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Draft Local Plan
Policy 9.12: Site Allocations in Green Belt
Representation ID: 16157
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
9.12 is confused and an assessment of Green Belt is required, an assessment of landscape is required to advise on the most appropriate land to release for development. The assessment by Crestwood draws a key conclusion that Dunton makes a high contribution to Green Belt contribution. This evidence base document is in full contravention to the DLP. There is no evidence base in place to have influenced the selection of the DLP's proposals, nor rejection of alternatives, from a Green Belt or Landscape perspective. Countryside Propoerties has commissioned a GB review and identifies areas where GB performs less well, including around Shenfield/Brentwood town, north of Blackmore and to the east and west of West Horndon and at Herongate. The land to the east of West Horndon is not visually connected to Basildon and avoids coalescence.
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Comment
Draft Local Plan
Policy 9.1: Historic and Natural Environment Landscape Character
Representation ID: 16161
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
Countryside Properties also independently commissioned Rummey Design to look at Green Belt and landscape issues in relation to strategic options for growth, including Dunton (written when the joint proposals were being considered) and West Horndon. The report prepared by Rummey Design forms part of Appendix 2. The land to the east of West Horndon affects 3 of the 5 purposes of GB, compared to other strategic growth locations these would be low. Benefits could offset the relatively minor harm it would cause.
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Object
Draft Local Plan
Policy 9.1: Historic and Natural Environment Landscape Character
Representation ID: 16164
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
Noted that land adjacent to Dunton is designated as a Historic Environment Zone, Dunton has a low landscape capacity to accommodate development without landscape impacts and would be visible form extensive transport networks surrounding the site. The development would lie closer to West Horndon that the Dunton garden suburb and would contribute to a perception of urban sprawl.
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Object
Draft Local Plan
Policy 10.1: Sustainable Transport
Representation ID: 16169
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
A range of issues need to be considered when planning form new infrastructure and so a Infrastructure delivery Plan is essential. Transport being a critical one. The key findings of Odyssey Markides (OM) support the view that there has been a lack of consideration of transport as a topic in the evidence base and SA. Transport as a topic should include the assessment of links to public transport and in particular to railway stations. It should consider travel by all modes including walking and cycling, public transport as well as vehicles. Detailed assessment of the land at Dunton by OM, demonstrates that it would be difficult to deliver a safe and suitable access strategy, and that this would be prohibited by cost and environmental considerations. There is insufficient land to create access from the A127 to the north. Whereas West Horndon already has a station and could become a transport hub.
See attached
Object
Draft Local Plan
Evidence Base
Representation ID: 16170
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
Appendix 1 to the report of OM provides a critique of the modelling work by PBA. This finds fundamental issues with the depth of the work carried out, the data presented and conclusions drawn from that data. Critically the work has not been reviewed by the Highways Authority, Essex County Council and Highways England. The methodology used is not clear and the modelling tool is unreliable. For example it does not appear to take account of existing and proposed major development including infrastructure. It lacks depth and serious technical analysis. No real conclusions on the various strategic options for growth can be drawn from it.
See attached
Object
Draft Local Plan
Policy 5.2: Housing Growth
Representation ID: 16965
Received: 16/05/2016
Respondent: Countryside Properties
Agent: Andrew Martin Planning Ltd
The DLP should include full and realistic targets for the growth of homes and jobs in line with the latest government guidance. The Council should proceed swiftly to ensure a plan is in place by 2017 if it wants to avoid intervention by the government. The Local Plan for Brentwood should consider full OAN for market and affordable housing, which now needs to reflect the government's latest initiative towards building 400,000 affordable homes, of which 50% should be starter homes. To cater for such initiatives and meet new 'delivery tests' that are proposed in further reforms, the Plan must look to higher targets than previously considered. It must include an up to date supply of specific deliverable sites to provide a rolling five-years worth of housing plus an additional buffer of 5% to 20%. (Those plans found sound at examination and referred to in the NLP report tended to show an extra 20% provision of new homes above the household projections)
See attached