Object

Representation ID: 19726

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Aside from the fact that DHGV was not supported by the SA, the emerging Plan was over reliant upon the allocation of DHGV to meet over 50% of the new housing proposed in the borough over the plan period. The allocation had emerged at the last minute and was not justified or supported by an up-to-date evidence base.

Object

Representation ID: 19727

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

There is an incomplete evidence base and without it a lack of robust assessment of sites to support the proposed strategic growth at DHGV. The supporting SA to the latest regulation 18 consultation plan, continues to find West Horndon (both east and west of the existing settlement) to be a viable option for growth. The Green Belt Review after years of preparation remains in draft. It continues to conclude that developing land at West Horndon would be less harmful to the Green Belt than DHGV.

Object

Representation ID: 19728

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Proposals for DHGV have progressed purely based on the political will of the Council for this development. Together with the promotion company CEG, the Council submitted an expression of interest in response to the government's Locally-Led Garden Villages, Towns and City opportunity and was selected as one of 14 garden village schemes to receive financial backing from the government in January 2017. We submit that all this has taken place without any proper justification or detailed site assessment.

Object

Representation ID: 19729

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

There is a strong argument for an alternative spatial strategy for growth that distributes new homes more widely throughout the Borough and has less impact on the Green Belt and open green landscape than proposal at Dunton Hills. Now is the right time to undertake detailed site assessments to ensure that the most sustainable sites are taken forward in the plan.

Object

Representation ID: 19730

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The Draft Plan Preferred Site Allocations does not provide any information on detailed planning policies, which are in the process of being reviewed and updated in the light of consultation representations made to the emerging Local Plan to date. This raises the question of how preferred land allocations have been identified when the guiding detailed planning policies have not yet been finalised.

Object

Representation ID: 19731

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Despite the draft nature of the proposed land allocations, the largest strategic site - Dunton Hills Garden Village - has been progressed as a new garden village, designated by the Government in January 2017. The Draft Plan claims to have arrived at a list of preferred allocations using a site assessment Matrix and supporting technical evidence. However we submit that consultation on the emerging plan to date has resulted in overwhelming objection to DHGV by key stakeholders including the public. In addition the technical evidence that should be available to support this key strategic allocation is absent.

Object

Representation ID: 19732

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The Green Belt Study remains to be completed despite having been undertaken since 2017 and earlier. An "Overview and Technical Note", dated February 2018 refers to work undertaken back in 2013, which found that DHGV location scored higher in terms of its contribution to the Green Belt than land at West Horndon. Work to date has yet to include detailed site assessments. The report confirms
specifically: "the scope of the study did not extend to the identification of Parcels that should be prioritised for allocation for housing, employment, or mixed use...."

Object

Representation ID: 19733

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The evidence base document "Site Assessment Methodology and Summary of Outcomes" (January 2018) is also a working draft and to date contains no individual detailed site assessment. This document can have made no contribution to the selection of preferred development sites. Strategic sites are identified as DHGV, Brentwood North and West Horndon. Reference is made to Appendix 7, which simply comprises a table of sites and accompanying site location plans. No assessment is made of the individual sites. This document defers instead to the SA. The purpose of the technical document (Site Assessment Methodology and Summary of Outcomes) is unknown.

Object

Representation ID: 19734

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

The Council states to have developed a site assessment process that is "robust, balanced and wide-ranging in terms of technical evidence material for each allocated and discounted site." There is no reference to the individual evidence base documents referred to. Many of these are still in draft form, were prepared historically and/or claim that they have not influenced the selection of sites. The 'robust framework' for site selection is shown graphically on page 23. Most of the critical stages of assessment remain to be undertaken. Important evidence base documents have not been updated/prepared in time to influence the Plan.

Object

Representation ID: 19735

Received: 12/03/2018

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Recent DCLG advised a target of 454 dwellings per annum. The Council proposes to stick with 380 dpa. It states that "should the Council need to accommodate this significant increase in housing need, consideration is being given as to whether the delivery of DHGV could be accelerated to increase its dwelling yield within the plan period." Its current capacity is around 2,500 with a possible total yield of 4,000. This assertion is made in the absence of a detailed site assessment. In any event this would result in a single development providing 46% of required housing over the plan period.