Comment

Representation ID: 15604

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 7.2, 7.7, Policy 9.2, Policy 9.9, Policy 9.13, Policy 9.14 and Policy 10.12.
make reference to imposing Conditions on planning permission to secure the provision of housing types provided in perpetuity and by tenure.

It should be noted that National policy (NPPF, para 206) states that planning conditions should only be imposed where they are necessary, relevant to planning and to the development as permitted, enforceable, precise and reasonable in all other respects.

Object

Representation ID: 15605

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

In supporting text to Policy 7.5, paragraph 7.57 notes that the SHMA suggests a 35% affordable housing target on "all suitable sites" to be justified, subject to viability and the balance of tenure mix. There is no evidence to demonstrate that BBC has undertaken a viability assessment to establish whether a 35% target is viable. This Policy requirement therefore does not accordance with NPPF in that sustainable development requires careful attention to viability and costs in plan-making and decision-taking, and therefore the scale of obligations and policy burdens (such as affordable housing) should not be such that development viability is threatened.

Object

Representation ID: 15606

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Part (e) seeks to require affordable housing standards to be equal to that of market housing in terms of appearance, built quality and materials. With regards to building standards and as stated above, Local Plans should not set local technical standards or requirements relating to the construction, internal layout or performance of dwellings. In addition, whilst the external appearance of affordable units can be sought to be indistinguishable from market dwellings, the internal layout is limited to the requirements of the Affordable Housing Provider.

Object

Representation ID: 15612

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Part (g) bullet (i) of Policy 7.5 advises that affordable housing should be at a cost low enough for eligible households to afford. This is a matter for an Affordable Housing Provider, to be agreed, and such wording is therefore not considered appropriate in a Local Plan policy.

Part (g) bullet (ii) directs that affordable housing should remain at an affordable price for future eligible households. Similarly, this requires agreement with an Affordable Housing Provider or as part of a Section 106 Agreement, and such wording is not considered appropriate in this context.

Comment

Representation ID: 15620

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 7.8 seeks to set out the nationally described space standards within a Local Plan policy. As required by the PPG, LPAs should consider the impact of using such national standards as part of their Local Plan viability assessment. No evidence has been presented to demonstrate this, and no justification is provided on the appropriateness of adopting such standards.

Support

Representation ID: 15636

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

The site is identified in SHLAA to be 'developable' and 'deliverable' if assessed as being 'available', 'suitable' and 'achievable'.

Although located within the Green Belt, the Site forms an enclave of open land framed for the
most part by existing development and transport infrastructure. As a development opportunity that would have little environmental impact on the locality, the Site benefits from effective physical and visual enclosure. It is well placed to accommodate future development by virtue of its sustainable position in close proximity to Shenfield.

Support

Representation ID: 15642

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Site 034 makes a very limited contribution to the NPPF Green Belt purposes as it is well contained by existing built form and infrastructure, exhibits defined and defensible boundaries and is strongly influenced by the adjoining urban/built elements. Development, set within a robust landscape framework, would provide the opportunity to enhance the existing landscape and biodiversity of the Site whilst maintain defensible and robust boundaries to the Green Belt.

Support

Representation ID: 15646

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Many potential economic, social and environmental benefits could arise from development at Site 034, contributing to sustainable development. These include:

- Provision of a wide range of much needed housing in a highly sustainable location;
- Provision of generous areas of public open space;
- Strengthening of Shenfield's vitality and viability;
- Delivery of a significant number of affordable homes;
- Contributions towards improved community facilities;
- Making a substantial contribution to meeting the Borough's overall housing need on a well contained site, thereby protecting more sensitive and visual sites from development;
- The creation of direct construction jobs plus additional indirect jobs; and
- New Homes Bonus payment (over 6 year period) of £2.6M generated by the scheme.

Comment

Representation ID: 15662

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 9.5 current wording is not 'Consistent with national policy'. The Policy advises that proposals for development affecting or within the vicinity of a Listed Building will only be permitted where these are sympathetic to its character and setting.

National policy directs that where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, a LPA should refuse consent unless the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or if the following apply:

The nature of the heritage asset prevents all reasonable uses of the site; and
No viable use of the heritage asset itself can be found in the medium term through appropriate marketing that will enable its conservation; and
Conservation by grant-funding or some form of charitable or public ownership is demonstrably not possible; and
The harm or loss is outweighed by the benefit of bringing the site back into use.

Alternatively, where a proposals leads to less than substantial harm to a designated heritage asset's significance, this harm should be weighed against the public benefits of the proposal.

Comment

Representation ID: 15681

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Policy 9.12 states that the sites allocated within the Green Belt will be expected to provide "significant" community benefits. In addition, the DLP (para 9.75) seeks to justify this requirement by stating that the loss of Green Belt is to be "repaid" through significant benefits to new and existing communities. This wording is not considered appropriate. Circumstances in which planning obligations should be sought are set out in the NPPF.

It is necessary that policies and criteria are provided for each allocation site. This will assist both the Applicant (in providing an appropriate development proposal) and decision makers (in considering a subsequent application). With regard to the above, such policies can identify new community benefits (including Use Classes) sought as part of new residential developments, to provide certainty on what deliverability expectations are.