brentwood.gov.uk

Object

Representation ID: 1888

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Savills UK

1. Significant proportion- It is considered that paragraph 2.20, and the process it identifies to support the Local Plan is unsound as it does not accord with the key principles of the NPPF. Paragraph 2.20 states that "The preferred spatial strategy seeks to accommodate a significant proportion of this (objectively assessed) development need". This approach does not accord with the NPPF (paragraph 47), as Local Plans should plan to exceed housing targets, not simply accommodate a "significant proportion" of the identified housing need. The Plan makes provision for 3,500 dwellings over the plan period, however OAN, based on household and population projection figures, suggests this figure should be at least 5,600 dwellings. 3,500 dwellings only represents approximately 60% of OAN within BBC, and thus cannot be described as a 'significant' proportion.
2. Limits to Growth- While we acknowledge that the Local Plan must respond to the Borough's environmental characteristics, BBC have not yet carried out a Green Belt assessment, and to conclude that growth above a certain level would lead to "significant impacts" is entirely unjustified. The Plan appears to be based on an assertion-led strategy, with the evidence base still to be finalised after publication of key policies. Given the lack of transparency in the Plan preparation process, the 'preferred' growth strategy is based on constraints that have not been assessed. It instead represents an entirely new approach which has not been consulted on robustly at any of the previous consultation stages. Notwithstanding the lack of evidence explaining the reasoning behind the Plan's inability to meet OAN, PINS have outlined that the constraints identified by BBC should not be used to limit growth required to meet OAN. PINS have identified that LPAs should explore all reasonable options to fulfill OAN. Where constraints are not fixed (i.e. they are not physical constraints such as floodplain), LPAs should plan positively to overcome the identified constraints. It is therefore clear that unfixed constraints including transport capacity and landscape impact should not be used as reasons to limit growth below OAN.