brentwood.gov.uk

Object

Representation ID: 3396

Received: 01/10/2013

Respondent: Mrs. F. Rasch

Agent: Pegasus Group

Relying solely on the impact on the Green Belt as a reason not to provide objectively assessed need is not adequate.The Council is relying on a forthcoming Landscape Sensitivity Testing and Green Belt Assessment and a 2006 Mid Essex Landscape Character Assessment in reaching the conclusions of harm to the Green Belt.

It is considered that the 2006 assessment is out of date and does not comply with the current guidance as set out in the NPPF. It is difficult to challenge or assess the conclusions of the forthcoming reports if these have not be published concurrently with the Local Plan. Therefore it is considered unsound to rely on out of date and unpublished data.
The Council themselves in allocating a significant level of housing in the Green Belt (1,500 houses at West Horndon Policy CP4) has already assessed that in certain very special circumstances it is appropriate to allocate houses in the Green Belt. Presumably this relies on the conclusions of the unpublished studies. However, the significant boost to housing supply can be also be considered as a very special circumstance as tested at a number of appeals. Therefore it is considered that additional assessment is needed as to the balance between the adverse impacts outweighing the benefits of housing supply.