Object

Representation ID: 16111

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

We have concerns regarding the site selection process which has resulted in this list of sites allocated for development, such as:
- We do not consider that the sites allocated for development over the emerging plan period could have been properly assessed on robust evidence, given that the SHLAA was last updated in 2011 and the Council's Urban Capacity Study was published in 2002.
- Appendix outlines the Council's estimated delivery timetable which fails to include the delivery rates of Dunton Hill Garden Village, which leads to the assumption that the Council do not anticipate the delivery of the development within the plan period.

Support

Representation ID: 16113

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

This policy provides a level of certainty to the developer as to what the Council expects to be achieved on the site, whilst providing flexibility to take into account when site constraints do not allow for a target compliant development.

Comment

Representation ID: 16115

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

It is noted that the policy considers the NPPF's five purposes of the Green Belt. We consider that each site should be considered on its own merits, and whether they meet the purposes of the Green Belt.

Object

Representation ID: 16119

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Council has not undertaken appropriate forms of assessment to determine whether the proposed de-allocations from the Green Belt are justified and whether the sites would continue to fulfil their role. Given the perceived high quality of the landscape in the Borough, we consider the Council has not properly assessed the effects of releasing land within the Green Belt for a garden village concept. Fundamentally, a Green Belt Review has not been undertaken that determines which areas of the Green Belt do not fulfill the functions of the Green Belt designation. The latter proposal of the policy to release land for Dunton Hills Garden Village is considered to be unjustified and ineffective in seeking to meet the objectively assessed needs of the Borough due to the Council's failure to fully assess the impact of development.

Support

Representation ID: 16122

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Council is correct to seek new development in accessible locations. However, the approach to site allocations does not seem to follow this rationale. E.g. DGS is not located adjacent to any existing (sustainable) transport links and instead growth should be focused in locations that seek to ensure existing public transport networks are fully utilised to avoid expensive, unjustified infrastructure improvement works in locations which cannot be considered sustainable in transport terms. We do not consider the Council has approached this in a sequential way which would unlock the potential of sites surrounding underutilised public transport hubs.

Comment

Representation ID: 16123

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Whilst the draft Plan makes various general references to supporting evidence, there is very little reference to specific evidence base documents relied upon. Additionally, as we understand at paragraph 2.16 of the draft Plan, there is further evidence "being undertaken to inform policies as they are being developed". It stands to reason that the Plan, prepared as it has, in the absence of this evidence will fail to satisfy the requirements of the NPPF.

Comment

Representation ID: 16126

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Council does not appear to have taken the representations to the 2015 consultation conscientiously into account as identified in the Statement of consultation 2016 and, in particular, failed to consider the legitimate criticisms of the way in which strategic Green Belt sites have been evaluated and chosen. The Council has failed to take into account the concerns raised by neighbouring authorities in this regard.

Object

Representation ID: 16130

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

The Council commissioned Crestwood Environmental to undertake an independent assessment of Housing Sites within the Green Belt and their relative contribution to the purposes of the Green Belt designation. The assessment is not a parcel based analysis nor does it take into consideration the results of the Council's Mid Essex Landscape Character Assessment 2006. The principal weakness is that it does not consider the role and function of the Green Belt in Brentwood and beyond to determine the best Green Belt sites to release.

Comment

Representation ID: 16132

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Sites 037a & 037b Land West of Thorndon Avenue in the Housing Sites Assessment are considered a moderate contribution to the overall purposes of the Green Belt. It is considered that the risk of a reduction of countryside gaps between towns would not be significant and any existing interlying barriers can be maintained. There is also no or very limited potential for other Conservation (Heritage) Designations to be adversely affected by development, and it is accepted that some encroachment into the countryside would occur as a result of development.

Object

Representation ID: 16140

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

In considering the proposals for the Dunton Hills Garden Suburb, the SA stated that:
"Considerable assumptions [have been made] regarding how options would be implemented 'on the ground' and what the effect on particular receptors would be.... In many instances, given reasonable assumptions, it is not possible to predict likely significant effects, but it is possible to comment on the merits of an option in more general terms." EASL is unaware that a detailed analysis of the likely significant effects on the proposed development at Dunton Hills has yet been undertaken and considers there is a complete lack of evidence to support these proposals as a sustainable development. There is no evidence as to where the figure of 2,500 homes has come from.