Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 1302
Received: 01/10/2013
Respondent: Mrs. F. Rasch
Agent: Pegasus Group
Policy S2 states that 3,500 dwellings need to be built in the Borough between 2015- 2030 (200-250 dwellings pa). There is concern regarding the justification in paragraphs 2.22 - 2.37. In summary, the concerns are:
1.The plan period starts in 1.5 years time not immediately, There is no explanation in the preamble to the policy as to why the plan period does not start immediately and what allowance is made for either the shortfall or over provision which may occur in the next year or previous years. It is considered that there needs to be an allowance made for the under or over supply of housing at March 2015 in order to ensure that the housing provision as set in Policy S2 is sound;
2.The housing provision is significantly lower than the objectively-assessed need for the Borough of 331-362 dwellings per year. The conclusions at Para. 2.20 are questionable and it is not considered that the adverse impacts reported by Brentwood Council have been assessed appropriately to conclude that they significantly and demonstrably outweigh the benefits of providing sufficient housing in the Borough.
3.No evidence of a duty-to-cooperate with neighbouring authorities in relation to locating any additional housing growth.
4. Alternative Option 1 which relates to the objectively assessed need is listed in Policy S2 and the reasons for rejection relate to the perceived environmental impact of such a level of housing provision. However, there is no assessment of the benefits which would be received by a significant boost to the housing supply in the Borough, as required by the NPPF, and therefore these do not seem to have been taken into account when selecting the housing options.
It is considered of paramount importance for the Council to demonstrate that the impact of not providing an adequate supply of housing in the Borough to meet the identified need has been assessed as part of the identification of an appropriate housing provision.
See attached