Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 728
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
1.The premise of the spatial strategy appears to be to protect the Green Belt around the two principal urban areas of Brentwood and Shenfield and that this overrides other requirements such as meeting 'objectively assessed needs' in accordance with the NPPF. The starting point for establishing the quantum of residential development to be provided within the Plan period should to meet 'objectively assessed needs' (Paragraph 14, NPPF). This was assessed by the Council (Alternative Option 1) and rejected on the basis that this level of growth (4,960 to 5,600 dwellings) "would require significant Green Belt release, significantly worsen congestion in Brentwood Town Centre and irrevocably change the rural character of the Borough." It goes on to state that "significant investment in infrastructure and services would be required to support this level of growth and there is no guarantee this would be forthcoming", none of the evidence base documents produced to date give a clear indication of the extent of Green Belt land required to meet needs relative to the Borough as a whole or an assessment on the impact of this level of development on the rural character of the Borough.
2.In the cases of congestion, infrastructure and services it is not disputed that further development may well have an impact as additional homes and people will result in increased use of infrastructure, but again there is no assessment of the extent of this impact and likely implications, and consequently it is difficult to respond with conclusions on how to quantify the impact. The Plan proposes to expand West Horndon with new infrastructure as part of the development, but does not make clear why the same approach cannot apply to other sites.
3.As many of the evidence base documents referred to in the Draft Local Plan are not currently available, it is not possible to assess whether the impact of meeting objectively assessed needs would "significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole" (NPPF, paragraph 14). It is queried whether these documents were prepared in advance of the Local Plan or whether they are being retrospectively prepared to accord with the 'revised' strategy. Green Belt sites identified as having potential for development in the SHLAA should be considered for inclusion within the Plan with a consequential amendment to Green Belt releases in this policy.
4.Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
1.The spatial strategy is not founded on an 'adequate, up-to-date and relevant evidence' base and is therefore fundamentally flawed, failing to accord with the NPPF (paragraph 158). The Plan adopts an arbitrary approach to residential development by restricting development in the Green Belt rather than positively seeking opportunities to meet the development needs of the Borough. There is no comprehensive justification for failing to meet objectively assessed needs.
2.Despite identifying that the Borough cannot meet its own housing needs, the Council has failed to seek to meet those needs by cooperating with neighbouring authorities, summarised as follows:
*The City Council disagrees with Brentwood Borough Council's Preferred Spatial Strategy which does not seek to accommodate its full housing need.
*The City Council disagrees with Brentwood Borough Council's approach of looking to neighbouring authorities to meet unmet need.
*The City Council raises concerns regarding the deliverability of sites, such as the strategic allocations in West Horndon, identified for housing in the Preferred Options Local Plan.
*The City Council objects to the Preferred Options Local Plan being published for public consultation prior to key relevant evidence base documents being made available.
Proposed Changes to the Plan: Policy S1: Spatial Strategy should be amended to change the word 'redevelopment' in the first paragraph to 'development'. The final paragraph should be deleted and replaced with the following wording:
"Amendments shall be made to the Green Belt to enable the following development:
i. Strategic Allocation at West Horndon;
ii. Allocation at land east of Bayleys Mead; and
iii. Existing developed sites in the Green Belt."
3. The Key Diagram ( figure 2.10) should be amended to show housing sites and the release of Green Belt land in accordance with representations and policies S1 and S2.