Comment

Representation ID: 15707

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

Request the Council to consider the allocation of Ongar Garden Centre as a suitable site for residential, retail, employment or leisure purposes.

The highly developed nature of the existing site would allow it to be redeveloped to contribute towards meeting the Borough's identified needs in a manner compliant with national Green Belt policy and without detriment to the existing character of the area.

The site may have a lower degree of accessibility to existing facilties but due to its previously developed nature it has a nil or even reduced impact.

Comment

Representation ID: 15726

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

Request to include Ongar Garden Centre for development allocation sites. Although the site does not immediately adjoin a settlement boundary such that a future resident or occupier of the site would be likely to utilise private means of transport, it is within easy reach of an established centre hence reducing the impact of traffic on the character and amenities of the locality.

Comment

Representation ID: 15732

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

Support the sequential land use approach however further clarity should be given to the status of brownfield sites which are not located on the edge of existing settlements.

The site selection approach allows undeveloped Green Belt sites in the form of urban extensions to existing settlements. Whilst it is accepted that such extensions may provide immediate access to established local facilities, their 'sustainability' needs to be balanced with the environmental impact caused by the development of currently open sites.

The Plan should prioritise the use of all previously developed land in preference to greenfield alternatives in accordance with the principles of sustainable development and the NPPF.

Comment

Representation ID: 15733

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

All previously developed lands are sequentially preferable to greenfield Green Belt sites on the edge of a settlement and it is requested that the proposed sequential hierarchy (Policy 5.1) be amended to reflect this.

Comment

Representation ID: 15734

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

Request to include Ongar Garden Centre for development allocation sites. Although the site does not immediately adjoin a settlement boundary, it is within easy reach of an established centre hence reducing the impact of traffic on the character and amenities of the locality.

Comment

Representation ID: 15735

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

Although the policy reflects the 'town centre first' approach advocated within the NPPF, however we request that regard is also had to para. 23 of the Framework which states (inter alia) that LPAs should "set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres".

This is applicable to specialist uses, such as garden centres, where the high bulk, low value of the goods sold, together with a need for access by private vehicle, renders a town centre location generally inappropriate and unviable. As such, the retail policies of the emerging Local Plan should recognize the need for such retailers to be located in out of centre locations and the inappropriateness of applying the sequential test in their regard.

Object

Representation ID: 15736

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

Strong objection to Policy 9.9 on the grounds that it is not consistent with national policy. Para.89 of the NPPF sets out exceptions to the definition of 'inappropriateness' in Green Belt terms which specifically includes the extension and alteration of a building provided that it does not result in disproportionate additions over and above the size of the original dwelling; a replacement building provided the new building is in the same use and not materially greater than the one it replaces; or the limited infilling or redevelopment of a previously developed site where it would not have a greater impact upon the openness of the Green Belt and the purpose of including land within it than the existing development.

Comment

Representation ID: 15738

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

Draft Policy 9.11 provides in part for the redevelopment of brownfield sites within the Green Belt, however no provision is made for the expansion of existing businesses through the limited extension, alteration or replacement of an existing building or limited infilling within a previously developed site.

Object

Representation ID: 15740

Received: 11/05/2016

Respondent: Wyevale Garden Centres Ltd

Agent: Greogory Gray Associates

When applied to existing lawful commercial sites within the Green Belt, Policy 9.9 is overly restrictive. Para. 28 of the NPPF provides support for the sustainable growth and expansion of all types of existing business in rural areas through conversion of existing buildings and well-designed new buildings. This support for economic growth in rural areas applies equally to Green Belt land as that in the open countryside and can be achieved in a manner consistent with Green Belt policy either through the re-use of an existing building (para.90) or through one of the specified exceptions to the definition of 'inappropriate' development as set out in para. 89.
It is requested that Policy 9.9 be fully revised so as to be consistent with national Green Belt policy.