Preferred Site Allocations 2018

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Comment

Preferred Site Allocations 2018

Fig. 15. Primary School Capacity

Representation ID: 19619

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

The RAG coding is not explained in the text of the document and we consider that it should be in order to understand the significance of the assessment.

Full text:

Figure 9 - we note that this figure neglects to identify the brownfield opportunities in Green Belt locations. We object to this omission and request that it be amended to note that this has been factored into the development strategy. Redrow Homes is in the process of bringing forward a large brownfield site at Ingatestone Garden Centre. The redevelopment of this derelict site in the Green Belt will assist in meeting identified needs and in restoring the appearance of the area. It is right that the brownfield land allocation within the Green Belt is acknowledged and would be consistent with the requirements of the draft NPPF. Interim Sustainability Appraisal (SA) - The Interim SA advises that it welcomes comments from stakeholders. Redrow Homes owns one of
the proposed allocation sites (site 128). It intends to bring this site forward for development as soon as planning permission is granted. Site 128 is included in the Interim SA and the appraisal so far raises a few concerns that Redrow Homes wishes to comment on. These relate to the topics used for assessment and how these have been applied to this site. Special Landscape Area - Site 128 is given an amber rating for this in Table C and the notes in Table B say that this is to reflect potential the effects on landscape. It is unclear how this can be assessed at this stage as there is no reference as to what is special about the landscape that could be affected and no account is take of the existing redundant nature of the site. It is further noted that the SLA designation is not proposed to be carried forward into the new development plan. It is also noted at Table A that "Limited data is available to inform the appraisal. Work is ongoing to ensure that all site options are categorised in terms of potential for landscape impacts and also the potential to result in loss of functioning Green Belt (i.e. Green Belt that meets the established purposes). This work will be drawn upon in the future." It is apparent, therefore, that this rating will need to be updated when further information is available and we would ask that it also include an assessment that takes into account the existing nature of the site, the potential for landscape enhancement and the removal of the SLA designation. Distances to facilities (criteria 7-9) - It is noted that Department of Transport walking distance guidelines have been used to rate the distance from these facilities. Consideration should be given to departing from these in light of the health benefits of walking and the NHS guidance that specifically encourages walking to maintain a healthy lifestyle. For these reasons it is considered that the walking distances should be extended. Site allocation 128 - we note that this site is described as being a self-contained urban extension with the neighbouring site (site 106). Redrow Homes owns site 128 and is bringing this forward for development. It has no control over site 106 and would not wish the wording of the allocation to be misconstrued as meaning that both sites must come forward together. The proximity of the site to the settlement boundary means that is clearly an urban extension and therefore it is suggested that the reference to site 106 is unnecessary. As such, it is requested that this be deleted from the allocation summary. SO1 - we support the strategic objective to maximise the sustainable growth opportunities of brownfield sites. Redrow Homes has a large brownfield site at Ingatestone Garden Centre that it is bringing forward for development. The use of such sites ensures that greenfield site release can be minimised and that previously developed land can be re-used to meet existing needs. SO3 - we support the strategic objective to support the sustainable growth of existing larger villages to provide improved housing choice and protect services and facilities. This is a welcome recognition of the benefits arising from developments in such locations. Figure 15 - the RAG coding is not explained in the text of the document and we consider that it should be in order to understand the significance of the assessment.

Support

Preferred Site Allocations 2018

Fig. 3. Strategic Objectives

Representation ID: 19620

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

SO1: we support the strategic objective to maximise the sustainable growth opportunities of brownfield sites. Redrow Homes has a large brownfield site at Ingatestone Garden Centre that it is bringing forward for development. The use of such sites ensures that greenfield site release can be minimised and that previously developed land can be re-used to meet existing needs. SO3: we support the strategic objective to support the sustainable growth of existing larger villages to provide improved housing choice and protect services and facilities. This is a welcome recognition of the benefits arising from developments in such locations.

Full text:

Figure 9 - we note that this figure neglects to identify the brownfield opportunities in Green Belt locations. We object to this omission and request that it be amended to note that this has been factored into the development strategy. Redrow Homes is in the process of bringing forward a large brownfield site at Ingatestone Garden Centre. The redevelopment of this derelict site in the Green Belt will assist in meeting identified needs and in restoring the appearance of the area. It is right that the brownfield land allocation within the Green Belt is acknowledged and would be consistent with the requirements of the draft NPPF. Interim Sustainability Appraisal (SA) - The Interim SA advises that it welcomes comments from stakeholders. Redrow Homes owns one of
the proposed allocation sites (site 128). It intends to bring this site forward for development as soon as planning permission is granted. Site 128 is included in the Interim SA and the appraisal so far raises a few concerns that Redrow Homes wishes to comment on. These relate to the topics used for assessment and how these have been applied to this site. Special Landscape Area - Site 128 is given an amber rating for this in Table C and the notes in Table B say that this is to reflect potential the effects on landscape. It is unclear how this can be assessed at this stage as there is no reference as to what is special about the landscape that could be affected and no account is take of the existing redundant nature of the site. It is further noted that the SLA designation is not proposed to be carried forward into the new development plan. It is also noted at Table A that "Limited data is available to inform the appraisal. Work is ongoing to ensure that all site options are categorised in terms of potential for landscape impacts and also the potential to result in loss of functioning Green Belt (i.e. Green Belt that meets the established purposes). This work will be drawn upon in the future." It is apparent, therefore, that this rating will need to be updated when further information is available and we would ask that it also include an assessment that takes into account the existing nature of the site, the potential for landscape enhancement and the removal of the SLA designation. Distances to facilities (criteria 7-9) - It is noted that Department of Transport walking distance guidelines have been used to rate the distance from these facilities. Consideration should be given to departing from these in light of the health benefits of walking and the NHS guidance that specifically encourages walking to maintain a healthy lifestyle. For these reasons it is considered that the walking distances should be extended. Site allocation 128 - we note that this site is described as being a self-contained urban extension with the neighbouring site (site 106). Redrow Homes owns site 128 and is bringing this forward for development. It has no control over site 106 and would not wish the wording of the allocation to be misconstrued as meaning that both sites must come forward together. The proximity of the site to the settlement boundary means that is clearly an urban extension and therefore it is suggested that the reference to site 106 is unnecessary. As such, it is requested that this be deleted from the allocation summary. SO1 - we support the strategic objective to maximise the sustainable growth opportunities of brownfield sites. Redrow Homes has a large brownfield site at Ingatestone Garden Centre that it is bringing forward for development. The use of such sites ensures that greenfield site release can be minimised and that previously developed land can be re-used to meet existing needs. SO3 - we support the strategic objective to support the sustainable growth of existing larger villages to provide improved housing choice and protect services and facilities. This is a welcome recognition of the benefits arising from developments in such locations. Figure 15 - the RAG coding is not explained in the text of the document and we consider that it should be in order to understand the significance of the assessment.

Comment

Preferred Site Allocations 2018

128 Ingatestone Garden Centre, Roman Road, Ingatestone

Representation ID: 19621

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

We note that this site is described as being a self-contained urban extension with the neighbouring site. It is requested that this be deleted from the allocation summary. This site is evaluated in the SA. Under Special Landscape Area this site received an amber rating. It is unclear as to how this determination was made. This rating will
need to be updated when further information is available and we would ask that it includes an assessment that takes into account the existing nature of the site, potential landscape enhancement and the removal of the SLA designation. Removal of walking distance.

Full text:

Figure 9 - we note that this figure neglects to identify the brownfield opportunities in Green Belt locations. We object to this omission and request that it be amended to note that this has been factored into the development strategy. Redrow Homes is in the process of bringing forward a large brownfield site at Ingatestone Garden Centre. The redevelopment of this derelict site in the Green Belt will assist in meeting identified needs and in restoring the appearance of the area. It is right that the brownfield land allocation within the Green Belt is acknowledged and would be consistent with the requirements of the draft NPPF. Interim Sustainability Appraisal (SA) - The Interim SA advises that it welcomes comments from stakeholders. Redrow Homes owns one of
the proposed allocation sites (site 128). It intends to bring this site forward for development as soon as planning permission is granted. Site 128 is included in the Interim SA and the appraisal so far raises a few concerns that Redrow Homes wishes to comment on. These relate to the topics used for assessment and how these have been applied to this site. Special Landscape Area - Site 128 is given an amber rating for this in Table C and the notes in Table B say that this is to reflect potential the effects on landscape. It is unclear how this can be assessed at this stage as there is no reference as to what is special about the landscape that could be affected and no account is take of the existing redundant nature of the site. It is further noted that the SLA designation is not proposed to be carried forward into the new development plan. It is also noted at Table A that "Limited data is available to inform the appraisal. Work is ongoing to ensure that all site options are categorised in terms of potential for landscape impacts and also the potential to result in loss of functioning Green Belt (i.e. Green Belt that meets the established purposes). This work will be drawn upon in the future." It is apparent, therefore, that this rating will need to be updated when further information is available and we would ask that it also include an assessment that takes into account the existing nature of the site, the potential for landscape enhancement and the removal of the SLA designation. Distances to facilities (criteria 7-9) - It is noted that Department of Transport walking distance guidelines have been used to rate the distance from these facilities. Consideration should be given to departing from these in light of the health benefits of walking and the NHS guidance that specifically encourages walking to maintain a healthy lifestyle. For these reasons it is considered that the walking distances should be extended. Site allocation 128 - we note that this site is described as being a self-contained urban extension with the neighbouring site (site 106). Redrow Homes owns site 128 and is bringing this forward for development. It has no control over site 106 and would not wish the wording of the allocation to be misconstrued as meaning that both sites must come forward together. The proximity of the site to the settlement boundary means that is clearly an urban extension and therefore it is suggested that the reference to site 106 is unnecessary. As such, it is requested that this be deleted from the allocation summary. SO1 - we support the strategic objective to maximise the sustainable growth opportunities of brownfield sites. Redrow Homes has a large brownfield site at Ingatestone Garden Centre that it is bringing forward for development. The use of such sites ensures that greenfield site release can be minimised and that previously developed land can be re-used to meet existing needs. SO3 - we support the strategic objective to support the sustainable growth of existing larger villages to provide improved housing choice and protect services and facilities. This is a welcome recognition of the benefits arising from developments in such locations. Figure 15 - the RAG coding is not explained in the text of the document and we consider that it should be in order to understand the significance of the assessment.

Object

Preferred Site Allocations 2018

Fig. 9. Proposed Housing-Led Allocations

Representation ID: 19622

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

This figure neglects to identify the brownfield opportunities in Green Belt locations. We object to this omission and request that it be amended to note that this has been factored into the development strategy. Redrow Homes is in the process of bringing forward a large brownfield site at Ingatestone Garden Centre. The redevelopment of this derelict site in the Green Belt will assist in meeting identified needs and in restoring the appearance of the area. It is right that the brownfield land allocation within the Green Belt is acknowledged and would be consistent with the requirements of the draft NPPF.

Full text:

Figure 9 - we note that this figure neglects to identify the brownfield opportunities in Green Belt locations. We object to this omission and request that it be amended to note that this has been factored into the development strategy. Redrow Homes is in the process of bringing forward a large brownfield site at Ingatestone Garden Centre. The redevelopment of this derelict site in the Green Belt will assist in meeting identified needs and in restoring the appearance of the area. It is right that the brownfield land allocation within the Green Belt is acknowledged and would be consistent with the requirements of the draft NPPF. Interim Sustainability Appraisal (SA) - The Interim SA advises that it welcomes comments from stakeholders. Redrow Homes owns one of
the proposed allocation sites (site 128). It intends to bring this site forward for development as soon as planning permission is granted. Site 128 is included in the Interim SA and the appraisal so far raises a few concerns that Redrow Homes wishes to comment on. These relate to the topics used for assessment and how these have been applied to this site. Special Landscape Area - Site 128 is given an amber rating for this in Table C and the notes in Table B say that this is to reflect potential the effects on landscape. It is unclear how this can be assessed at this stage as there is no reference as to what is special about the landscape that could be affected and no account is take of the existing redundant nature of the site. It is further noted that the SLA designation is not proposed to be carried forward into the new development plan. It is also noted at Table A that "Limited data is available to inform the appraisal. Work is ongoing to ensure that all site options are categorised in terms of potential for landscape impacts and also the potential to result in loss of functioning Green Belt (i.e. Green Belt that meets the established purposes). This work will be drawn upon in the future." It is apparent, therefore, that this rating will need to be updated when further information is available and we would ask that it also include an assessment that takes into account the existing nature of the site, the potential for landscape enhancement and the removal of the SLA designation. Distances to facilities (criteria 7-9) - It is noted that Department of Transport walking distance guidelines have been used to rate the distance from these facilities. Consideration should be given to departing from these in light of the health benefits of walking and the NHS guidance that specifically encourages walking to maintain a healthy lifestyle. For these reasons it is considered that the walking distances should be extended. Site allocation 128 - we note that this site is described as being a self-contained urban extension with the neighbouring site (site 106). Redrow Homes owns site 128 and is bringing this forward for development. It has no control over site 106 and would not wish the wording of the allocation to be misconstrued as meaning that both sites must come forward together. The proximity of the site to the settlement boundary means that is clearly an urban extension and therefore it is suggested that the reference to site 106 is unnecessary. As such, it is requested that this be deleted from the allocation summary. SO1 - we support the strategic objective to maximise the sustainable growth opportunities of brownfield sites. Redrow Homes has a large brownfield site at Ingatestone Garden Centre that it is bringing forward for development. The use of such sites ensures that greenfield site release can be minimised and that previously developed land can be re-used to meet existing needs. SO3 - we support the strategic objective to support the sustainable growth of existing larger villages to provide improved housing choice and protect services and facilities. This is a welcome recognition of the benefits arising from developments in such locations. Figure 15 - the RAG coding is not explained in the text of the document and we consider that it should be in order to understand the significance of the assessment.

Comment

Preferred Site Allocations 2018

An Evolving Evidence Base

Representation ID: 19806

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

In particular Redrow supports the Spatial Strategy which has a clear rationale and which reflects well the spatial patterns and dynamics of the Borough. However Redrow have concerns about how the release of land from the Green Belt is justified. The Council has not expressly demonstrated exceptional circumstances to justify significant areas of land being taken out of the Green Belt. Steps have been taken, but not described in the Local Plan in terms that reflect the provisions of the National Planning Policy Framework (NPPF). This information should be included to justify the changes to the greenbelt.

Full text:

See attached.

Support

Preferred Site Allocations 2018

263 Land east of Chelmsford Road, Shenfield

Representation ID: 19807

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

The Draft Plan shows this site as coming forward in years 5-10 of the Plan period. Redrow Homes believe that in the absence of any site specific constraints which might affect delivery timescales and the sustainability credentials, there is the opportunity to bring the site forward to support the five-year housing land supply. Redrow would seek to ensure that the masterplanning exercise was high level to ensure that all sites could still be delivered separately. the combined development provides for new primary school provision; further details required.

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Fig. 7. Site Assessment Process

Representation ID: 19808

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

This figure, Figure 7 "Site Assessment Process", does not demonstrate the complexities that the council faces when deciding on the release of Green Belt land. Stage 4 shows Green Belt as one of several criteria used to assess sites, yet Green Belt has a different planning status and its application in plan-making and decision-making differs from that of other criteria. This diagram does not seem to be consistent with others showing the sequential approach e.g. Figure 4 "Developing the Spatial Strategy". The Council should reconsider Figure 7 to provide suitable clarity.

Full text:

See attached.

Comment

Preferred Site Allocations 2018

Fig. 11. Sites by Size

Representation ID: 19809

Received: 12/03/2018

Respondent: Redrow Homes

Representation Summary:

The first column heading should probably be "Site Size"

Full text:

See attached.

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