Object
Draft Local Plan
Representation ID: 13670
Received: 23/03/2016
Respondent: Mr Sasha Millwood
I object to the Council's imposing an arbitrarily and unnecessarily high target. The 'objective' level may have been overestimated, and, in any case, the NPPF (paragraph 34 of the Planning Practice Guidance especially) makes clear that the green belt is a higher priority, and an admissible defence for setting a significantly lower target than the 'objective' level would suggest. I therefore call upon the Council to stick with the old regional target, which, in the circumstances, is unlikely to be deemed 'unsound' -- even if it were, I would want my Council to stand up and fight for its residents.
Re 5.9: how did the Council magically come up with this figure between the old regional target and the 'objective' need? Given the green belt is accorded a higher priority in the NPPF than so-called 'objective' targets, there is a strong case for sticking with the old regional target.
Re 5.10: The NPPF is clear in stipulating that the green belt is adequate reason for not meeting so-called 'objective' needs. I would rather the Council risked being found 'structurally unsound' and, if necessary, take up a legal battle to preserve the green belt. The 'structually unsound' precedents cited by the Council to scaremonger us into submission come from districts with far less/no green belt, such as Uttlesford, therefore the cases are not comparable. Paragraph 34 of the Planning Practice Guidance stipulates that "Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the 'very special circumstances' justifying inappropriate development on a site within the Green Belt." Paragraphs 44 and 45 also make clear that Objectively Assessed Housing Need is not the only pertinent factor in determining housing targets, and the significant amount of green belt land in the Brentwood and Basildon districts would be sufficient justification to set housing targets at a far lower level. Finally, it is worth noting that the report for 'objective' need concedes it may have overestimated the figure, since housing completion rates during the recession were anomalously large due to the conclusion of several major projects that had started before the recession (see ยง5.28). This means that projections that may have been appropriate for other local authorities are likely to be overestimates in the case of Brentwood.