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Comment

Draft Local Plan

Figure 5.4. Sequential Selection of Sites

Representation ID: 14462

Received: 18/04/2016

Respondent: Asphaltic Developments Ltd

Agent: Rapleys LLP

Representation Summary:

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."

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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

Representation Summary:

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.

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Object

Draft Local Plan

Policy 5.1: Spatial Strategy

Representation ID: 14466

Received: 18/04/2016

Respondent: Asphaltic Developments Ltd

Agent: Rapleys LLP

Representation Summary:

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.

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Object

Draft Local Plan

Site Selection

Representation ID: 14472

Received: 18/04/2016

Respondent: Asphaltic Developments Ltd

Agent: Rapleys LLP

Representation Summary:

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.

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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

Representation Summary:

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.

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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

Representation Summary:

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.

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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

Representation Summary:

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.

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