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Object

Draft Local Plan

Policy 5.1: Spatial Strategy

Representation ID: 15399

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

Generally support spatial strategy but concerned that proposed housing allocations will not deliver the vision or the quantum of dwellings required to meet OAN.

Allocations inconsistent with the 'evidence base' that the Council has failed to undertake a comprehensive review of Green Belt boundaries. As such, the Council cannot demonstrate that the proposed strategy and housing allocations minimise the impact on the Green Belt. Consider the Local Plan unsound. The Council's working draft Green Belt Assessment does not appear to have informed policy.

The Policy also states that limited development, including infilling where appropriate, will take place in villages within rural areas; however this is not evident within the Draft Local Plan allocations as published for consultation.

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Comment

Draft Local Plan

Sequential Land Use

Representation ID: 15407

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

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 settlement).
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 on the Green Belt at each stage, that the Council can assure itself that the overall impact of the Green Belt will be minimised.

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Object

Draft Local Plan

Evidence Base

Representation ID: 15408

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

Publication of Green Belt Assessment on the Council's website noted. Whilst a number of sites are assessed, it is evident that the Council have not taken into account the results of this assessment when preparing their Draft Local Plan. In particular, it is noted that the Council has allocated a number of sites, which have a 'moderate' impact to the Green Belt, rather than the smaller, but 'Low to Moderate' risk sites.

No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated. Failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

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Comment

Draft Local Plan

Policy 5.2: Housing Growth

Representation ID: 15409

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

OAN figure of 7,240 new residential dwellings to be built over the Plan period is supported. However there is a significant question mark over the deliverability of the Strategic Site at Dunton Hills and its ability to deliver within the Plan period.

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Object

Draft Local Plan

Policy 5.2: Housing Growth

Representation ID: 15410

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

The Council's working draft Green Belt Assessment does not appear to have informed policy. No justification within either the Assessment or the Draft Local Plan, as to the reason why those 'low-moderate' sites have not been allocated and whilst it is appreciated that some of those 50 sites within the 'Low' or 'Low to Moderate' criteria are not appropriate for housing development, being either in employment use, or having already been developed, the Council's failure to explain why the Evidence Base does not influence the housing strategy makes the Plan, at present, unsound.

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Support

Draft Local Plan

Policy 5.3: Job Growth and Employment Land

Representation ID: 15411

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

Support is given to the provision of employment land to benefit the creation of new jobs within the Borough and to the allocation of existing employment sites within the Green Belt. Paragraph 5.56 acknowledges that there needs to be further work undertaken to "identify the exact loss of employment and the extent to which this needs to be replaced" and it is considered that this work should have been undertaken prior to the publication of this Draft Local Plan.

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Object

Draft Local Plan

Policy 7.1: Dunton Hills Garden Village

Representation ID: 15412

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

Serious questions remain regarding the deliverability of the Dunton Hills Garden Village and the cooperation between Basildon Borough Council and Brentwood Borough Council appears to have ceased following the consultation on the Strategic Growth Options and Dunton Garden Suburb Consultation in early 2015.
The proposal for the Dunton Hills Garden Village is not sustainable and insufficient justification for its allocation has not been provided.

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Object

Draft Local Plan

Policy 7.1: Dunton Hills Garden Village

Representation ID: 15413

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

The fact that the area annotated in the Basildon Borough Council Draft Local Plan H10b is not to be allocated until after 2034 is of serious detriment to Brentwood's own allocation and would result in Dunton Hills Garden Village sitting as an isolated development. It is highly unlikely, given the land ownership, infrastructure and other essential requirements and to ensure that this does not come forward as piecemeal development that the allocation could feasibly be delivered within the Plan period. As a result, the figures set out within Policy 5.2 do not meet the Objectively Assessed Needs of the plan period.

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Object

Draft Local Plan

Policy 7.1: Dunton Hills Garden Village

Representation ID: 15414

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

Council's Green Belt Assessment has commented that the proposed development would effectively harm three of the four purposes of the Green Belt - it would result in unrestricted sprawl of an urban area; significantly reduce the gap between West Horndon and Basildon; and encroach on the countryside. It's only positive attribute is that it does not impact on the setting or special character of historic towns.

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Object

Draft Local Plan

Policy 7.1: Dunton Hills Garden Village

Representation ID: 15415

Received: 06/05/2016

Respondent: JTS Partnership LLP

Representation Summary:

It is noted that representations were made to the Council during the last consultation which raised serious doubts over the deliverability of a proposed station at Dunton due to the proximity of other stations, Network Rail's technical requirements and viability issues. This does not appear to have been resolved within this version of the Draft Local Plan. Without a station, the site is solely dependent on travel by car, resulting in a highly unsustainable development.

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