brentwood.gov.uk

Object

Representation ID: 776

Received: 02/10/2013

Respondent: Crest Nicholson

Agent: Bidwells

My client objects entirely to the Council's proposed strategy in relation to the amount and distribution of growth in the Borough on the basis that it conflicts with the National Planning Policy Framework. It should be noted that it also conflicts with the Council's proposed spatial strategy set out in Policy S1 of the draft Local Plan.

1.Brentwood Borough's Objectively Assessed Housing Need. It is difficult to fully understand the OAN for Brentwood Borough because at the time of writing the Council had not published it. Notwithstanding my client's reservations over the process and evidence base, it is nonetheless clear that the OAN figure for the Borough is substantially higher than the target proposed by the Local Plan at policy S2. In this context Brentwood Borough Council's housing target is wholly inadequate and cannot be considered sound.
2.Constraints to meeting OAN. We accept that the Framework attaches great importance to Green Belt and its permanence however due to the considerable deficit between the targeted growth and OAN one would expect that exceptional circumstances exist and therefore a robust assessment of Green Belt boundaries is justified in this instance.
3.Quality of the Evidence. In the first instance we question the omission of a large number of sites which were assessed as suitable, available and deliverable by the Council's SHLAA and did not present insurmountable constraints in the published 'Supporting Document: Draft Site Assessment'. In the case of my client's land at Nags Head Lane, Brentwood the Council's reasons for discounting it (and many other sites) are unknown despite the site assessment suggesting it is actually a suitable allocation. We are therefore left to assume that the site has been discounted almost entirely on the basis of its designation as Green Belt, which does not acord with NPPF.