Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 24075

Received: 20/05/2019

Respondent: LaSalle Land Limited Partnership

Agent: Chilmark Consulting Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Vision is not effective. Unclear what landscape-led or design and build with nature means or how this is translated into the proposed Dunton hill Garden Village allocation. Also unclear from the Vision Statement and supporting text how a landscape led approach accords with the definition of sustainable development established in the NPPF at paragraph 8. Overemphasis on environmental, needs more on economic and social. Therefor plan is not consistent with national policy and is unsound.

Change suggested by respondent:

. LLLP conclude that amendment of the Vision Statement is required to ensure it
properly reflects the three overarching national planning policy objectives for
sustainable development and in particular makes an explicit reference to meeting in
full the Borough's housing needs

Full text:

Representations for and on LaSalle Land Limited Partnership
Vision and Spatial Strategy Driving Factors
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with the Plan's Vision and Spatial Strategy Driving
Factors set out in Section 3.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Vision Statement
4. The Plan's Vision statement set out at page 35 is not clear. It refers to a:
"landscape-led development, where new development responds to a 'design and
build with nature' approach...".
5. LLLP does not consider that the Vision represents an effective statement. It is not
clear what is meant by "landscape-led" and "design and build with nature" or how
this is then translated into the proposed allocation of significant housing land in the
Dunton Hills Garden Village, which would involve a very significant intrusion into the
existing countryside landscape and impacts on biodiversity and ecological systems.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
6. It is also unclear from the Vision Statement and supporting text how a landscapeled
approach accords with the definition of sustainable development established in
the NPPF at paragraph 8 which identifies three overarching and inter-dependent
objectives: (a) economic; (b) social; (c) and environmental.
7. It is considered that a "landscape-led" and "design with nature" approach may help
meet (c) the environmental objective of the NPPF but over-emphasises this to the
detriment of meeting objectives (a) and (b) of paragraph 8 which are equally
important.
8. The Vision statement fails to set out the need to meet housing growth requirements
which are described at paragraph 3.1 (c) (within the section Spatial Strategy Driving
Factors), to include meeting the Borough's housing needs.
Conclusions
9. LLLP object to the plan's Vision Statement. The Vision is not sound as it is not:
* Consistent with National Policy - for the reasons identified in this
representation, LLLP does not consider that the Vision statement is
consistent with the NPPF definition of sustainable development which
underpins the approach to plan-making.
Modifications Sought
10. LLLP conclude that amendment of the Vision Statement is required to ensure it
properly reflects the three overarching national planning policy objectives for
sustainable development and in particular makes an explicit reference to meeting in
full the Borough's housing needs

Attachments: