Object

Representation ID: 15416

Received: 06/05/2016

Respondent: JTS Partnership LLP

The development at Dunton would not assist in meeting existing settlement specific housing and socio-economic needs in the Borough, especially in the villages throughout Brentwood.

Object

Representation ID: 15417

Received: 06/05/2016

Respondent: JTS Partnership LLP

The key characteristics of a garden village are that it forms the expansion of existing small settlements, is within the catchment of a town, located on an existing transport corridor and is partly or mostly self-sufficient in terms of local social infrastructure. The Dunton Hills proposal cannot meet three of the four characteristics identified above.

Object

Representation ID: 15418

Received: 06/05/2016

Respondent: JTS Partnership LLP

There is no evidence of the financial viability of the Dunton Hills development. Whilst it is accepted that the proposal will prove to be a vital source of housing, the ability to fund significant new capital infrastructure will be extremely limiting. The Council should be aware that the recent consultation on the Lower Thames Crossing included a proposed Route 4, which passes through the Dunton Hills area. However, this is unlikely to come forward as a result of the A127 and the junction with the roundabout at the M25 being at capacity. Essex County Council has already acknowledged that the A127 is one of the busiest non-trunk roads in the Country, with regular extensive and widespread delay and disruption to traffic and on the local road network.

Object

Representation ID: 15419

Received: 06/05/2016

Respondent: JTS Partnership LLP

Of principle concern to the delivery of the Dunton Hills Garden Village is the located of the designated Flood Zone 2. Identification of the site fails to comply with Paragraph 100 of the NPPF, which requires that Local Plans are submitted by Strategic Flood Risk Assessment and that Local Plans should apply a sequential, risk-based approach to the location of development. The Strategic Flood Risk Assessment found in the Evidence Base was published in 2011, prior to the identification of the Dunton Hills Garden Village site. The SFRA provides a list of recommendations within Paragraph 7.1 in regard to the inclusion of sites. It states that "should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a specific site level".

Support

Representation ID: 15420

Received: 06/05/2016

Respondent: JTS Partnership LLP

Support the proposed housing allocations within the urban area as set out within Table 7.2.
Support the redevelopment of brownfield land within the Green Belt; however there are far more sites that those stated within Table 7.2 that are suitable for redevelopment for housing.

Comment

Representation ID: 15421

Received: 06/05/2016

Respondent: JTS Partnership LLP

Remains a question mark over the housing numbers for Wates Way Industrial Estate, which has been sold to Lidl, which does not generally provided for residential within its development.

Comment

Representation ID: 15422

Received: 06/05/2016

Respondent: JTS Partnership LLP

200 dwellings appears very optimistic for the Baytree Centre and further investigation should be undertaken to ascertain whether this number is achievable.

Object

Representation ID: 15423

Received: 06/05/2016

Respondent: JTS Partnership LLP

Significant doubt over the deliverability of the Dunton Hills Garden Village strategic site allocation and the figure of 2,500 is unrealistic.

Object

Representation ID: 15424

Received: 06/05/2016

Respondent: JTS Partnership LLP

Of the five sites that have been identified for release from the Green Belt, site 079A is considered to have a 'Low-Moderate' assessment rating, sites 022, 023 and 032, 087, 235 are considered to have a 'Moderate' racing, whilst 034 has a 'Moderate-High' rating. A 'Moderate' rating is defined as being where "development of the site will moderately affect the site's contribution to the purposes of the Green Belt" and where either: -
- Three, or all, Green Belt Purposes is assessed to a Moderate Level; or
- One Purpose of the Green Belt is assessed to a High Level and at least two Purposes are assessed to a Moderate Level; or
- Two Purposes are assessed to a High Level and the other two Purposes limited to a Low level."

Given that the Assessment also lists 50 sites that are either within the 'Low-Moderate' or the 'Low' assessment rating, the Council has failed to take into account their own Evidence Base in identifying sites and when informing their Local Plan strategy. As a result, it is considered that the Local Plan, as it stands, is unsound.

Comment

Representation ID: 15425

Received: 06/05/2016

Respondent: JTS Partnership LLP

It is evident that some Green Belt land will have to be released in order to meet the objectively assessed target. As a result, it is recommended that a detailed review of Green Belt boundaries is undertaken. Over the years a number of anomalies have been created by inept drawing of the Green Belt boundaries. There are quite a few examples, for instance, of the Green Belt boundary cutting across the middle of a residential curtilage or wrapping around a single site. This makes no sense at all, and should be corrected.