Rochford District Core Strategy Regulation 26 Draft

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.