brentwood.gov.uk

Policy SP05, Construction Management (page 58)
Criterion B might usefully clarify that this refers to "... other major 'committed' development..."

Policy SP01, Sustainable Development (page 46 - 47)
Criterion B and C of Policy SP01 unnecessarily repeats the NPPF and could be removed.
Criterion D(i) should be amended to reflect multiple heritage assets and conservation areas.

Local Housing Need (page 48 - 50)
Since the Regulation 19 Local Plan was published, the Ministry of Housing, Communities and Local Government has confirmed its position on the standard method for calculating housing need (19 February 2019) which is of relevant to this Plan. In response, the Council will need to update explanatory text in Chapter 4 of the Local Plan to reflect the use of 2014 rather than 2016 household projections.
The Planning Practice Guidance makes clear that the standard method formula is used to identify the minimum number of new homes to be planned for and does not in itself establish a housing requirement figure. The Council's housing requirement figure is set out in the Plan at 456 dpa and this figure is in excess, albeit only slightly, of the standard method figure (452 dpa) using the 2014 projections and is sufficient. The requirements of national policy are met and the plan is sound.
The Council states that in including its 'annual housing supply buffer' on top of the 350 dpa (derived from use the standard method calculation using the 2016 projections) it serves to safeguard against any potential uplift to the standard method, this now having materialised. This was a sensible contingency. Considering this buffer has now effectively absorbed within the updated standard method figure the Council is requested to confirm if its purpose has now been served and it intends to submit the plan to examination with the housing requirement as currently stated.
CEG supports the Council's reliance on a stepped trajectory which, in accordance with the Planning Practice Guidance (paragraph 34, Ref. ID: 3-034-20180913), is appropriate in circumstances where: there is to be a significant change in the level of housing requirement between the adopted and emerging Local Plans, as is the case here; and, recognising that many sites will not be available for development until the adoption of the plan, reflecting the high proportion of designated Green Belt in the Borough.
CEG is committed to bringing forward the provision of new homes on Dunton Hills Garden Village (DHGV) as early as possible in the Plan period and is working closely with the Council and Homes England to achieve this.

Policy SP02, Managing Growth (page 50) & Figure 4.2 (page 51)
A modification to Policy SP02(A) and Figure 4.2 is proposed in our response to question no. 6 to acknowledge that housing provision should represent a 'minimum' for consistency with national policy and guidance, and Local Plan Policy R01.

Policy SP05, Construction Management (page 58)
Policy SP05 requires developers to take a considered approach to construction management and seeks to manage construction activity to minimise local disturbance. CEG supports this policy and will bring forward the development at DHGV in this way. Criterion B might usefully clarify that this refers to other major 'committed' development.

Policy SP06, Effective Delivery of Development (page 60)
Policy SP06 requires development proposals for large allocation sites to be developed in partnership with the Council, infrastructure providers and relevant organisations through a masterplanning approach. This may include an independent Design Review Panel process, which is an approach supported by the NPPF (paragraph 129). CEG supports this policy and is bringing forward the development of DHGV in this manner, with an independent Design Review Panel process and working in partnership with the Council and other relevant organisations as necessary.
A footnote might usefully clarify what constitutes large complex allocation sites as far as the Council is concerned.