Comment

Representation ID: 16036

Received: 13/05/2016

Respondent: Countryside Properties

Agent: Phase 2 Planning and Development Ltd

The inclusion of Dunton Hills Garden Village for 2,500 dwellings within the Plan period is questioned.
The site at Bayleys Mead can make a modest contribution towards housing supply and is deliverable within the early part of the plan period.. The site has good access to public transport, services and facilities, within Brentwood Urban Area. Although the site falls within the Green Belt, it performs poorly and hence development is considered to be appropriate. Development on the site would have a minimal impact on the countryside as identified in SHLAA. There are no heritage assets on the site. It has a relatively low landscape quality in the Council's GB Assessment and not at risk from flooding nor in close proximity to an Air Quality Management Area.

Comment

Representation ID: 16038

Received: 13/05/2016

Respondent: Countryside Properties

Agent: Phase 2 Planning and Development Ltd

This should be amended to include reference to our representation site at Bayleys Mead.

Comment

Representation ID: 16039

Received: 13/05/2016

Respondent: Countryside Properties

Agent: Phase 2 Planning and Development Ltd

This should be amended to include reference to our representation site at Bayleys Mead, which is deliverable early in the plan period, unconstrained, adjoins Brentwood urban area and can provide a high quality residential development.

Object

Representation ID: 16063

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Summary of Objections :
OBJECT TO THE LOCAL PLAN ON THE BASIS THAT IT IS UNSOUND AS CURRENTLY
DRAFTED DUE TO THE ABSENCE OF AN APPROPRIATE, COMPREHENSIVE AND UPTO-DATE EVIDENCE BASE.

THE ABSENCE OF AN ADEQUATE SUSTAINABILITY APPRAISAL. FAILURE TO COMPLY WITH THE RELEVANT EU DIRECTIVE AND REGULATIONS MADE TO IMPLEMENT IT.
NOTWITHSTANDING THE ABOVE SUBMISSION THAT THE PLAN AS A WHOLE IS
UNSOUND, OBJECT TO POLICIES:

5.1 SPATIAL STRATEGY;
5.2 HOUSING GROWTH;
6.1 SUSTAINABLE DEVELOPMENT;
6.2 MANAGING GROWTH;
6.6 STRATEGIC SITES;
7.1 DUNTON HILLS GARDEN VILLAGE; and
7.4 HOUSING LAND ALLOCATIONS.

Please note that 15 documents were submitted for this representation.

Object

Representation ID: 16069

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Documents described as 'forthcoming':
Green Belt Review.
Infrastructure Delivery Plan.
New economic evidence including the impact of Crossrail.
Documents requiring an Update/Further Assessment:
A Green Infrastructure Study.
Transport Assessment.
Objectively Assessed Housing Needs.
Strategic Housing Market Assessment (SHMA).
Strategic Housing Land Availability Assessment.
The Plan is therefore supported by a limited evidence base, which by the Council's own admission is "emerging and ongoing" (DLP, paragraph 1.22). Paragraph 2.16 confirms: "several pieces of evidence are being undertaken alongside Local Plan preparation to inform policies as they are being developed and ensure the Council is able to produce a Plan as quickly as possible".

Object

Representation ID: 16071

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Late in the process of preparing the Draft Plan, land at West Horndon has been rejected for strategic growth in favour of an allocation at Dunton. At paragraph 7.10 the Draft Plan confirms "Land around West Horndon Village remains a reasonable alternative because it can provide for similar development numbers towards local needs." The only justification given for rejecting this highly sustainable
location for growth is that "it has not been selected as a preferred site in this Draft Plan owing to impacts on the existing village, which would not be consistent with emerging spatial strategy."
The rejection of this alternative site is not supported by sustainability assessment. Indeed the limited assessment that has been undertaken gives more support to West Horndon as a strategic site for growth, based on landscape impact. We would add to this that an extension to an existing village served by a railway station and community services and facilities must be more sustainable than a randomly located site on open green fields that is not contained by defensible boundaries. This conclusion is summed up in the latest SA Interim report of February 2016 that states:
"The process of the assessment of sites that are suitable, available and deliverable for development within the Borough is on-going."
"The appraisal finds that the Draft Plan is set to result in significant positive effects in terms of housing and economy/employment objectives, but significant negative effects in terms of landscape objectives."
Specifically in respect of Dunton: "at the current time it remains appropriate to 'flag' the potential for significant negative effects given the uncertainty that remains regarding Dunton Hills Garden Village". (The key words are highlighted in bold and in red print by the authors of the Interim SA).

Object

Representation ID: 16080

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

As a minimum, consultation is required on the scope of the SA and the SA report accompanying the Draft Plan. It is best practice for consultation to take place on SA during the plan preparation process for example through the production of interim SA Report and other means such as workshops and working groups.
The testing of the options and reasonable alternatives within the SA is required, however the evidence base is not complete nor up to date.
The land to the east of West Horndon performs better in the SA than the proposed Dunton Hills Garden Village.

Object

Representation ID: 16083

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representations made in 2013 include an SA of the land to the east of West Horndon out by consultants on behalf of Countryside Properties to address the absence of such assessment by the Council. This considers the issues of transport and access, landscape and design, and delivery and viability. Appendix 1 to the 2013 representations comprises a report by Rummey Design that explores a landscape-led urban extension to West Horndon.
Representations submitted in 2015 provided further justification for growth at West Horndon and include a critique of other strategic growth options being considered by the Council, such as Dunton. The appendices to the 2015 representations include comprehensive assessment of a number of issues including transport, landscape and Green Belt Assessment, archaeology and ecology, to demonstrate that there are no overriding constraints to strategic growth at West Horndon.

Object

Representation ID: 16084

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The key benefits that would arise from development of land to the east of West Horndon are considered to be:

* Countryside Properties track record of delivering high quality strategic schemes with genuine a sense of place and integration with existing villages
* Fully deliverable and fully sustainable- within a 5 minute walk of the existing railway station and local facilities and services.
* Delivery of much needed high quality housing in the Borough.
* Development early on in the plan period with minimal infrastructure required to access and deliver proposals.
* Delivery of new open space, recreational facilities, primary school, new connections to wider countryside.
* Improvements to the existing village.
* No significant impact on the Green Belt, landscape character and visual amenity
* Development proposals can fully mitigate its impact.
* Comprehensive illustrative masterplan.

Object

Representation ID: 16085

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Key benefits that would arise from development on land to the east of West Hordon :

* Countryside Properties track record of delivering high quality strategic schemes with genuine a
sense of place and integration with existing villages
* Fully deliverable and fully sustainable- within a 5 minute walk of the existing railway station and
local facilities and services.
* Delivery of much needed high quality housing in the Borough.
* Development early on in the plan period with minimal infrastructure required to access and deliver
proposals.
* Delivery of new open space, recreational facilities, primary school, new connections to wider
countryside.
* Improvements to the existing village.
* No significant impact on the Green Belt, landscape character and visual amenity
* Development proposals can fully mitigate its impact.
* Comprehensive illustrative masterplan.