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Draft Local Plan
Figure 5.4. Sequential Selection of Sites
Representation ID: 14462
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
We support this approach in principle, as it promotes the sustainable patterns of development to accommodate growth/development needs without encroaching onto Greenfield land. However we consider that brownfield sites in Green Belt that are connected to, or close to, urban areas are sustainable urban extensions, and as such they should be released to meet the housing requirements of the Borough before releasing Greenfield sites. As such, we consider that the definition of "Brownfield Sites in Green Belt" is not appropriate, and should be amended as "previously developed sites connected to or close to existing urban areas."
See attached
Support
Draft Local Plan
Policy 9.11: Previously Developed Land in Green Belt
Representation ID: 14463
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
Support Policy 9.11, which supports the principle of reuse/recycling of brownfield land/PDL in Green Belt to meet the Borough's housing and employment needs, provided that, inter alia, it will not have significantly greater impact on the openness of the Green Belt.
See attached
Object
Draft Local Plan
Policy 5.1: Spatial Strategy
Representation ID: 14466
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
The reuse/recycling of brownfield sites in Green Belt is identified as sequentially preferable sites than strategic sites or greenfield sites in Green Belt, the Local Plan's Spatial Strategy under Policy 5.1 does not reflect this sequential approach to meeting local needs (for which no definition is given and appears to be contrary to the NPPF referring to 'local needs'relative to the housing needs in rural areas). We therefore consider that Policy 5.1 should be amended, which is also necessary in order to ensure the effectiveness of Policy 9.11.
See attached
Object
Draft Local Plan
Site Selection
Representation ID: 14472
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
Given the Council's reliance on greenfield urban extensions in Green Belt it is considered that more sustainable sites which do not have significantly greater impact on the openness of the Green Belt such as our clients site [Brentwood Leisure Park at Warley Gap] should be considered as potential sites for housing development (in line with Policy 9.11), in addition to the proposed allocations in the Green Belt, such as sites no. 010 and 128, which are brownfield land in the Green Belt that are connected to or close to urban areas.
See attached
Object
Draft Local Plan
Policy 9.9: New Development, Extension and Replacement of Buildings in Green Belt
Representation ID: 14475
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
Draft Local Plan does not provide applicants with clarity on the Council's approach to the development of brownfield land in the Green Belt notwithstanding Policy 9.11. It is considered that Policy 9.9 provides conflicting advice on development of brownfield land and Policy 9.11, as it states that development within the defined Green Belt including re-use or extension of existing buildings is defined as "inappropriate." This is contrary to the NPPF, As such, Policy 9.9 requires amendments to ensure that it does not conflict with the strategy/sequential approach at Paragraph 5.16, Policy 9.11 and national policy.
See attached
Comment
Draft Local Plan
Policy 9.12: Site Allocations in Green Belt
Representation ID: 14481
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
Policy 9.12 states that the sites allocated for housing development in Green Belt will be deallocated from Green Belt and provide new defensible boundaries to protect open countryside for future generations. Our client's Site [the Brentwood Leisure Park at Warley Gap] is suitable for housing development as it is brownfield land, close to and well connected to the existing urban boundary of Brentwood. The site can sustainably accommodate residential development, without adversely affecting the openness of the Green Belt. As such, the Site should be allocated under Policy 9.12, as it offers significant potential to contribute to the Borough's housing requirements.
See attached
Comment
Draft Local Plan
Policy 10.9: Open Space, Community, Sport and Recreational Facilities
Representation ID: 14482
Received: 18/04/2016
Respondent: Asphaltic Developments Ltd
Agent: Rapleys LLP
There are exceptions to the presumption under this policy, where it can be demonstrated that there is an excess provision or where alternative facilities of equal or better quality and convenience will be provided as part of the development. On this point, any alternative open space provision which could be brought forward as part of redevelopment should be considered alongside other sustainable benefits associated with recycling of the brownfield site for housing development, and this should be reflected in the Policy.
See attached