brentwood.gov.uk

LLLP consider that the Strategic Objectives should be modified at an appropriate point in SO1 to clearly state that the Local Plan will meet the Borough's identified housing requirement.

Strategic Objectives
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 Section 3, the Strategic Objectives on page
38.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Strategic Objectives - Overall
4. LLLP are concerned that the none of the four Strategic Objectives identify the need
to meet in full the Borough's housing requirement. The need to meet housing
requirements is noted as one of the spatial strategy driving factors (at paragraph
3.1c) but this has not been translated clearly into the Plan's Strategic Objectives.
5. Coupled with LLLP's concern that the Plan's Vision statement (see LLLP's separate
representation) fails to reflect the three dimensions of sustainable development as
laid out in the National Planning Policy Framework at paragraph 8, it is considered
that the failure to clearly state that the Plan will meet housing needs as one of the
key Strategic Objectives means that the Plan is not effective and is not consistent
with the NPPF.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
Strategic Objective One: Managing Growth Sustainably
6. Strategic Objective One (SO1) is concerned with directing development to the most
sustainable locations in the Borough, ensuring that the characteristics and patterns
of settlements are protected and enhanced to provide a strong sense of place.
7. LLLP supports the intention of SO1 to manage and direct growth to sustainable
locations but is deeply concerned that the proposed spatial strategy and site
allocations resulting fails to achieve this Strategic Objective.
8. LLLP's separate representations (with regard to inter alia: the sequential use of land,
demonstrating housing provision, managing growth and the Dunton Hills Garden
Village proposals) set out greater details of the concerns and deficiencies in the
BBLP's proposed spatial strategy. Those concerns are not re-iterated herein but
provide the context for LLLP's objection to SO1 as drafted.
Conclusions
9. LLLP object to the Strategic Objectives generally (and SO1 in particular) as there is
no firm, clear commitment in any of the stated objectives to meet, in full, the
Borough's housing requirement.
10. The Strategic Objectives are not sound as they are not:
* Positively prepared - clearly establishing that the Plan will have the objective
of meet the area's objectively assessed housing needs;
* Consistent with national planning policies - The Strategic Objectives are not
consistent with national planning policies, including at paragraphs 8, 11(b),
and 16(d).
Modifications Required
11. LLLP consider that the Strategic Objectives should be modified at an appropriate
point in SO1 to clearly state that the Local Plan will meet the Borough's identified
housing requirement.