Comment

Representation ID: 15540

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

It should be noted that:

A range of development types, as included within the sequential approach, should be utilised in meeting Brentwood Borough's growth requirements. This should be based on an overarching vision of sustainable development, as underpinned by National planning policy. For example, larger Green Belt sites may be in a more sustainable location than brownfield sites, and/or able to provide a number of benefits that smaller brownfield sites cannot;

The sequential test was appropriately undertaken to the identification of sites but should not be stringently applied to the subsequent delivery of sites/the housing trajectory.

Object

Representation ID: 15546

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The policy test of "no significant impact" on the aspects listed does not comply with National policy. Notably:

For Green Belt: The NPPF directs that Green Belt boundaries should only be altered in "exceptional circumstances". To require "no significant impact" on the Green Belt is therefore considered over prescriptive and beyond the wording of the NPPF. It is considered appropriate that reference is made to the 5 Green Belt purposes.

For visual amenity/environmental quality - Unless the NPPF directs that development should be restricted, for both plan-making and decision-taking, development should be positively sought unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies of the Framework taken as a whole.

For Transport - The NPPF states that development should only be prevented or refused whether the residual cumulative impact of development are severe.

For Heritage -The test to be considered in the NPPF is whether such development would lead to
substantial harm to/total loss of a heritage asset's significance, or less than substantial harm.

Support

Representation ID: 15547

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Support the identified of Shenfield and Brentwood as Category 1 settlements, and thereby under Policy 5.1, are the focus for development.

Comment

Representation ID: 15548

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We do question the designation of Hutton, Warley, Brook Street and Pilgrim Hatch under the Main Town category.

Comment

Representation ID: 15549

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Housing should be largely proportionate and appropriate to each settlement and greater in number for the larger settlements that would be able to accommodate, and provide for, sustainable growth.

Therefore whilst we do not dispute that Hutton, Warley, Brook Street and Pilgrims Hatch are sustainable and can support new development, it should be recognised that Brentwood and Shenfield are the most sustainable locations and can accommodate higher levels of growth. It is therefore suggested that Brentwood and Shenfield are defined as Category 1A settlements and the remaining settlements as Category 1B to make this distinction and to also support the approach contained within the Policy 5.1

Support

Representation ID: 15550

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The allocation of Site 034 will:

* Make a substantial contribution to meeting local housing need, in an area that is likely to be in high demand following the introduction of Crossrail;
* Contribute towards securing an effective and balanced supply of dwelling types and tenures;
* Contribute toward the continued economic vitality of the settlement.

Comment

Representation ID: 15556

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The NPPF allows LPAs to set appropriate housing densities that reflect local circumstances. The consultation on proposed changes to National Planning Policy proposes a change to National Planning Policy to expect LPAs to require higher density development around commuter hubs wherever feasible. Shenfield with current and future transport links would be defined as a "commuter hub", therefore it is supported to focus higher densities here.
However, such an approach will need to have regard to the existing nature of the site, including Landscape, Listed Buildings and Topography.

Support

Representation ID: 15558

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

BBC has sought to be realistic about the likelihood of sites coming forward within the housing trajectory. This seeks to deliver development within urban locations in the short term (p47). Such an approach is supported.

Comment

Representation ID: 15565

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Site 034 is dentified to deliver housing in the first 5 years: 40 dwellings to be delivered in 2018, and 80 dpa thereafter, up to 2025 (Appendix 3)

There is a possibility that the residential development of the Site could immediately follow the permitted Crossrail works. This would assist in reducing the level of construction necessary on the Site, and therefore reduce the associated impacts to the surroundings. It will assist BBC in realising its Strategic Objective no. 7 to optimise the social and economic benefits arising from Crossrail.

To meet development needs, we would seek the submission of an early planning application in respect of the Site. Although it is recognised that, in the context of National Green Belt policy, permission may not be granted until after the adoption of the Local Plan.

Support

Representation ID: 15566

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

We support Policy 6.1 in that it reflects the context of paragraph 14 of the NPPF.