Comment

Representation ID: 16094

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

We do not consider the Council has fully assessed the impact on the Green Belt by absence of an independent and objective assessment, nor has the Council assessed the feasibility of the strategic sites put forward in their ability to be delivered in the plan period. Furthermore, the sustainability of settlements with underutilised public transport services should have been assessed. In this regard the policy is not justified or consistent with national policy.

Object

Representation ID: 16101

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

As referenced at paragraph 5.20, we do not consider the Dunton Hills garden Village Suburb would achieve the Council's Spatial Strategy in that the plan lacks evidence confirming the timescales for key developments through infrastructure delivery and lack confirmation from relevant stakeholders that the delivery can be accomplished. We therefore consider the policy is not effective on cross-boundary strategic priorities.

Object

Representation ID: 16102

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

This policy is unsound as it is not justified or consistent with national policy. We do not consider the housing growth provision has been based on up-to date or reliable evidence. The Council should consider updating its SHMA and undertaking further work on the OAN in understanding further how the Council has arrived at this growth requirement.
A strategy which seeks to deliver 19% of its overall housing requirement on Windfall sites cannot be considered sound, in line with NPPF paragraph 48 which states that 'compelling evidence' to justify its inclusion has been identified.
We consider the reliance on a strategic site at Dunton Hills Garden Village for 2,500 units should be approached with caution as it is highly unlikely this will site will be delivered in the plan period and this is therefore not an
effective policy.

Support

Representation ID: 16103

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Council's policy on sustainable development is consistent with national policy and positively prepared to enable a flexible approach to delivery. In achieving the overall aim of this policy, the Council should consider updating its evidence base to effectively promote and optimise the delivery of sustainable development.

Support

Representation ID: 16104

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

We support the Council's strategy to ensuring development allocations make the best use of land to meet local needs and therefore this policy can be considered justified and effective in promoting this delivery.

Comment

Representation ID: 16105

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

This policy is sound, in line with paragraph 58 of the NPPF; however, in applying the policy the Council should ensure that each assessment is made on a case-by-case basis having regard to the local context. The Council should consider inserting this into the policy to ensure flexibility.

Support

Representation ID: 16106

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Rail stations are considered a key gateway to the Borough and therefore the utilisation of surrounding sites to deliver sustainable development throughout the plan period should be considered, alongside the opportunity to deliver higher density development in the short term.

In line with paragraph 30 of the NPPF the Council should support a pattern of development which facilitates the sustainable modes of transport. The Council's proposed spatial strategy encourages this and therefore the policy can be considered positively prepared or justified as the most appropriate strategy.

Object

Representation ID: 16107

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

This policy is fundamentally unsound given the lack of evidence underpinning the Council's decision to allocate the site for development. The policy is not positively prepared in that the Council has not properly considered the infrastructure requirements to facilitate a development on this scale, nor is the policy justified due to a lack of credible and robust evidence base e.g. Green Belt Review, Landscape Assessment ad Infrastructure Delivery Strategy. We consider any development on this site will not be deliverable within the plan period and therefore cannot be considered effective and finally the allocation does not constitute sustainable development.

Object

Representation ID: 16109

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Remove policy.
- The site has not been subject to any capacity or technical analysis;
- Will require significant investment in new infrastructure; and
- Is unlikely to deliver sufficient growth within the plan-period.

Support

Representation ID: 16110

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

An assessment should be made on a case-by-case basis having regard to the quality of the design, the mix of uses and the amount and quality of public realm and open space. We therefore support this policy.