Comment

Representation ID: 19850

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Concern regarding the evidence base and specific wording of the allocations. A care home and 10 gypsy and traveller (G&T) pitches are sought on the Officer's Meadow Site, with the allocations for Sites 158 and 263 for housing and employment only. Although BBC is seeking the provision of a care home and G&T pitches in Shenfield, the sites have not been fully assessed at this stage to determine the most suitable location for these uses. They should not be restricted to the Officer's Meadow Site, the Plan should include provision of these uses across the sites in Shenfield area.

Comment

Representation ID: 19851

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Concern regarding the evidence base and specific wording of the allocations. A care home and 10 gypsy and traveller (G&T) pitches are sought on the Officer's Meadow Site, with the allocations for Sites 158 and 263 for housing and employment only. Although BBC is seeking the provision of a care home and G&T pitches in Shenfield, the sites have not been fully assessed at this stage to determine the most suitable location for these uses. They should not be restricted to the Officer's Meadow Site, the Plan should include provision of these uses across the sites in Shenfield area.

Comment

Representation ID: 19852

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Masterplan: The current consultation document refers to the opportunity for a masterplan for the development of the Officer's Meadow Site and Sites 158 and 263. We have concerns with this approach, with the sites being promoted and controlled by different parties. The sites are all physically separated, with Ancient Woodland between Officer's Meadow and Site 263, and houses separating Site 158 from the others. As such, whilst there may be the opportunity to create pedestrian links between the sites, there are no opportunities to create vehicular links and
development will be separated and will be delivered by differing developers.

Comment

Representation ID: 19853

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

The masterplan required within the current Reg 18 consultation would be required prior to the submission of planning applications for the sites, delaying the submission of these and ultimately the delivery of housing on the sites. As such, whilst the relevant Local Plan Policy may include an indicative plan to demonstrate how development may be located on the sites, the requirement for a masterplan across all 3 sites of the allocations (Officer's Meadow, site 158, site 263) should not be included to ensure the Officer's Meadow Site can be delivered in a timely manner.

Comment

Representation ID: 19854

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Phasing of Sites: The current Reg 18 consultation Plan does not include any reference to the phasing of the sites in the Shenfield area. Given their location, the phasing of the sites in the Shenfield area must be managed and guided by the Local Plan to avoid development separated from the built-up area. Officer's Meadow is the logical first phase, adjoining the existing built-up area of Shenfield and being a logical urban extension.

Comment

Representation ID: 19855

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Whilst some evidence base documents have been published, others are outstanding. This raises some concerns in respect of the allocation of Sites 158 and 263 and the increase in housing within the immediate area. Whilst there are benefits to focusing development in an area, this does have a cumulative impact that must be considered and managed. This is particularly relevant in highway terms with the capacity of the surrounding roads and Mountnessing Roundabout. Similarly, the cumulative impact of development should be assessed in terms of landscape and community infrastructure requirements to ensure the Plan makes adequate provision for infrastructure improvements.

Comment

Representation ID: 19856

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Some evidence base documents remain outstanding. Notably this includes transport studies to consider the higher level of growth proposed and the Housing and Economic Land Availability Assessment (HELAA). The last transport information was published in February 2016, comprising draft highway modelling. The implications of housing and employment growth across the Borough for transport are key considerations that require thorough assessment. This should be undertaken prior to the Reg 19 Local Plan consultation to inform the relevant Policies and ensure a comprehensive planned approach.

Comment

Representation ID: 19857

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

The Site Selection Methodology details a 5 No. stage process for assessing sites, as follows:
1. HELAA
2. Local Plan Spatial Strategy
3. Sustainability Appraisal (SA)
4. Detailed Site Assessment
5. Whole Plan Viability Testing
However, the published Site Selection Methodology only includes a very high-level assessment of sites, which does not follow the detailed 5 No. stage process of assessing sites, being at a very high-level and considering the general location of sites rather than detailed assessments.

Comment

Representation ID: 19858

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Whilst the SA considers reasonable alternatives, these relate to the distribution
of growth across the Borough with the only variables being the potential strategic allocations. As such, the SA does not provide further assessment or clarity of individual sites.

Comment

Representation ID: 19859

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

The Site Selection Methodology refers to the need for more detailed site assessment work, stating at Paragraph 3.23 that this will be 'produced later as emerging evidence is published', with Paragraph 3.40 stating that further work will include 'further updates to the HELAA, detailed site assessments and viability assessment'. The HELAA, detailed site assessment and viability assessment are key aspects of the 5 stage process of assessing sites and the absence of these raises concerns at the assessment that has been undertaken of additional allocated sites.