Object
Local Plan 2015-2030 Preferred Options for Consultation
Representation ID: 731
Received: 02/10/2013
Respondent: Countryside Properties
Agent: Phase 2 Planning and Development Ltd
The starting point for establishing the quantum of residential development to be provided within the Plan period should be to meet 'objectively assessed needs' in accordance with paragraph 14, NPPF. The option chosen is contrary to the NPPF and therefore it is inappropriate as it fails to meet 'objectively assessed needs' and there is a lack of evidence to justify this approach. The Plan also fails to "positively seek opportunities to meet the development needs of their area" . There is no evidence to support the selected level of residential development. Further sites should be considered that will help to meet the objectively assessed needs without resulting in adverse impacts that would "significantly and demonstrably outweigh the benefits" (NPPF, paragraph 14). Sites identified within the Council's SHLAA as being 'suitable, available and achievable', such as land at Bayleys Mead could contribute towards fulfilling this objective, providing residential development adjoining the urban area of Brentwood. This site should be allocated for development within the Plan period.
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.