Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 23662
Received: 19/03/2019
Respondent: M Scott Properties Ltd
Agent: Strutt & Parker LLP
Legally compliant? No
Sound? No
Duty to co-operate? No
The proposed PSLP period runs until 2033. Assuming, optimistically, adoption in 2019, this means that the Local Plan will address development needs for a maximum of 14 years. The NPPF (paragraph 22) is clear that strategic policies should look ahead over a minimum of 15 years from the date of adoption. This deficiency in the PSLP is of particular relevance given that the Borough is predominantly Green Belt, and failure to ensure that development needs are planned for over a sufficient period of time would likely result in an early review of the Green Belt being required.
Paragraphs 1.1 - 1.5 of the PSLP and all references throughout the PSLP including supporting text and Policies should be amended to refer to a period of at least 15yrs from date of adoption. It is suggested that this be at least 2016 - 2035. Policies SP02; HP07; and PC02 should be amended to refer to a minimum of 15yrs from date of adoption with all housing and land requirements adjusted accordingly.
We consider the Local Plan to be unsound in relation to the ability of the plan to meet the needs for older people, and that the identification of suitable sites has not fully considered all available sites in suitable locations, against the need to identify land to meet the need for specialist accommodation. In addition, the Plan in inflexible in meeting the identified need and additional, non-strategic, sites are required for the reasons set out in the representation.
We therefore seek to participate to provide oral explanation of the failures of the Plan in this regard via the examination in order to articulate the case for the recommended modifications as set out in this form and the accompanying representation.