives can be properly assessed and noted.

Comment

Representation ID: 11786

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Paragraph 3.12 of the SOCG rightly identifies a potential housing site option at Dunton. This option is considered in more detail within the interim SA. In our view, this option should more accurately be described as a mixed use development option. The economies of scale and location with existing access to the major junctions of the A127 afford it the opportunity to make a major and unique contribution to achieving the three dimensions of sustainable development noted in the NPPF - economic, social and environmental. Appendix A represents an early and more detailed assessment of the potential delivery advantages of development at Dunton.

Comment

Representation ID: 11788

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

In our view there is also a sixth reasonable alternative option to investigate as part of the evidence base which could be designed to concentrate on the delivery of Brentwood Borough Council's requirements only. A standalone settlement at Dunton which is not dependent on the delivery of other land to the east in the adjacent Borough Council area or on the development of land to the west of the A128. Assessment of such an option does not have to commit the Council at this stage to such a form of development but in order to make any subsequent plan 'sound' an objective assessment should be undertaken.

Comment

Representation ID: 11789

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

In our view there is also a sixth reasonable alternative option to investigate as part of the evidence base which could be designed to concentrate on the delivery of Brentwood Borough Council's requirements only. A standalone settlement at Dunton which is not dependent on the delivery of other land to the east in the adjacent Borough Council area or on the development of land to the west of the A128. Assessment of such an option does not have to commit the Council at this stage to such a form of development but in order to make any subsequent plan 'sound' an objective assessment should be undertaken.

Comment

Representation ID: 11790

Received: 15/02/2015

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

An alternative of having Dunton as a standalone development could potentially bring forward all the benefits and advantages discussed in Appendix A on land wholly within Brentwood Borough and in one ownership. This would ensure that, with other land elsewhere in the Borough, the Brentwood Borough Local Plan delivered its full housing need in a sustainable location and form rather than relied upon the potential uncertainties associated with the delivery of land in a different local plan in a different local planning authority area. It could also be designed to maintain a meaningful and sustainable separation between any new development and the existing village of West Horndon.